USCIS Registration of Non-U.S. Citizen Children
April 16, 2025
As discussed in our recent guidance (available here), ALL foreign nationals present in the U.S. for more than 30 days must confirm their compliance with a new “Alien Registration Requirement” which took effect on April 11, 2025. For the majority of foreign nationals this registration requirement has been met by admission through a U.S. port of entry and issuance of an I-94 admission record. No additional registration is required for these individuals but all foreign nationals over the age of 18 must carry proof of registration at all times (typically green card, I-94 admission record, or EAD card).
Children turning 14 years of age
Effective April 11th, 2025, non-U.S. citizen children reaching their 14th birthday while in the U.S. are required to create an online USCIS account and submit a G-325R Registration form within 30 days of their birthday. The rule is unclear as to how and whether it will be applied retroactively for children that turned 14 prior to the rule’s effective date but parents should pursue registration as soon as possible for their children who have turned 14 and have not yet been fingerprinted by a U.S. Embassy/Consulate or port of entry.
Children under the age of 14
Ambiguity also exists as to whether children under the age of 14 with an I-94 admission record are required to register. USCIS is currently reviewing public comments on this point and may provide clarity in the coming weeks. Until that time, parents may wish to initiate registration for each of their non-U.S. citizen children to ensure compliance with all interpretations of the new rule.
Creating USCIS Account
Each required registrant must first create an online USCIS account in their own individual name and with a unique email address. Please see the attached guidance for setting up a new online account.
Preparing G-325R Registration
Once a USCIS account has been created, registrants will choose File a form online and then select “G-325R” from the dropdown menu and “Start Form.” While foreign nationals are encouraged to exercise their own judgment, we are currently recommending that registrants only complete the required fields marked with an asterisk. There are a number of questions that are NOT required, and we recommend those fields be skipped until further guidance is released. Carefully review completed registration prior to final submission and correct any erroneous entries that may have been generated due to system or form limitations.
Caution on “Entry Without Inspection”
Please note, one of the questions that is NOT required requests “immigration status at last arrival” and the only listed option is “entry without inspection.” As such, this question MUST be left blank as a lawful I-94 admission confirms entry with inspection by CBP upon entry into the U.S. and erroneously self-identifying as entering without inspection is likely to lead to immediate removal from the United States.
How to Answer Certain Questions
In addition to questions regarding criminal activity, the following questions are required fields, and our recommended responses are as follows:
- Since entry, in what activities have you been engaged?
Response: Accompanying parent(s). - In what activities do you intend to engage between now and your expected date of departure?
Response: Accompanying parent(s). - How long do you expect to remain in the United States?
Response: For duration of authorized stay.
Uploading Additional Evidence
While not required, if registrants choose to upload additional evidence, we recommend limiting documents to evidence of most recent I-94 Admission Record confirming current lawful status. The I-94 record can be found on CBP’s website and/or at the bottom of the most recent I-797 approval notice issued by USCIS. Please carefully review and confirm the registrant’s I-94 record is unexpired before uploading to USCIS. If an extension of status is currently pending, consider omitting additional evidence since it is not required for registration.
Proof of Registration and Biometrics (if required)
Once the form is accepted by USCIS, proof of registration will be posted to the registrant’s USCIS account. While carrying proof of registration is only required at age 18 or older, we recommend downloading registration documents and storing with other important immigration documents. If the registrant is also subject to fingerprinting (at or after age 14), USCIS will schedule the registrant for a biometrics appointment. Fingerprinting will be waived for Canadians and for all foreign nationals under the age of 14.
When to Seek Counsel
Registrants with criminal offenses, entries without inspection, and/or those present in the U.S. pursuant to Temporary Protected Status (TPS) or Deferred Action for Childhood Arrivals (DACA) are strongly encouraged to seek advice from immigration counsel prior to submitting the G-325R Registration. In addition, if registrants have questions regarding unique personal circumstances or receive a Request for Information or Evidence from USCIS in connection with registration, please contact us immediately.