Biometrics Reuse Policy: New 36-Month Rule
/
On December 12, 2025, U.S. Citizenship and Immigration Services (USCIS) issued Policy Alert PA-2025-29, implementing an important change to biometrics photo reuse requirements. If you're planning to file a work permit extension, travel document, or other immigration benefit, here's what you need to know.
What Changed?
USCIS can now only reuse a previously collected photograph if no more than 36 months (3 years) have passed since the photo was taken at a biometric services appointment. This time is measured from your application filing date.
Previously, the policy used an age-based calculation system that was more complex. The new rule simplifies this to a straightforward 36-month maximum for all applicants, regardless of age.
Key Details of the New Policy
Effective Date: December 12, 2025 (applies to all requests filed on or after this date)
36-month maximum for everyone
Exceptions: Form N-400 (naturalization), N-600 (citizenship certificate), I-90 (green card replacement), and I-485 (adjustment of status) always require new biometrics regardless of this policy
Self-submitted photos will NOT be used or reused
USCIS retains discretion to require new photos even within the 36-month window
What This Means for Your Immigration Case
If your last biometrics appointment was more than 3 years ago and you're filing for an extension, renewal, or other benefit, expect a biometrics appointment notice. This will add time to your case processing, as you'll need to:
Receive the biometrics appointment notice
Attend the appointment at an Application Support Center (ASC) (USCIS schedules the appointment for you)
Wait for USCIS to process your biometrics before your case moves forward
We're already receiving biometrics notices for cases filed in the past few days where photos were previously collected but fall outside the 36-month window.
Planning Ahead
If you're considering filing for a work permit extension, travel document, or other immigration benefit, check when your last biometrics appointment occurred. If it was more than 3 years ago, factor in additional processing time for a new appointment.
For those with green card applications or other complex cases, this policy change emphasizes the importance of submitting complete and accurate applications to avoid unnecessary delays.
Questions About Your Immigration Case?
At L.I.H. Law, we stay current on all USCIS policy changes to provide our clients with timely, accurate guidance. Our bilingual team (English and Spanish) has over 20 years of experience handling complex immigration matters in the Seattle area.
Contact us today for a consultation:
📞 (206) 838-7628
📧 info@lihlaw.com
📍 159 Denny Way, Suite 107, Seattle, WA 98109
Se habla español. Consultas disponibles en inglés y español.