Overview
- Effective immediately, only photos taken by USCIS or other authorized entities and captured within the past 36 months may be used on secure immigration documents.
- Photo reuse is no longer automatic, and USCIS retains discretion to require a new photograph even if a prior image falls within the three-year window.
- New biometrics, including a fresh photograph, will always be collected for key forms such as I-90, I-485, N-400, and N-600.
- The shift rolls back pandemic-era flexibilities that allowed extended photo reuse, which USCIS says weakened identity verification and at times produced documents with images up to 22 years old.
- Immigration practitioners report unresolved implementation details, noting that some form instructions have not yet been updated and the timing for ending self-submitted photo submissions remains unclear.