With the exception of two much earlier schemes – the Alien Registration Act of 1940, which registered 6 million noncitizens during World War II, and the National Security Entry-Exit Registration System (NSEERS), which operated briefly after the 9/11 attacks – the term “registration” in the U.S. immigration system has been applied, in practice, only to the process of applying for permanent residence. In fact, the green card is officially called an “Alien Registration Card” or “Alien Registration Receipt Card.”

On February 25, 2025, the Department of Homeland Security announced a new scheme, the Alien Registration Requirement, that applies the term much more broadly by requiring all noncitizens in the United States to register. The announcement lists categories of people, lifted directly from a 1960 regulation, who are deemed to already be registered. These are people who have green cards, parole, I‑94s, visas, EADs or Border Crossing Cards, anyone in removal proceedings, anyone who has filed a form associated with lawful permanent residence, and anyone who has been fingerprinted for another benefit such as DACA or Temporary Protected Status.

Under the Alien Registration Requirement, those who do not meet pre-registration criteria must file a new form, which has not yet been released, by creating a myUSCIS online account. At this time, there appears to be no alternate procedure for those who do not have internet access. There are no exceptions to the requirement based on advanced age or youth: parents and guardians must register on behalf of unregistered children under age 14.

The new registration form is likely to contain, at a minimum, the questions prescribed in 8 USC §1304, “Forms for registration and fingerprinting,” which include:

1. Date and place of entry
2. Activities in which the individual has been and intends to be engaged
3. Length of time expected to remain in the United States
4. Police and criminal record, if any

Although details are not yet available, there is likely to be a deadline to register. Registrants will certainly be required to attend biometrics appointments, and some – possibly based on answers they provide on the form – may be required to report for in‑person interviews. Although DHS says registrants will receive evidence of compliance that they can keep and present when required, it is also highly likely that any undocumented immigrant who complies may be detained and subject to removal.

In addition, all children who reach age 14 in the United States, whether they already hold registration evidence or not, must re-register on their own account within 30 days of their 14th birthdays to be fingerprinted. Presumably, this provision is included because fingerprints are waived for children under age 14 who apply for U.S. visas, green cards, parole, or other benefits that qualify as registration and, it appears, will also be waived for these children under the new system.

The law has always required that children who become permanent residents apply to replace their green cards within 30 days of reaching age 14 (unless the card will expire before their 16th birthday) for the express purpose of being fingerprinted. The provision is essentially unenforceable and no penalty is routinely levied for noncompliance even when the child later applies to replace their green card, which must be renewed every 10 years.

The new registration scheme cites “criminal and civil penalties, up to and including misdemeanor prosecution and the payment of fines” for noncompliance with any of its provisions.

Under existing law, since 1952, it has been a misdemeanor to “willfully fail” to register, carrying monetary penalties of up to $1,000 and/or 6 months in jail, although no specific registration requirement has been established.

The law also already requires noncitizens age 18 and over to carry their “certificate of alien registration” or “alien registration receipt card” at all times or be subject to prosecution, fines up to $100, and/or 30 days’ jail time. More than 3 million nonimmigrants are estimated to be in the United States on tourist, student and work visas. It’s unlikely that many of them carry their passports with visas or their I‑94 admission records as they go about their daily lives. By the same token, an estimated 13 million permanent residents are unlikely to carry their green cards to work, college, or out shopping every day. These are all valuable legal documents that are expensive, difficult and time consuming to replace.

Another provision, also from the 1950s, levies a $200 fine and/or 30-day sentence for not filing a change-of-address notice within 10 days of each residential move – something even people with green cards are required to do, and routinely do not.

These penalties, like the “registration” statutes and regulations, have been on the books for decades but not routinely enforced. Many may assume the new Alien Registration Requirement does not apply to them but only to those who are unlawfully present in the country. However, the Executive Order on which the requirement is based directs federal agencies to make compliance with all of its provisions an “enforcement priority,” requiring action from those who are lawfully present as well.

Nonimmigrants and permanent residents over age 18 must now weigh the legalities and risks of not carrying their registration evidence on their persons. This includes travelers from Visa Waiver Countries who arrive on ESTA and remain in the country for more than 30 days. All nonimmigrants are also well advised to check whether their children have turned age 14 since they were last issued an I-94, a visa, or a green card.