DHS has proposed a sweeping biometrics rule that would allow USCIS to require fingerprints, photos, and even DNA from virtually anyone connected to an immigration filing—including U.S. citizens, green card holders, and children—unless specifically exempted.

Introduction

On November 3, 2025, the Department of Homeland Security (DHS) issued a Notice of Proposed Rulemaking (NPRM) in the Federal Register. This proposal is not final and, if adopted, would significantly update DHS’s biometrics regulations by allowing the agency to require biometrics from any individual who files or is associated with an immigration benefit request, other request, or information collection, unless that person is specifically exempted.

DHS presents this as a move toward more “person-centric” identity management, enhanced and continuous vetting, and reduced reliance on paper documents, but these changes will not take effect unless and until a final rule is issued after the public comment process.

What DHS Is Proposing

Under this proposal, U.S. Citizenship and Immigration Services (USCIS), and other DHS components within their authorities, could require biometrics from almost anyone connected to an immigration case, not just the main applicant. That could include the person applying, the person filing a petition for a family member, financial sponsors, and others tied to the case, and it would apply “regardless of age,” unless DHS decides to create a specific exemption.

The NPRM emphasizes that DHS intends to phase in any new modalities through form-by-form updates rather than impose every new requirement on day one of a final rule. In practice, that means you would only be subject to a new biometric or DNA requirement if USCIS updates the specific form you are using and its instructions to add that requirement.

Who Would Be Covered, Including Some U.S. Citizens and LPRs

While the existing regulations generally mandate biometrics from noncitizens in defined contexts, the proposal would allow USCIS to require biometrics from U.S. citizens, U.S. nationals, and lawful permanent residents in specified circumstances when they are filing or otherwise associated with certain benefit requests (e.g., family-based petitioners where DHS must assess disqualifying criminal history). DHS explains that current rules do not generally require biometrics from citizen or Lawful Permanent Resident (LPR) petitioners.

The proposal also eliminates age-based limits across many contexts, explaining that collecting biometrics from individuals under age 14 can support identity verification, anti-fraud objectives, and child-protection priorities.

What Counts as “Biometrics”

DHS proposes a formal definition of “biometrics” as measurable biological or behavioral characteristics and lists the authorized modalities it may request: facial imagery; prints (including fingerprints and palm prints); handwritten signature; ocular imagery (including iris, retina, and sclera); and voice (i.e., voice print, vocal signature, and voice recognition). Separately, the NPRM provides a detailed framework to codify and expand DNA testing, use, and storage, treating DNA evidence as a biometric identifier used—among other purposes—to verify claimed parent-child relationships.

Your Chance to Comment on the NPRM

Importantly, this is still a proposal, not a final rule. DHS is accepting public comments through the Federal eRulemaking Portal at Regulations.gov, under DHS Docket No. USCIS-2025-0205, until January 2, 2026. If you are concerned about how expanded biometrics and DNA collection could affect you, your family, or your business, you may submit a comment online by referencing the docket number and explaining your concerns, suggested changes, and any supporting information or examples.

Legal Disclaimer

This article is for informational purposes only and does not constitute legal advice. Reading any content on our website does not create an attorney-client relationship. For legal guidance tailored to your specific situation, consult a qualified immigration attorney.