USCIS Now Limits Photo Reuse to 3 Years, Requiring More Applicants to Provide New Biometrics

USCIS has updated its rules on identity photos, the official photos taken at a biometrics appointment and used on green cards, work permits, and other secure documents. The agency will now only reuse one of these photos if it was taken within the last 36 months. If your last biometrics photo is older than three years, USCIS will require you to attend a new appointment.

This change replaces both the broad COVID-era photo reuse policy and the more complex age-based limits introduced in 2024. As a result, many applicants should expect to provide a fresh photo before USCIS can issue an updated document.

What Photos USCIS Is Talking About

This rule applies only to the ID photo USCIS takes at an Application Support Center (ASC) during a biometrics appointment.

USCIS is not referring to:

• Photos you submit as evidence (such as relationship photos)
• Passport-style photos you mail in yourself
• Any self-submitted photos of any kind

USCIS clearly states it will not use or reuse self-submitted photographs. Only ASC-collected identity photos are covered by the new policy.

What the Previous Policies Allowed

COVID-era policy (2020–2023)

To reduce in-person visits, USCIS reused photos taken years earlier. This sometimes meant applicants received secure documents with photos that could be up to 22 years old.

September 2024 policy

Once pandemic flexibilities ended, USCIS introduced age-based limits:

• For applicants 26 and older: photos could remain valid for up to 10 years
• For applicants 25 and younger: photos could not exceed 30 months
• Officers had to calculate both the age of the photo and the document validity period

This system has now been fully replaced.

What the New Policy Says

USCIS may reuse a previously taken biometrics photo only if it is less than 36 months (3 years) old at the time of filing.

Additional points:

• USCIS can still require a new photo at its discretion
• Officers no longer need to calculate how old a photo will be by the end of a document’s validity
• The rule applies to all immigration benefit types except the following, which always require new biometrics:
  • N-400 (Naturalization)
  • N-600 (Certificate of Citizenship)
  • I-90 (Replace Green Card)
  • I-485 (Adjustment of Status)

This guidance is effective immediately for all applications filed on or after the publication date.

What This Means for Immigrants

More applicants will need to attend a biometrics appointment, even if they recently applied for another benefit.

Action Steps

• Expect a new biometrics notice. Do not assume USCIS will reuse your photo.
• Plan for possible delays. New biometrics can affect processing timelines.
• Keep your mailing address updated. Missing the appointment notice can delay your case.
• Bring valid ID to your ASC appointment. USCIS may require updated identity verification.

If you’re filing an N-400, I-90, N-600, or I-485, prepare for biometrics regardless — photo reuse is not allowed for those forms.

What This Means for Employers

Employers sponsoring foreign workers should plan for more employees needing biometrics appointments.

Action Steps for HR Teams

• Build biometrics into onboarding timelines. Employees may need to travel to an ASC.
• Encourage workers to keep their appointments. Rescheduling can add weeks of delay.
• Plan early for extensions and renewals. Work authorization renewals may involve new biometrics.

Bottom Line

USCIS is now limiting identity-photo reuse to three years, simplifying its internal process and ending the broader reuse practices of the COVID era. For most applicants, this means preparing for a new biometrics appointment before USCIS can issue a green card, work permit, or other secure document.

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