DHS Alien Registration Rule: What H-1B Holders Need to Know

What Happened

On June 29, 2026, the Department of Homeland Security [published a Final Rule](https://www.govinfo.gov/content/pkg/FR-2026-06-29/html/2026-13057.htm) in the Federal Register (91 FR 39248–39332) codifying the online registration requirement for certain foreign nationals in the United States. The rule finalizes and replaces the interim regulations that DHS put in place in March 2025 and that took effect in April 2025.

The rulemaking traces back to Executive Order 14159, [Protecting the American People Against Invasion](https://www.uscis.gov/alienregistration), signed by President Trump on January 20, 2025. That order directed DHS to enforce longstanding registration requirements under [Section 262 of the Immigration and Nationality Act](https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title8-section1302&num=0&edition=prelim) (8 U.S.C. 1302), which has required most noncitizens aged 14 and older to register with the federal government since 1940. DHS originally implemented the requirement through an interim final rule without advance notice; this Final Rule incorporates public comment feedback and makes several clarifications.

Critically, [the rule does not create any new registration obligations](https://www.fragomen.com/insights/united-states-dhs-finalizes-rule-on-foreign-national-registration-requirement-with-clarifications.html). It does not expand who must register. Instead, it formalizes the existing framework and introduces Form G-325R as the standard registration mechanism for individuals who are not already considered registered.

Who Is Affected — and Who Is Not

For H-1B holders, the most important takeaway is straightforward: you are already registered and have no new obligations under this rule. The same applies to most employment-based visa holders.

• **Already registered (no action needed):** Foreign nationals who entered on a valid visa, were issued a Form I-94 admission record, hold an Employment Authorization Document (EAD), have a green card, or filed qualifying applications such as adjustment of status (Form I-485). This covers H-1B, O-1, L-1, TN, and virtually all employment-based nonimmigrant categories.
• **Subject to online registration:** Foreign nationals who entered the United States without inspection and will remain 30 or more days; visa-exempt Canadian nationals who entered at a land port of entry without receiving an I-94 and will remain 30 or more days; and foreign national children who turn 14 while present in the United States for 30 or more days.
• **Newly exempted:** Individuals who enter under a [Trusted Traveler program](https://www.fragomen.com/insights/united-states-dhs-finalizes-rule-on-foreign-national-registration-requirement-with-clarifications.html) — Global Entry, NEXUS, SENTRI, or FAST — are now recognized as registered. This is a new clarification in the Final Rule that was not in the interim regulations.

The Age-14 Requirement: What H-1B Families Must Know

The provision with the most direct impact on H-1B families concerns dependent children. Under the Final Rule, foreign national children who turn 14 while in the United States and will remain for 30 or more days must complete online registration within 30 days of their 14th birthday — even if they were previously registered through an earlier visa or I-94.

This applies to children of H-1B professionals on H-4 dependent visas, as well as children of L-1 executives, international students, and other temporary visa holders who entered before turning 14. As [Mitch Wexler, senior counsel at Fragomen](https://timesofindia.indiatimes.com/nri/us-finalises-alien-registration-rule-h-1b-holders-need-not-register-again-children-turning-14-must/articleshow/132103418.cms), told the Times of India: "The clarification is relevant for children of H-1B professionals, L-1 executives, international students and temporary visa holders who entered the US before turning 14."

The registration process requires creating a USCIS online account, submitting biographic information via the new [Form G-325R](https://eiglaw.com/dhs-finalizes-alien-registration-rule-introducing-new-uscis-form-g-325r/) (Biographic Information — Registration), and attending a biometrics appointment for fingerprinting and a background check. DHS has not imposed a biometric fee at this time, though the agency indicated this may be considered in the future.

One exception: children who are lawful permanent residents (green card holders) turning 14 satisfy the re-registration requirement by filing Form I-90 to replace their green card, as already required under existing law. They do not need to separately file Form G-325R.

Form G-325R and Updated Registration Evidence

The Final Rule designates [Form G-325R (Biographic Information — Registration)](https://eiglaw.com/dhs-finalizes-alien-registration-rule-introducing-new-uscis-form-g-325r/) as the universal registration mechanism for individuals who have not previously registered through existing immigration processes. The form is filed online through a USCIS account, and upon completion, registrants receive digital proof of registration that serves as official evidence under federal law.

