USCIS Cracks Down on Photo Reuse: New Guidelines Impact Green Card Holders and Citizenship Applicants

Published on December 16, 2025

The USCIS has recently made its first policy change regarding the reuse of photographs immigration identity documents namely in immigration determinations (green cards) including holders and applicants. With these changes going forward, starting December 12, 2025, the practice where applicants are allowed to submit their own photographs is being discontinued, and the agency is implementing stricter deadlines concerning the reuse of biometric photographs in immigration.

Key Changes in USCIS Photo Reuse Policy: What Green Card Holders and Applicants Need to Know

Under the updated guidance, the USCIS will no longer accept photographs submitted directly by applicants. This move comes as part of an effort to streamline the process and ensure security and consistency in immigration procedures.

As per the new policy, photographs taken during biometric services appointments may only be reused if the image is no older than 36 months (three years) from the date of the appointment at the time of filing the immigration request. If the photograph exceeds this time limit, a new image will be required, even if it was previously collected and stored by USCIS.

In addition, USCIS officers now have discretion to request a new photograph at any point during the application process, even if the previous image falls within the three-year window. This marks a departure from the previous rule, where applicants could rely on photographs that were less than 10 years old.

The End of Self-Submitted Photos: A Step Toward Improved Security

One of the most significant changes in the updated policy is the end of the practice where applicants could submit their own photos for use on immigration identity documents, including green cards. Previously, many individuals opted to self-submit their images, which raised concerns about consistency, accuracy, and fraud prevention.

By eliminating this option, USCIS aims to standardize the photograph submission process, ensuring that all images meet specific quality and security standards. This move is expected to help reduce potential vulnerabilities in the immigration system by ensuring that photos are taken at USCIS-approved biometric service centers.

Exempt Applications: Who Is Still Required to Submit New Biometric Photos?

The new guidance affects a majority of immigration applications, but some requests are exempt from these changes due to their specific biometric requirements. These applications, which will continue to require new biometrics—including a fresh photograph—are:

• Application for Naturalization (Form N-400)
• Application for Certificate of Citizenship (Form N-600)
• Application to Replace Permanent Resident Card (Form I-90)
• Application to Register Permanent Residence or Adjust Status (Form I-485)

These applicants must still provide new biometric information, including an updated photograph, as part of their filing process.

How the System Worked Before the Update

Under the previous system, USCIS allowed the reuse of photographs for up to 10 years for green card holders and applicants filing various immigration documents. This policy, which was implemented after pandemic-related flexibilities ended in September 2024, permitted applicants over the age of 26 to reuse their photographs if they were not older than 10 years. For applicants aged 25 and under, the time frame for reusing the photograph was stricter, with a limit of 30 months.

However, the latest guidance replaces these age-based rules with a single, standardized 36-month limit, regardless of the applicant’s age or the document’s validity. This shift ensures greater uniformity in the handling of photographic data.

What This Means for Green Card Holders and Citizenship Applicants

This new policy change requires applicants to be more proactive about submitting up-to-date photographs during the immigration process. Applicants should prepare for the possibility of additional requests for biometric appointments if their previous photographs fall outside the 36-month limit.

Though the policy update brings some challenges, it aligns with broader efforts to enhance security and ensure that all immigration documents adhere to stringent standards. Applicants are encouraged to carefully monitor the timing of their biometrics appointments and stay informed about the USCIS guidelines to avoid delays or complications in their applications.

Conclusion: Adapting to the New Rules

The USCIS’s revised approach to photo reuse is a vital step toward securing the integrity of the immigration process. By imposing a 36-month limit and eliminating the option for self-submitted photos, the agency aims to standardize the immigration experience for all applicants. Green card holders and prospective U.S. citizens should be prepared for these changes to ensure smooth processing of their applications and to avoid any unnecessary delays.

As the world’s largest democracy continues to refine its immigration procedures, staying informed and adhering to the updated rules is essential for ensuring timely approval of immigration identity documents.

Table: Exempt Applications that Require New Biometrics