The new policy, announced on December 12, 2025, rescinds previous COVID-era allowances and demands a more rigorous approach to identity verification. By tightening photo requirements, USCIS aims to enhance document security and prevent fraud. However, the stricter regulations could also lead to delays and complications for applicants, as the updated rules are implemented across various forms and processes.
New Guidelines on Photo Submission
Under the updated rules, applicants must now submit photos taken within three years of filing their immigration forms. Previously, USCIS had allowed photos to be reused for up to 10 years during the COVID-19 pandemic, accommodating processing delays. However, the agency has now reinstated its original policy, which stipulates that photographs must be recent and accurately reflect the applicant’s current appearance. This move is intended to strengthen security measures, making it easier for authorities to identify individuals and detect potential fraud.
The new regulations apply to several critical immigration forms, including Form I-90 (for replacing a Green Card), Form I-485 (for adjusting immigration status), Form N-400 (for naturalisation), and Form N-600 (for applying for a Certificate of Citizenship). USCIS emphasized that photos submitted for these forms must meet its precise standards, ensuring a more reliable and consistent verification process.
According to USCIS, these updates align with priorities set by the Department of Homeland Security (DHS), which has been working to modernise immigration screening and vetting procedures. The agency explained that requiring up-to-date, government-approved photographs is essential for preventing identity theft and fraud. Self-submitted photographs, such as those taken at home or by private providers, will no longer be accepted. Only photos captured by USCIS or other government-authorised entities will be permissible moving forward.
Impact on Immigration Applicants
The rule change could have significant implications for millions of people seeking to navigate the complex U.S. immigration system. With stricter photo requirements in place, applicants will need to ensure that they comply with the new guidelines, which may involve additional steps in the application process.
For instance, individuals seeking to replace their Green Cards (Form I-90) or adjust their immigration status (Form I-485) will now be required to submit a new photo, even if their previous image is still valid according to older standards. This could result in delays for applicants who may need to schedule an appointment with USCIS-approved photographers, especially in regions where such services are in high demand.
Furthermore, the decision to exclude self-submitted photographs may inconvenience applicants who previously relied on more affordable or accessible options. As USCIS now mandates government-authorised entities for photo submissions, applicants could face higher costs and longer wait times.
The policy shift also raises questions about the practical impact on those already in the process of applying for immigration benefits. While USCIS maintains that the rule is necessary to enhance document security, critics argue that it could create unnecessary barriers for applicants, particularly those in underserved or rural areas where access to USCIS-approved photographers may be limited.
