Effective April 11, certain foreign nationals residing in the United States will be required to register themselves and undergo fingerprinting through an online US Citizenship and Immigration Services system. This new requirement is in addition to the existing requirement that all non-citizens report a change of address within 10 days.
On January 20, 2025, President Donald Trump issued Executive Order 14159, titled “Protecting the American People Against Invasion,” which calls for renewed enforcement of existing registration requirements under the Immigration and Nationality Act (INA). In response, the US Department of Homeland Security (DHS) issued an Interim Final Rule on March 12, 2025, outlining how these requirements will now be implemented through an online system administered by US Citizenship and Immigration Services (USCIS).
The rule aims to ensure that foreign nationals residing in the United States are fully informed of their obligation to register and comply with fingerprinting requirements, even if they entered lawfully under parole or visa programs. Set to take effect on April 11, 2025, the rule mandates that certain foreign nationals who were not previously registered or fingerprinted must now complete the process through the newly established online platform.
All foreign nationals physically present in the United States who are 14 years of age or older who were not previously registered and fingerprinted (if required) when applying for a visa to enter the United States and who intend to stay in the United States for 30 days or longer must register. Parents and legal guardians are responsible for registering minors under 14 years of age who have not been registered and will remain in the United States for 30 days. These children must be registered within the 30-day period. After a minor reaches 14 years of age, re-registration and fingerprinting is required within 30 days of their 14th birthday.
Foreign nationals are generally considered registered if they have previously submitted required documentation under 8 CFR § 264.1(a) and received a form of registration evidence identified in 8 CFR § 264.1(b). Individuals who have undergone fingerprinting—unless specifically exempt—typically meet these requirements. Examples of those already registered include the following:
Individuals who have not applied for a visa, or who did not receive recognized registration documents or undergo fingerprinting as required by 8 CFR § 264.1(a) and (b), are not considered registered under the new rule. This includes foreign nationals physically present in the United States without lawful admission or parole, including those who entered without inspection (EWI), Canadians who entered the United States through land ports of entry and were not issued formal registration documents, and individuals who submitted applications for Deferred Action, Temporary Protected Status (TPS), or other benefits not covered by the regulation who did not receive official registration evidence.
Foreign nationals who believe they may be subject to this new registration requirement should act promptly to review their prior immigration processing and registration history. Individuals who were not previously fingerprinted or who do not hold evidence of registration should create an online account with the USCIS by April 11, 2025.
It is also important to note that this rule is currently the subject of litigation. On March 31, 2025, several advocacy organizations filed suit, alleging that DHS’s implementation of the Interim Final Rule without a public notice-and-comment period violates the Administrative Procedure Act. While the litigation is pending and could ultimately affect the scope or enforceability of the rule, there is currently no injunction in place. As such, the rule remains in effect, and foreign nationals who fall within its scope should take steps to comply while monitoring for legal updates.
It is also crucial to remember that non-citizens living in the United States must report any change of address to the USCIS within 10 days of moving. The address reporting requirement applies to all non-citizens, including legal permanent residents, in the United States except for A and G visa holders and visa waiver visitors.
Foreign nationals may satisfy the address reporting requirement through submission of Form AR-11, Alien’s Change of Address Card, with the USCIS. The USCIS strongly encourages online submission of Form AR-11 through a USCIS online account as it allows for near-immediate processing. The USCIS also accepts Form AR-11 by mail but warns that a physical submission of Form AR-11 will not provide an automated update to USCIS records. Non-compliance with this requirement could result in a misdemeanor charge punishable by a fine of up to $5,000, imprisonment for up to 30 days, or both.
Lawful permanent residents who have filed Form I-864, Affidavit of Support Under Section 213A of the INA, and whose sponsorship agreement remains in force must file Form I-865, Sponsor’s Notice of Change of Address, in addition to Form AR-11 within 10 days of moving to notify the USCIS of a change in address. US citizens who have filed Form I-864 must file Form I-865 within 30 days of a change in address if the sponsorship agreement remains in force.
Moreover, anyone who has filed an immigration benefit request with the USCIS must notify the USCIS of any changes of address as soon as possible to ensure receipt of all correspondence and benefits without delay.
Contract attorney Rosemarin Belliard contributed to this LawFlash.
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