Alien registration mandate (Form G-325R)

Alien registration mandate (Form G-325R)

What’s happening

Registration mandate in effect nationwide under a DHS final rule effective June 29, 2026; no court has blocked it. The D.C. Circuit dismissed the consolidated appeals on August 6, 2026 without ruling on whether the rule is lawful.

Who it affects

Affects noncitizens already physically present in the United States who are age 14 or older and were not previously registered or fingerprinted — for example, people who entered without inspection, certain parolees and applicants without a registration document, and Canadian visitors staying 30+ days — who under the registration rule (the March 2025 interim final rule, adopted as final on June 29, 2026) must file Form G-325R, submit biometrics, and carry proof of registration, with criminal penalties for willful failure to register or to carry proof. People already documented as registered (most lawful permanent residents, EAD holders, those issued an I-94 or placed in removal proceedings, and many DACA/TPS recipients with the right documents) are generally treated as already registered. The June 2026 final rule did not change who must register or the penalties; it adopted the interim rule’s Form G-325R provisions without change, updated which documents count as proof of registration (adding Forms I-94A/I-94W, DSP-150, I-860 and I-871 and NEXUS/SENTRI/FAST/Global Entry documents), and imposed no filing or biometric services fee.

How it got here

1. Mar 12, 2025 DHS publishes interim final rule 'Alien Registration Form and Evidence of Registration' (90 FR 11793), designating new USCIS Form G-325R and reviving the INA Sec. 262 registration requirement; effective April 11, 2025.
2. Apr 10, 2025 District court (Judge McFadden) denies plaintiffs' motion to stay / preliminarily enjoin the IFR, finding plaintiffs failed to show standing/likelihood of success.
3. Apr 11, 2025 Interim final rule takes effect; registration mandate and Form G-325R become operative nationwide.
4. Aug 12, 2025 D.C. Circuit per curiam order (Henderson, Wilkins, Garcia) denies a stay/injunction pending appeal, refers the government's motion to dismiss to the merits panel, expedites the appeal, and sets a briefing schedule.
5. Dec 18, 2025 Oral argument held before the D.C. Circuit merits panel in the consolidated alien-registration appeal.
6. Dec 22, 2025 D.C. Circuit, on its own motion, orders the government to advise the court by January 9, 2026 of the current status of the interim final rule, whether it is expected to be issued as a final rule, and on what timeframe. The government files that letter on January 9, 2026.
7. Jun 29, 2026 DHS publishes the final rule “Alien Registration Form and Evidence of Registration” (91 FR 39248, RIN 1615-AC96), effective the same day. It adopts the March 2025 interim final rule as final, keeps Form G-325R as the general registration form, updates the lists of registration forms and proof-of-registration documents in 8 CFR 264.1, and declines to impose a biometric services fee at this time.
8. Jul 27, 2026 A stipulation to dismiss the appeals voluntarily is filed (corrected July 28). The same day the D.C. Circuit, on its own motion, orders the parties to show cause within 10 days why the appeals should not be dismissed as moot in light of the June 29, 2026 final rule.
9. Aug 6, 2026 D.C. Circuit (Millett, Katsas, Childs) discharges the show-cause order and orders the clerk to note that the case is dismissed; no mandate will issue. The court did not decide whether the registration rule is lawful, and the registration mandate stays in effect.

What to watch next

Update — Sept. 1, 2026 (the rule is final and the appeal is over): two things happened while this page still said a merits ruling was pending. First, on June 29, 2026 DHS published the final rule Alien Registration Form and Evidence of Registration (91 FR 39248, RIN 1615-AC96), effective the same day. It adopts the March 2025 interim final rule as final and, in DHS’s words, adopts the amendments to 8 CFR 264.1(a) and (b) “without change” — so Form G-325R stays the general registration form. The changes it does make are administrative: it updates which documents count as registration or as proof of registration (adding Form I-94A/I-94W, Form DSP-150 in place of the old Canadian and Mexican border crossing cards, Form I-860, Form I-871, and NEXUS/SENTRI/FAST/Global Entry documents; dropping obsolete forms I-67, I-691 and I-700), restructures the fingerprinting waivers in 8 CFR 264.1(e) (edits DHS calls “non-substantive and clarifying”), and makes technical corrections to 8 CFR 264.1(g), 264.5(h) and 264.6. DHS also decided not to impose a biometric services fee “at this time,” while saying it may impose an application or biometric services fee in the future. Second, on August 6, 2026 the D.C. Circuit (Judges Millett, Katsas and Childs) discharged its own July 27 order to show cause — which had asked why the appeals should not be dismissed as moot “in light of the issuance of a new final rule on June 29, 2026” — and ordered the clerk to note that the case is dismissed, adding that “No mandate will issue.” A stipulation to dismiss the appeals voluntarily had been filed on July 27 and corrected on July 28. The court did not decide whether the registration rule is lawful, and the mandate keeps operating. (Checked against the Federal Register document and the D.C. Circuit docket, Sept. 1, 2026.)

No appellate ruling is coming — the consolidated appeals (Nos. 25-5152/25-5233/25-5247) were dismissed on August 6, 2026 and no mandate will issue. What is left to watch: the district court case (D.D.C. 1:25-cv-00943), stayed since July 10, 2025 with the plaintiffs’ motion to lift the stay still undecided on the public docket, and any further DHS rulemaking — DHS’s comment period on additional registration changes closed August 28, 2026.

DHS used the final rule to ask for comments on possible future changes, which it says “would not change the alien registration requirements under section 262 of the INA.” Those ideas include prescribing more forms as registration forms (among them Forms I-90, I-102, I-539, I-589, I-730, I-751, I-821, I-829, I-854A, I-881, I-914 and I-918) and considering the removal of Form I-766, the Employment Authorization Document, from the list of documents that count as proof of registration. None of that is in effect; it would take a further rulemaking, and the comment period closed August 28, 2026.

Official sources

• federalregister.gov
• courtlistener.com
• courtlistener.com
• courtlistener.com
• nilc.org

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This page is general information about ongoing litigation, not legal advice. A case’s status can change with a single ruling, and outcomes can turn on facts specific to each person. For advice on a specific situation, consult a licensed immigration attorney or a DOJ-accredited representative.