On January 20, 2025, President Trump issued Executive Order 14159, Protecting the American People Against Invasion, which directed the Department of Homeland Security (DHS) to ensure that noncitizens in the U.S. comply with their duty to register with the government under section 262 of the Immigration and Nationality Act (INA) (8 U.S.C. 1302), and ensure that failure to comply with the registration requirement is treated as a civil and criminal enforcement priority, effective April 11, 2025.

Under the Alien Registration Requirement regulations, registration is required for the following individuals:

• Noncitizens aged 14 or older who were not previously registered when applying for a U.S. visa and who plan to remain in the U.S. for 30 or more days
• Noncitizens who turn age 14 while in the U.S. (must register within 30 days of their birthday)
• Parents and legal guardians of aliens under the age of 14 must ensure that those aliens are registered

It is the legal obligation of all unregistered noncitizens (or previously registered noncitizens who turn 14 years old) who are in the U.S. for 30 days or longer to comply with these requirements.

USCIS has established a new form, G-325R, Biometric Information (Registration), and an online process by which unregistered aliens may register and comply with the law as required by the INA. Noncompliance may result in criminal prosecution and/or other penalties, including fines up to $5,000 or imprisonment for not more than 30 days, or both. In addition, noncitizens aged 18 or older are required to carry proof of registration. Failure to do so is a federal misdemeanor, punishable by a fine not to exceed $100, or 30 days’ imprisonment, or both.

Documents that serve as proof of registration under the Alien Registration Requirement include, but are not limited to:

• Form I-94 (Arrival/Departure Record)
• Form I-551 (Permanent Resident Card)
• Form I-766 (Employment Authorization Document [EAD])
• Form I-185 or I-186 (Nonresident Alien Border Crossing Card)

Certain noncitizens are considered to be registered and do not need to take further action as part of the Alien Registration Requirement. These include the following:

• Lawful permanent residents (Green Card holders)
• Individuals who have been issued an EAD
• Individuals admitted with immigrant or nonimmigrant visas
• Individuals who were issued Form I-94/I-94W, even if the period of admission has expired
• Individuals paroled under INA 212(d)(5), even if the parole period has expired
• Individuals who have been issued Border Crossing Cards
• Individuals who have applied for lawful permanent residence (Green Card) using Forms I-485, I-687, I-691, I-698, I-700, and provided fingerprints (unless waived), even if the applications were denied
• Individuals who have been placed in removal proceedings by DHS

Noncitizens must also report changes of address to the USCIS within 10 days of moving.

Please contact UB Greensfelder Partner and Immigration Practice Group Leader David Leopold with any questions regarding the Alien Registration Requirement or other immigration matters.  

The information provided in this client alert speaks only to the information and guidance we have available as of the date of publication and is subject to change. This legal update was created by UB Greensfelder LLP, and is not intended as a substitute for professional legal advice. Receipt of this client alert, by itself, does not create an attorney-client relationship. For any questions, or for further information, please contact your UB Greensfelder attorney.