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      GMS Flash Alert 2025-056

      United States – Alien Registration Requirement

      GMS Flash Alert 2025-056 | March 7, 2025

      On February 25, 2025, the United States Citizenship and Immigration Services (USCIS) announced its intention to enforce the alien registration requirement under the Immigration and Nationality Act (INA). This mandate requires the following individuals to register:

      • All aliens 14 years of age or older who were not registered and fingerprinted (if required) when applying for a visa to enter the United States and who remain there for 30 days or more. They must apply prior to the expiry of those 30 days.
      • The parents and legal guardians of aliens under 14 years of age who have not been registered and remain in the United States for 30 days or longer, prior to the expiry of those 30 days; and
      • Any alien, previously registered or not, who turns 14 years old in the United States, within 30 days after their 14th birthday. 1

      USCIS has not yet released the form or published the process for alien registration, but it is expected that the agency will do so shortly.

      WHY THIS MATTERS

      Non-citizens not previously registered during their visa application must now register with USCIS if they intend to stay in the United States. This includes (1) Aliens who are present in the United States without inspection and admission, or inspection and parole; (2) Canadian visitors who entered the United States at land ports of entry and were not issued an I-94 record; and (3) Aliens who submitted Deferred Action for Childhood Arrivals (DACA) or Temporary Protected Status (TPS) and were not issued evidence of registration.

      Furthermore, parents or guardians of a non-U.S. citizen child under 14 years of age who turns 14 while in the United States are responsible for ensuring that the child, whether previously registered or not, be registered and have fingerprints taken (if required) within 30 days of their 14th birthday.

      Once someone has been registered and appeared for fingerprinting (unless waived), the U.S. Department of Homeland Security (“DHS”) will issue evidence of registration, which must be carried and always kept in possession of all aliens over the age of 18. 2

      Failure to comply with the registration requirement may result in criminal and civil penalties, up to and including misdemeanor prosecution and the payment of fines.3

      Registration documentation does not establish U.S. employment authorization or any other right or benefit under the INA or any other U.S. law. 4

      WHO IS ALREADY REGISTERED?

      Any non-U.S. citizen who has been issued one of the following documents is considered to have already registered:

      • Lawful permanent residents;
      • Individuals paroled into the United States under INA 212(d)(5), even if the period of parole has expired;
      • Individuals admitted to the United States as nonimmigrants who were issued Form I-94 or I-94W (paper or electronic), even if the period of admission has expired;
      • All individuals present in the United States who were issued immigrant or nonimmigrant visas prior to arrival;
      • Individuals whom DHS has placed into removal proceedings;
      • Individuals issued an employment authorization document;
      • Individuals who have applied for lawful permanent residence using Forms I-485, I-687, I-691, I-698, I-700, even if those applications were denied; and
      • Individuals issued Border Crossing Cards. 5

      How to Register

      DHS will soon announce a form and process for non-citizens to complete the registration requirement. In anticipation of this, non-citizens are required to register for a USCIS online account. Once the registration process is implemented, non-citizens may submit their registration and parents and guardians may submit registration applications on behalf of their children under 14 through their USCIS account. 

      KPMG LAW LLP INSIGHTS

      Next Steps

      Register Promptly: If you or your children meet the criteria, create your USCIS account and complete your registration within the required timeframe.

      Carry Proof: Always have evidence supporting your registration with you, as required by law. This can include your valid I-94, Form I-797 Notice of Action, Endorsed Form I-129s, USCIS I-485 Receipt Notice or confirmation of registration from the USCIS website. 

      FOOTNOTES:

      1.    United States Citizenship and Immigration website.

      2.    United States Citizenship and Immigration website.

      3.    United States Citizenship and Immigration website.

      4.    United States Citizenship and Immigration website.

      5.    United States Citizenship and Immigration website.

      Contacts

      Elizabeth Nanton
      Elizabeth Nanton

      Partner and U.S. Immigration Practice Leader, KPMG Law LLP

      KPMG in Canada

      jashan-girn
      Jashan Girn

      Associate Attorney

      KPMG in Canada

      Disclaimer

      * Please note the KPMG International member firm in the United States does not provide immigration or labour law services. However, KPMG Law LLP in Canada can assist clients with U.S. immigration matters.

      The information contained in this newsletter was submitted by the KPMG International member firm in Canada.

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