This article was prepared with the assistance of ABIL, the Alliance of Business Immigration Lawyers, of which Loan Huynh is an active member.
On December 12, 2025, U.S. Citizenship and Immigration Services (USCIS) announced new guidance, effective immediately, limiting the age of foreign nationals’ photos that can be used to create immigration documents to a maximum of three years, with many exceptions. Certain forms will require a new photo, along with new biometrics, “regardless of when an applicant’s or petitioner’s last photograph was taken,” including applications to replace permanent resident cards and to register permanent residence or adjust status, and applications for naturalization and certificates of citizenship.
Additionally, USCIS said, “self-submitted photos will no longer be accepted. Only photos taken by USCIS or other authorized entities will be used.” USCIS also said that it “has the discretion to require a new photograph from requestors in lieu of reusing an existing photograph.”
