In February 2025, the United States Department of Homeland Security (“DHS” or “Department”) published an interim final rule mandating a new alien registration requirement for certain non-citizens.
On March 31, a lawsuit was filed against the Department challenging the new registration requirement. However, the United States District Court for the District of Columbia, on April 10, 2025, denied the plaintiff’s motion to stay or preliminarily enjoin the rule from taking effect. As a result, the interim final rule takes effect today, April 11, 2025.
The interim final rule requires certain non-citizens residing within the United States to register with DHS by completing Form G-325R, Biographic Information (Registration) and carrying proof of such registration.
The interim final rule applies to the following:
- Non-citizens 14 years of age or older who were not fingerprinted or registered when they applied for their visa and who remain in the U.S. for 30 days or more;
- Non-citizen children under 14 years of age who were not fingerprinted or registered when a visa application was submitted on their behalf and who will remain in the U.S. for 30 days or more must be registered by their parent(s)/guardian(s); and
- Previously registered non-citizen children turning 14 must re-register within 30 days after their 14th birthday.
There are some limited exceptions to the registration requirement, including lawful permanent residents, employment authorization recipients, and certain visa holders.
While there is no cost or fee associated with completing Form G-325R, willful failure to register as required by the interim final rule may result in significant penalties, including civil penalties, conviction of a misdemeanor offense, or imprisonment and potential immigration consequences.
For assistance in determining whether you are subject to the new registration requirement, please contact Grace Pennerat (gpennerat@poynerspruill.com).
