USCIS Updates Photograph Reuse Policy for Immigration Benefits

The U.S. Citizenship and Immigration Services (USCIS) announced updated policy guidance on 12.Dec.2025, regarding significant changes to its photograph reuse policy for immigration benefit applications. For the benefit of MurthyDotCom readers, a summary of the new policy is provided.

Background on Photograph Collection

Before issuing a secure document, the USCIS typically collects photographs from benefit requestors during biometric services appointments at an Application Support Center (ASC) or through other approved submission processes. These photographs are used on various identity documents issued by the agency. Once a photograph is on file, the USCIS can reuse the photograph for subsequent benefits requests to negate the need for an applicant to return for additional biometrics.

New 36-Month Photograph Reuse Policy

Under the new policy, the USCIS may reuse a previously collected photograph only if, as of a benefit filing date, no more than 36 months have passed since the date the photograph was collected at an ASC. The policy applies to all immigration benefit requests filed on or after 12.Dec.2025. For those whose photographs are within the 36-month window, the USCIS still may reuse the existing photograph, though the agency reserves the right to request a new one if deemed necessary.

Updated Photograph Policy for Certain Other Forms

The 36-month reuse policy does not apply to form N-400, application for naturalization; form N-600, application for certificate of citizenship; form I-90, application to replace permanent resident card; and form I-485, application to register permanent residence or adjust status. These forms always require the collection of new biometrics, including a new photograph, regardless of when the last photograph was taken. The USCIS also will not use or reuse self-submitted photographs.

Implications for Benefit Requestors

Applicants filing for immigration benefits should be aware that new biometrics will be required more frequently when applying for benefits if their most recent biometric services appointment photograph was taken more than 36 months before their filing date, or if filing one of the enumerated forms above. This may require advance planning when filing for an immigration benefit.

Conclusion

The new photograph reuse policy represents the continued USCIS effort to increase security and vetting for various benefit requests. Individuals with questions about how this policy affects their specific immigration benefit application are encouraged to consult with a qualified immigration attorney.

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