Featured Issue: Alien Registration Requirement

4/22/25 AILA Doc. No. 25042205.

On February 25, 2025, USCIS announced that, pursuant to INA §262 and executive order 14159, the agency was establishing a new form and process by which undocumented immigrants may register. On March 12, 2025, DHS published an interim final rule (IFR) amending DHS regulations to designate a new form (G-325R) for noncitizens and additional documentation that may serve as evidence of registration. The IFR took effect on April 11, 2025.

This collection provides updates, information, and resources on the Alien Registration Requirement.

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Practice Resources

Practice Pointer on the Alien Registration Requirement: Fingerprinting, Registration, Change of Address, and Possession of “Papers”

On 3/11/25, DHS published the draft of its proposed new registration interim final rule (IFR) referenced in the announcement by USCIS on 2/25/25. AILA provides the following practice resource to help members understand the registration requirements and intricacies.

4/22/25 AILA Doc. No. 25042204.
Client Flyers

Client Flyer: Understanding Alien Registration Requirements

AILA provides a simple flyer to help your clients understand alien registration requirements. There is a generic PDF version and a customizable Word version. Please share widely with your networks.

4/22/25 AILA Doc. No. 25041634.
Memo & Regulatory Comments

AILA and the Council Submit Comments on USCIS' Interim Final Rule on the Alien Registration Form and Evidence of Registration

AILA and the American Immigration Council submitted comments on the USCIS IFR on the new alien registration requirement. The comments argue that the IFR violates the Administrative Procedure Act (APA), the Paperwork Reduction Act (PRA), and the Fifth Amendment.

4/11/25 AILA Doc. No. 25041113.
Cases & Decisions

Order Denying Motion for Stay/Preliminary Injunction on Alien Registration Interim Final Rule

On 4/10/25, the District Court of D.C. denied Plaintiffs Motion to Stay or Preliminarily Enjoin the effective date of the Alien Registration Interim Final Rule (IFR) on standing. As a result, the registration requirement in the IFR will take effect beginning tomorrow 4/11/25.

4/10/25 AILA Doc. No. 25041011.
Cases & Decisions

District Court Complaint Challenging Registration Rule for Noncitizens

AILA and partner organizations filed a lawsuit on behalf of several membership-based nonprofit organizations challenging DHS’s interim final rule, Alien Registration Form and Evidence of Registration. (Coalition for Humane Immigrant Rights v. U.S. Department of Homeland Security, 3/31/25)

3/31/25 AILA Doc. No. 25040708.
Professional Resources

The Ethics of Advising Clients Subject to the Alien Registration Requirement

The Alien Registration Requirement should be explained to clients, Jesse Lloyd from the Ethics Committee concludes. He parses out what that means and how to stay on the right side of the ethics rules in this article.

3/19/25 AILA Doc. No. 25031901. Ethics
Practice Resources

USCIS Form G-325R - Biographic Information (Registration)

AILA provides images of each section of the new Form G-325R which has been made available on client myUSCIS accounts. A new interim final rule (IFR) requires that, beginning 4/11/25, certain foreign nationals register their presence by completing the online form.

3/14/25 AILA Doc. No. 25031403.
FR Regulations & Notices

DHS Publishes IFR on Alien Registration Form and Evidence of Registration

DHS published an interim final rule (IFR) that amends DHS regulations to designate a new registration form for noncitizens and additional documentation that may serve as evidence of registration. The IFR takes effect on 4/11/25. Comments are due by 5/12/25. (90 FR 11793, 3/12/25)

3/12/25 AILA Doc. No. 25030703.
Practice Resources

Practice Alert: DHS to Publish the Alien Registration Form and Evidence of Registration Interim Final Rule

On 3/12/25, DHS will be publishing an Interim Final Rule (IFR), which will take within 30 days requiring individuals to register their presence and provide their fingerprints if they are in the U.S. for 30 days or more. AILA provides the following based on the advanced copy of the IFR.

3/11/25 AILA Doc. No. 25031108.
Federal Agencies, Agency Memos & Announcements

USCIS Provides Update on Alien Registration Requirement

USCIS provided information on the “Alien Registration Requirement” under INA §262, stating that USCIS is establishing a new form and process by which undocumented immigrants may register. The notice includes details on who has already registered, who must apply for registration, and how to register.

2/25/25 AILA Doc. No. 25022602. Removal & Relief