U.S. Citizenship and Immigration Services (USCIS) announces new policies regarding photographs required for certain applications
12 December 2025
USCIS has published a policy memo regarding requirements for photographs submitted with immigration benefit applications. The memo is effective December 12, 2025, and states that USCIS will require photos taken at a USCIS Biometric Services Appointment (BSA). The agency will no longer accept self-submitted photos. It also limits the re-use of photos submitted within a three-year period. Some applications would always require new photos, for example, the I-90 application for a green card replacement; the I-485 application to register permanent residence or adjust status; the N-400 application for naturalization, and the N-600 application for certificate of citizenship.
It is as yet unclear whether students filing an I-765 application for OPT would be required to have a photo taken at a BSA, or if they would still be able to file the I-765 with self-submitted photos. The USCIS policy manual states, “[i]n limited circumstances and subject to applicable form instructions, USCIS may require a photograph to be submitted along with an application, petition, or request to produce a secure document, even when there is no associated biometrics collection requirement for that application, petition, or request.” Until more clarification is received, it is probably best for students to continue to submit compliant photos with the I-765 application, but to be aware that they may receive a notice for a biometrics appointment in order to have the photos taken.
The USCIS memo can be found here. The statement issued on the USCIS website is found here.