USCIS Implements Three-Year Limit on Immigration Photograph Reuse to Combat Identity Fraud

The US Citizenship and Immigration Services (USCIS) has implemented stricter regulations regarding photographs for immigration documentation to combat identity fraud.

According to the new policy, applicants can no longer use photographs that are more than three years old. Additionally, USCIS will reject images submitted directly by applicants, requiring instead that all photographs be taken either by USCIS personnel or by authorized service providers.

This change represents a significant adjustment to previous protocols. Before this revision, USCIS allowed the reuse of photographs up to ten years old for certain applications that didn't require new biometric data. The acceptable timeframe has now been substantially reduced.

USCIS traced the origin of the more lenient photo policy to accommodations made during the COVID-19 pandemic, when the agency permitted reuse of previously collected images. This resulted in extreme cases where applicants submitted photographs taken as long as 22 years earlier. When pandemic restrictions eased, USCIS initially established a 10-year limit on photo reuse, which they now consider insufficient.

The agency emphasized that physical appearance can change significantly over extended periods, which undermines effective identity verification. USCIS stated that the previous policy weakened their ability to properly verify, identify, and screen non-citizens.

In explaining the new three-year standard, USCIS stated: "USCIS is now changing its photograph reuse policy. USCIS may only reuse a previously collected photograph if, at the time of filing, no more than 36 months (3 years) have passed since the date the photograph was collected at a BSA. This policy applies to all immigration benefit requests, with the exception of the Application for Naturalization (Form N-400), the Application for Certificate of Citizenship (Form N-600), the Application to Replace Permanent Resident Card (Form I-90), and the Application to Register Permanent Residence or Adjust Status (Form I-485). These forms require the collection of new biometrics, including a new photograph."

The agency also noted that it maintains the authority to request a new photograph in any case, even when an existing image might otherwise qualify for reuse under the updated guidelines.