U.S. Citizenship and Immigration Services (USCIS) has announced a significant policy shift aimed at enhancing national security and ensuring the integrity of identity documents. Effective December 12, 2025, the agency has tightening the rules regarding the photographs used for official immigration documents, such as Green Cards and Employment Authorization Documents (EADs).
Key Changes to Photo Validity
Under the newly issued guidance, USCIS will no longer use photographs that are more than three years old to create secure immigration documents. This is a major departure from the flexibilities introduced during the COVID-19 pandemic, which allowed the agency to reuse biometric photos for up to 10 years.
The agency noted that the extended reuse of old photos compromised the ability of officers to accurately verify identities, especially in cases where an applicant’s appearance had changed significantly over a decade.
End of Self-Submitted Photos
In addition to the age limit, the update clarifies that self-submitted photos will no longer be accepted for the production of secure documents. Moving forward, USCIS will only utilize photographs taken by the agency itself or other authorized entities. This ensures that every image meets strict federal standards for accuracy and reliability.
Mandatory New Photos for Specific Forms
While the policy applies broadly, USCIS has highlighted several key forms that will now require a new photograph regardless of when the applicant’s last photo was taken:
* Form I-90: Application to Replace Permanent Resident Card (Green Card)
* Form I-485: Application to Register Permanent Residence or Adjust Status
* Form N-400: Application for Naturalization
* Form N-600: Application for Certificate of Citizenship
Conclusion
This policy change is part of a larger Department of Homeland Security (DHS) effort to modernize screening and vetting processes. Applicants, should expect to attend an Application Support Center (ASC) appointment for biometrics more frequently than in recent years, even if one had the photo taken by USCIS previously.
Failure to provide a recent, authorized photograph could result in delays in the production of physical identity cards or even issues with the adjudication of cases.
Technical details of this update, the full policy alert and manual update can be found here.