On June 29, 2026, DHS published a final rule adopting the Interim Final Rule (IFR) DHS published in March 2025, implementing a registration requirement for foreign nationals. The interim rule has been in operation since April 2025 and DHS has now finalized that rule, with only minor technical corrections.
While there are no new substantive requirements and the obligations that apply today are the same ones that have applied since April 2025, this blog serves as a timely reminder of these important immigration obligations, which can have serious immigration ramifications if not followed.
The following is a summary of the registration requirements as described in the final rule.
Most Foreign Nationals Are Already Registered — Nothing New Required
The rule’s central mechanism — Form G-325R — is for people who have never gone through any formal DHS immigration process. If you have any of the following documents, you are already registered and do not need to file anything:
- Nonimmigrant visa holders (H-1B, L-1, TN, O-1, E-3, F-1, J-1, and all other categories) — the visa plus Form I-94 constitutes registration.
- Lawful permanent residents — the green card (Form I-551) is evidence of registration.
- EAD holders (OPT, STEM OPT, H-4 EAD, pending adjustment of status) – Form I-766 evidences registration.
- Trusted Traveler Program members (NEXUS, SENTRI, FAST, Global Entry) are considered registered.
Note for DACA recipients: a DACA grant alone is not sufficient. A currently valid EAD is required to be considered registered. If the DACA EAD has lapsed, please contact our firm.
There are two groups of foreign nationals who need to register via Form G-325R:
- Canadian nationals who regularly enter at land borders without a Form I-94; and
- Undocumented individuals who have never been encountered by DHS.
Two Practical Steps Every Foreign National Should Take
Whether or not the registration requirement is applicable, all foreign nationals in the U.S. should:
- Carry your registration documents.Federal law requires all registered foreign nationals aged 18 and over tocarry evidence of their registration at all times. Again, this is not new law, but enforcement is active to an extent it has not been for decades. Nonimmigrant visa holders should carry their passport and an I-94 printout or digital copy. Green card holders should carry their I-551. EAD holders carry their I-766. Failure to carry is a federal misdemeanor: up to a $5,000 fine and 30 days in jail.
- Report address changes within 10 days.Any timeforeign nationals in the U.S. move, they are required to notify DHS within 10 days via their myUSCIS account. Willful non-compliance is a misdemeanor and a ground of removal. If a foreign national has failed to notify USCIS of a new address in a timely manner, they should do so as soon as possible.
Two Practical Observations for Employers
- File EAD renewals early. DHS acknowledged that new registration filings may add pressure to USCIS processing queues. If you have employees on H-4 EAD, OPT, or with a pending green card, start as early as USCIS permits.
- No new I-9 or E-Verify obligations. This rule changes nothing about your employment verification responsibilities. Form G-325R is not a Form I-9 document and cannot be used as evidence of work authorization.
Questions about how this rule applies to you or your employees? The Meltzer Hellrung immigration team has been advising clients on this requirement since the interim rule was issued in March 2025. We are here to help.
