USCIS Photograph Reuse Policy Update (Effective December 12, 2025)

The U.S. Citizenship and Immigration Services (USCIS) has issued updated guidance in the Policy Manual limiting the reuse of previously collected photographs for immigration benefit requests.

This change standardizes biometric photograph requirements and strengthens identity verification processes.

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Key Policy Provisions

Biometric Services Appointment (BSA) Definition

Photographs are collected during Biometric Services Appointments (BSA) at Application Support Centers (ASC) or through other USCIS-approved submission methods authorized by agency policy.

36-Month Reuse Limitation

USCIS may reuse a previously collected BSA photograph only if no more than 36 months (3 years) have passed since the photograph collection date at the time of filing the benefit request.

USCIS Discretion

Even when a photograph meets the 36-month requirement, USCIS reserves the right to require a new photograph at its discretion.

Prohibited Practices

USCIS will not accept or reuse self-submitted photographs from applicants.

Simplified Calculation

The previous requirement to calculate both photograph age and secure document validity timeframe has been eliminated.

Excluded Forms (New Photographs Required)

• Form N-400 (Application for Naturalization)

• Form N-600 (Application for Certificate of Citizenship)

• Form I-90 (Application to Replace Permanent Resident Card)

• Form I-485 (Application to Register Permanent Residence or Adjust Status)

Forms Eligible for Reuse

All other USCIS benefit requests may use photographs meeting the 36-month requirement, subject to USCIS discretion.

Strategic Implications

This policy aligns with Department of Homeland Security priorities to modernize screening and vetting processes while addressing vulnerabilities in identity documents. Recent photographs enhance national security and prevent identity fraud across all immigration benefit categories.

Source: USCIS Policy Manual Update (PM-602-0187), December 12, 2025PDF Link

The Visa Code will monitor implementation and provide client guidance on affected filings.