On December 12, 2025, U.S. Citizenship & Immigration Services (USCIS) updated its policy regarding the reuse of photographs for immigration benefit requests. The policy change replaces prior COVID-era flexibilities and previous rules that allowed photographs to be reused for up to 10 years or more. The change will also disallow self-submitted physical photographs and require all photographs to be taken at a USCIS Application Support Center (ASC) or through an approved Biometrics Services Appointment (BSA). 

Key Policy Changes: 

• New Time Limit – USCIS may only reuse a previously collected photograph if it was taken within three (3) years of the filing date.  
• Applies to All Immigration Benefits Except: 
  • Form N-400 (Naturalization) 
  • Form N-600 (Certificate of Citizenship) 
  • Form I-90 (Replacement of Permanent Resident Card) 
  • Form I-485 (Application to Register Permanent Residence or Adjust Status) 
  • *These forms require new biometrics, including a new photograph*  
• USCIS Discretion 
  • At its discretion, USCIS can require a new photograph even if the new 3-year rule has been met. 
• No Self-Submitted Photos 
  • USCIS will no longer accept or reuse physical paper photographs submitted by applicants themselves. Previous to this change in policy, many immigration applications that required a photograph did not require an in-person ASC appointment to obtain the picture as physical/paper photographs could be submitted as part of the initial filing. This extra step in the adjudication process could lead to delays in overall adjudication times.  

The new photograph reuse policy is effective immediately and applies to all benefit requests filed on or after December 12, 2025. Individuals who wish to learn more about how they may be impacted by the policy change should consult with a Foster LLP attorney. Foster LLP will continue to monitor USCIS policy changes and provide additional updates via our firm’s website at www.fosterglobal.com