On December 12, 2025, USCIS issued a Policy Alert announcing new guidance governing the submission and reuse of photographs for immigration benefit requests. The change is binding and effective immediately for all applications filed on or after that date.
What changed
Self-submitted photos will no longer be accepted. Only photos taken by USCIS or other authorized entities will be used. Photos must be collected through a Biometric Services Appointment (BSA) at an USCIS Application Support Center or through another “approved submission process” specified by USCIS.
Effective immediately, the new guidance in the USCIS Policy Manual limits the use of photos to those that were taken within three years of the date a person files a USCIS form. Photos collected through a BSA may be reused on a new USCIS application or petition, as long as they are no more than three (3) years old at the time of filing.
This guidance is effective immediately and applies to all benefit requests filed on or after December 12, 2025.
Why it matters
This policy change creates two major friction points for practitioners and applicants:
Form instructions lag behind policy. The policy manual has been updated in some places, but the form instructions have not. It is unclear when the requirement to submit photographs will end. Forms like I-765, I-485, and I-90 still instruct applicants to include passport photos, but USCIS will now discard them. You need to advise clients accordingly—include photos if the form instructions still require them, but understand USCIS will not use them for the final document.
Processing timelines shift. Clients can no longer submit a complete application with passport photos. Any case requiring a photo will now require a separate BSA appointment. This can add 2–4 weeks to the timeline before USCIS even reaches the merits of the application. If a client’s photo on file is older than three years, USCIS will schedule a BSA automatically—but only after receiving the application. Plan for this delay when advising on time-sensitive filings (e.g., work authorization cases under a deadline).
Continuity from prior biometrics. If a client attended a biometric appointment within the past three years and USCIS captured a photo, that photo can be reused. Clients should maintain records of prior ASC appointment dates to confirm eligibility.
Way forward
-
Track prior biometrics. Confirm whether your client attended a biometric appointment within the past three years and whether USCIS captured a photo. If yes, note the date; you may avoid a second BSA.
-
Continue submitting passport photos with applications. Form instructions still require them in many cases (I-765, I-485, I-90, I-131, N-400). Do not omit them based on the new policy. USCIS will discard them, but rejecting an application for missing photos creates avoidable delays. Submit per the form instructions, and note in your file memo that under PA-2025-29, these photos will not be used for the final document.
-
Budget extra time. Add 4–6 weeks to your timeline for cases requiring a BSA. After USCIS receives the application and determines a photo is needed, it will send an ASC Appointment Notice (Form I-797C). Clients must then schedule and attend; only after the photo is captured can adjudication proceed.
-
Monitor form updates. USCIS has not yet revised the printed form instructions to reflect PA-2025-29. When instructions do change, they may also update fee schedules, document requirements, or evidence lists. Check the USCIS forms page and policy manual regularly for downstream guidance.
Disclaimer
This article is provided for informational purposes only and does not constitute legal advice. It is a summary of publicly available USCIS policy guidance; it is not a substitute for review of the primary source or consultation with a licensed immigration attorney. Policy can change without notice. You should verify the current status of this guidance against the authoritative USCIS Policy Manual and the Policy Alert linked above before advising a client or filing an application.