United States | New USCIS photo policy for enhanced identity verification, effective immediately

U.S. Citizenship and Immigration Services announced it will limit the use of photographs for secure immigration documents to those taken within the past three years, effective immediately.

Key Points:

• Under the updated guidance, USCIS will only reuse a previously captured photograph if it was taken at a biometrics services appointment within 36 months of the date an applicant files a form.
• Self‑submitted photos will no longer be accepted. Only photos taken by USCIS or other authorized entities may be used in secure documents.
• The following forms will always require new biometrics, including a fresh photograph, regardless of when the last photo was taken:
  • Form I‑90, Application to Replace Permanent Resident Card
  • Form I‑485, Application to Register Permanent Residence or Adjust Status
  • Form N‑400, Application for Naturalization
  • Form N‑600, Application for Certificate of Citizenship
• USCIS retains discretion to require a new photograph for any application, even within the three‑year reuse window.
• The guidance is effective immediately and applies to all immigration benefit requests filed on or after Dec. 12, 2025.
• The official policy alert, PA-2025-29, can be viewed here.

This alert has been provided by the BAL U.S. Practice Group. 

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