The rule also updates and modernizes the list of documents that qualify as evidence of registration:

• Digital proof of G-325R registration (new)
• Form I-94 and related travel records
• Employment Authorization Documents (EADs)
• Lawful permanent resident (green) cards
• Trusted Traveler program documentation — Global Entry, NEXUS, SENTRI, FAST (new)
• Certain removal-related documents such as expedited removal orders

Compliance Reminders: Documentation and Address Changes

While the Final Rule does not create new obligations for most visa holders, it reinforces existing requirements that carry real consequences for noncompliance. Two requirements deserve particular attention.

• **Carry proof of immigration status.** Under INA Section 264(e) (8 U.S.C. 1304(e)), every registered foreign national 18 or older must carry proof of registration at all times. For H-1B holders, this means keeping your valid I-94, approved I-797 notice, or other qualifying document accessible. Failure to carry evidence of registration is a misdemeanor under [INA Section 266(a)](https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title8-section1306&num=0&edition=prelim) (8 U.S.C. 1306(a)).
• **Report address changes within 10 days.** Under [INA Section 265](https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title8-section1305&num=0&edition=prelim) (8 U.S.C. 1305), every foreign national must notify DHS of any change of address within 10 days by filing [Form AR-11](https://www.uscis.gov/ar-11) online or by mail. This is a longstanding requirement, but enforcement has increased under the current administration. Willful failure to report an address change is punishable by fines of up to $200 and up to 30 days imprisonment.

What Attorneys Should Know

The Final Rule is largely a codification rather than a policy shift, but practitioners should note several developments.

• **No expanded scope.** The registration requirement applies only to the categories already established in the April 2025 interim rule. No new classes of nonimmigrants, including H-1B holders, have been added. Advise clients who are asking about the rule that visa holders with valid I-94s, EADs, or approved petitions are already considered registered.
• **Trusted Traveler clarification.** The inclusion of Global Entry, NEXUS, SENTRI, and FAST as qualifying evidence of registration is new in the Final Rule and may be relevant for Canadian TN holders or frequent cross-border travelers who previously had ambiguous registration status.
• **Age-14 compliance calendaring.** For families with minor dependents on H-4, L-2, or similar visas, build the 30-day registration deadline after the child's 14th birthday into your case management workflow. The requirement applies even if the child had a prior registration through an earlier visa.
• **Enforcement environment.** The Final Rule, combined with increased DHS enforcement posture under EO 14159, signals that registration compliance will receive greater scrutiny. Ensure clients understand both the carry-documentation and address-change requirements, particularly given that violations carry criminal penalties under INA Section 266.
• **Federal Register citation.** The Final Rule is published at 91 FR 39248 (June 29, 2026), FR Doc No. 2026-13057. It amends 8 CFR Part 264 (alien registration form and evidence of registration).

What Applicants Should Do

For most H-1B holders and employment-based visa applicants, no immediate action is required. But this is a good moment to audit your compliance.

• **Verify your registration status.** If you entered the United States on a valid visa and received an I-94, you are already registered. You can confirm your I-94 record at [i94.cbp.dhs.gov](https://i94.cbp.dhs.gov).
• **Check your carry documents.** Make sure you have a physical or digital copy of your current I-94, approved I-797, or valid EAD accessible at all times. A phone screenshot of your I-94 from the CBP website is generally considered acceptable.
• **Review your AR-11 filing history.** If you have moved since your last address change filing, file [Form AR-11](https://www.uscis.gov/ar-11) immediately. The 10-day window is strict, and the current enforcement environment makes compliance more important than ever.
• **Calendar your child's 14th birthday.** If you have a child on an H-4 visa who will turn 14 while in the United States, mark the date and begin the registration process promptly. You will need to create a USCIS online account for the child and file Form G-325R within 30 days of their birthday.
• **Keep Trusted Traveler documents current.** If you hold a Global Entry, NEXUS, SENTRI, or FAST membership, know that this now counts as evidence of registration — but only if the membership is active and valid.