Introduction
The Department of Homeland Security has finalized a sweeping update to the alien registration framework through a final rule published in the Federal Register on June 29, 2026, that formally adopts the March 2025 Interim Final Rule on alien registration form requirements. The finalized alien registration rule responds to thousands of public comments, makes several technical and substantive changes to the forms and documents that satisfy registration obligations under the Immigration and Nationality Act, and simultaneously solicits additional public input on proposed future changes to the regulation. The rule took effect immediately upon publication and carries real consequences for anyone in the United States who may be unregistered or uncertain about their registration status.
Background
The Longstanding Statutory Framework
The United States has maintained alien registration requirements since the Alien Registration Act of 1940, which were later incorporated into the Immigration and Nationality Act in 1952. Most noncitizens who stay in the United States for 30 days or longer must register with the federal government and, with limited exceptions, undergo fingerprinting. Those who register must also carry evidence of registration at all times once they turn 18, and must notify DHS of any change of address within 10 days of moving. Willful failure to comply carries criminal penalties, including fines and potential imprisonment.
Despite this long-standing statutory obligation, prior to early 2025, a meaningful gap existed in the regulatory framework: there was no general registration form available to noncitizens who had not previously had a reason to interact with DHS through visa applications, immigration court proceedings, or formal benefit requests. Many individuals who lacked a prescribed registration form were technically in violation of the statute with no clear path to compliance.
What Is Changing
What the Final Rule Does
The March 2025 IFR addressed that gap by designating Form G-325R, Biographic Information (Registration), as a universal registration option available to any unregistered noncitizen regardless of immigration status. The June 2026 final rule adopts that IFR without changes to its core provisions and adds several additional modifications informed by the more than 4,000 public comments DHS received.
The most significant changes the final rule makes to the existing regulatory tables are as follows.
Removing forms
DHS removed three obsolete forms from the list of prescribed registration forms at 8 CFR 264.1(a): Form I-67 (used for Hungarian refugees under a 1958 statute), Form I-691 (used under the 1986 legalization program), and Form I-700 (used under the Special Agricultural Worker program). These forms are no longer accepted and can no longer be submitted to satisfy registration requirements. Aliens who used them while they were valid retain their registered status.
Updating Forms
DHS updated multiple form names and entry descriptions to reflect current USCIS practice, including correcting the title of Form I-485 and Form I-590 and adding explicit references to Form I-94A and I-94W as subcategories of the standard I-94 registration pathway.
New Forms
DHS added three new forms of evidence of registration to the list at 8 CFR 264.1(b): Form I-860 (Notice and Order of Expedited Removal), Form I-871 (Notice of Intent/Decision to Reinstate Prior Order), and CBP-approved documents or their electronic equivalents for the Trusted Traveler Programs NEXUS, SENTRI, FAST, and Global Entry for aliens last admitted through those programs. This last addition is particularly significant for Canadian and other frequent cross-border travelers who participate in these programs.
DHS restructured the fingerprinting waiver provisions at 8 CFR 264.1(e) for clarity and clarified that NATO-7 nonimmigrants — the attendants, servants, and personal employees of NATO representatives — do not qualify for the fingerprinting waiver that applies to the representatives themselves.
In this final rule, DHS confirmed that it will not impose the $30 biometric services fee proposed in the IFR, but it reserved the right to revisit that question in future rulemaking.
Who Is Affected
Direct and Indirect Effects
The populations most directly affected by this rule fall into several overlapping categories.
Unregistered noncitizens who have not previously received a visa or been issued a Form I-94 must still register. They must use Form G-325R if they have not interacted with DHS through a recognized registration pathway. DHS estimated this population at between 2.9 and 3.5 million individuals at the time of the IFR.
Canadian citizens entering the United States through land ports without a Form I-94 must register if they stay for 30 days or more. However, if they last entered through NEXUS, SENTRI, FAST, or Global Entry, their Trusted Traveler documentation is recognized as proof of registration.
Noncitizens who turn 14 years old in the United States must re-register within 30 days of their birthday, even if they were previously registered as minors. This requirement applies across visa categories, including F and J nonimmigrant students.
Asylum applicants and TPS holders who do not hold a Form I-766 Employment Authorization Document are generally not considered registered under existing regulations, though DHS is seeking comments on whether to change this in future rulemaking.
Noncitizens who hold a valid Form I-766 remain registered under current rules. DHS is actively considering removing the EAD from the list of evidence of registration in future rulemaking. This significant potential change should be monitored closely by affected individuals and employers.
Registered individuals, such as visa holders admitted through a U.S. embassy or consulate and lawful permanent residents, do not need to act under this rule. However, those uncertain of their status can use Form G-325R as a compliance tool.
Practical Implications
What This Means in Practice
Unregistered individuals must create a myUSCIS account at my.uscis.gov, complete Form G-325R electronically, and attend a USCIS Application Support Center appointment for biometrics collection if fingerprinting is required. DHS currently does not charge a filing fee for this process. USCIS electronically issues a USCIS Proof of Alien G-325R Registration document to the applicant’s myUSCIS account after they submit their biometrics. That document satisfies the statutory requirement to carry evidence of registration for adults 18 and older.
For registered noncitizens who hold a Form I-766 as their sole evidence of registration, the potential future removal of the EAD from the registration list is worth tracking carefully. If that proposal is finalized, individuals may need to register through Form G-325R or another pathway to maintain compliance. That change has not yet occurred and remains in the comment stage only.
For attorneys and HR professionals advising employers, this rule adds complexity to compliance reviews. Many workers hold only an EAD and lack another recognized registration document. Proposed future changes could affect these individuals’ registration status. Additionally, Canadian business visitors who stay in the United States for extended periods may now find themselves subject to registration requirements that were not previously a compliance priority.
For Trusted Traveler Program participants, the explicit recognition of NEXUS, SENTRI, FAST, and Global Entry documents as evidence of registration is a meaningful clarification that removes uncertainty for this population.
One important open question is whether DHS will expand the list of forms recognized as registration forms — including potentially adding Form I-589, I-539, I-821, I-914, I-918, and other commonly filed petitions. DHS has proposed adding many of these in Section V of the final rule and is soliciting public input on that question.
What to Watch For Next
The comment period on the proposed future changes described in Section V of the final rule closes on August 28, 2026. Stakeholders who have views on the potential removal of Form I-766 as evidence of registration, the addition of new registration forms, the proposed changes to biometric waiver provisions for certain nonimmigrants, or the possible requirement that LPRs who turn 14 apply for a replacement Permanent Resident Card should submit comments through regulations.gov under DHS Docket No. USCIS-2025-0004 before that deadline. DHS will provide further guidance on whether and when it will finalize these proposed changes after the comment period closes. The EAD removal proposal, in particular, is one that immigration practitioners and employers should monitor closely given its broad potential impact.
How Immigration Professional Association Can Help
Alien registration compliance is no longer a background issue. With this final rule now in effect, noncitizens and the employers, HR teams, and advisors who work with them need accurate, current guidance on who is registered, who is not, and what steps are required.
Immigration Professional Association assists individuals in navigating the Form G-325R process and understanding their registration status. Our team also advises employers and HR professionals on how changes to the registration framework may affect their workforce.
If you are an immigration attorney, employer, or individual trying to understand how this rule applies to a specific situation, we invite you to contact Immigration Professional Association directly. Our focus is practical, current, and specific to the immigration landscape as it exists today — not as it existed before March 2025.
