Registration Requirement for Foreign Nationals

March 20, 2025

On March 12, the Trump administration introduced an interim final rule that revives a provision of U.S. immigration law, which has largely remained inactive for years. This provision mandates that immigrants who did not enter the U.S. with a visa must register with the federal government upon arrival and carry proof of their registration.

A new form has been issued for immigrants who are not yet registered to complete. However, many immigrants, including those without formal legal status, are already deemed to be registered. 

This registration process, set to take effect on April 11, is being paired with federal criminal law, which deems it a criminal offense for immigrants to fail to register or carry proof of their registration. By doing this, the Trump administration is adding a new enforcement mechanism, using the possibility of criminal prosecution as leverage against immigrants.

Federal regulations include a list of forms which are considered sufficient for registration. According to the new regulation, anyone who has submitted one of the following forms, or received one of the following notices, and who has been fingerprinted by the federal government is considered “registered” under the law and will not need to submit new registration through the forthcoming process. However, they may need to carry proof of these forms with them if they want to avoid criminal charges. 

For foreign nationals present in the U.S. on work visas through employer sponsorship or self-sponsorship, we have highlighted the most applicable forms below:

• I-94 (Arrival-Departure Record) which covers:
  • People admitted with non-immigrant visas.
  • People paroled into the U.S. under 212(d)(5) of INA.
  • People who have been granted permission to depart without the institution of deportation proceedings.  
• I-95, Crewmen’s Landing Permit—Crewmen arriving by vessel or aircraft. 
• I-181, Memorandum of Creation of Record of Lawful Permanent Residence—Noncitizens presumed to be lawfully admitted.
• I-184, Alien Crewman Landing Permit and Identification Card—Crewmen arriving by vessel.  
• I-185, Nonresident Alien Canadian Border Crossing Card—Citizens of Canada or British subjects residing in Canada.  
• I-186, Nonresident Alien Mexican Border Crossing Card—Citizens of Mexico residing in Mexico.  
• I-221, Order to Show Cause and Notice of Hearing—People against whom deportation proceedings are being instituted.  
• I-221S, Order to Show Cause, Notice of Hearing, and Warrant for Arrest of Alien—People against whom deportation proceedings are being instituted.  
• I-485, Application for Status as Permanent Resident.
• I-551, Permanent Resident Card—Lawful permanent residents of the United States.  
• I-590, Registration for Classification as Refugee-Escapee.
• I-687, Application for Status as a Temporary Resident.
• I-691, Notice of Approval as a Temporary Resident.
• I-698, Application to Adjust Status from Temporary to Permanent Resident.
• I-700, Application for Status as a Temporary Resident. 
• I-766, Employment Authorization Document—People with work permits.
• I-817, Application for Voluntary Departure under the Family Unity Program.
• I-862, Notice to Appear—People against whom removal proceedings are being instituted.  
• I-863, Notice of Referral to Immigration Judge—People against whom removal proceedings are being instituted.

Our firm will continue to closely monitor this development. Please reach out to our firm if you have any questions.