Green card holders in the US need to be aware of certain new rules announced recently by the Trump administration. U.S. Citizenship and Immigration Services (USCIS) has issued new guidance that limits the age of foreign nationals’ photos that can be used to create immigration documents to no more than three years.
Starting December 12, 2025, the new guidance in the USCIS Policy Manual limits the use of photos to those that were taken within three years of the date a person files a USCIS form.
Additionally, self-submitted photos will no longer be accepted. Only photos taken by USCIS or other authorized entities will be used. USCIS believes that it will ensure every photo used in a secure document is recent, accurate, and reliable—key requirements to preventing fraud and identity theft.
Green Card Holders
US immigrants with lawful permanent residence status, also called Green Card holders, have different pathways to become US citizens. Some of them require a ‘change of status’, while others may be directly eligible for the green card. After meeting other conditions, they can apply for US citizenship through the process of Naturalization.
At each stage, they need to file the right application form. Form I-485, is used as an Application to Register Permanent Residence or Adjust Status, while Form I-90, is to be used as an Application to Replace Permanent Resident Card. For applying for Naturalization, Form N-400, Application for Naturalization is used and Form N-600, is to be used as an Application for Certificate of Citizenship.
All these forms will require a new photo, regardless of when an applicant’s or petitioner’s last photograph was taken.
As part of the current process of issuing secure documents, USCIS may take a photograph of a benefit requestor at an Application Support Center (ASC) or through another approved submission process authorized by agency policy, collectively referred to as a biometric services appointment (BSA) for this update.
New Rule for Green Card Holders
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, except 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. So, whenever green card holders are required to submit applications for Naturalization, or an application for Certificate of Citizenship, the application to replace a permanent resident card, or the application to register permanent residence, or for adjustment of status, they need to provide new biometrics, including a new photograph. For other immigration forms, the photographs taken within the last 3 years remain valid.