Overview
- The DHS interim final rule took effect on Tuesday, August 11 and gives USCIS authority to require exclusive electronic filing for forms that have been available online for at least 180 days.
- Twenty-two forms met the 180-day test as of December 16, 2025 and could be targeted first, including I-90, I-130, I-765, I-589 and N-400.
- USCIS must publish a notice and provide a transition period before forcing e-filing, and the agency opened a public comment window that runs through October 13, 2026.
- The rule creates a narrow paper-exception process using Form I-936 with a $25 fee for applicants who face extreme digital hardship.
- Major parts of the system remain paper-based with over 80 forms covering about 1.2 million annual receipts, and reporting conflicts over whether USCIS must give 60 days or 600 days’ advance notice could affect implementation timing.