US Expands Biometric Exit Checks with Photo Verification

(U.S. Customs and Border Protection) U.S. Customs and Border Protection has issued an interim final rule authorizing nationwide biometric exit checks, requiring live photographs—biometric facial scans—of all non‑U.S. citizens as they depart the country by air, sea, or land. The move, approved by the Office of Information and Regulatory Affairs on September 15, 2025, removes earlier pilot limits and clears the way for full deployment at ports of departure where cameras and network systems are in place.

U.S. citizens may still have their photo taken at departure, but they retain the right to opt out and complete a manual document check instead.

How the system works

CBP’s Traveler Verification Service (TVS) is a cloud‑based matching system. It compares a traveler’s live image captured at the gate or departure point with a government photo gallery built from existing records (passports, visas, and prior entry photographs).

• The live image is captured by a camera as the traveler prepares to board.
• TVS runs a quick match against the government-held reference gallery.
• If the image matches, the traveler proceeds without handing a passport to the gate agent.
• If the match fails or no reference image is found, a manual inspection follows.

CBP describes this as part of a long‑delayed statutory mandate to build an integrated entry–exit system using:
– Biographic data (name, date of birth, travel document number), and
– Biometrics (physical traits used to verify identity).

Who is affected and where it will occur

• Who is covered: The rule applies to all departing non‑U.S. citizens (statutorily referred to as “aliens”; CBP often uses “noncitizens”).
  • U.S. citizens may be photographed but can opt out for a manual check.
• Where it will occur: Airports, seaports, and land border crossings—any port where cameras and network systems are installed.
• When expansion begins: The rule was approved on September 15, 2025, enabling immediate scaling as infrastructure comes online.
• Why DHS is doing this: CBP says the goals are to:
  • Verify who leaves the United States,
  • Reduce impostor risk,
  • Flag visa overstays,
  • Identify known or suspected threats before departure.

Background and policy context

Attempts to create a full entry–exit system date back to the post‑9/11 era (PATRIOT Act and the Enhanced Border Security and Visa Entry Reform Act of 2002). While biometric entry checks expanded over time, exit checks remained limited to pilots (starting around 2015). The new interim final rule ends the pilot approach and allows nationwide biometric exit checks where technology is available.

CBP emphasizes that the exit program uses photographs already collected during visa issuance, lawful permanent resident enrollment, or prior arrivals to build the TVS reference gallery. The agency says the live capture at the gate is a short, contact‑free step intended to speed queues and reduce document handoffs.

Privacy, retention, and civil liberties concerns

Privacy and civil‑liberties groups have raised longstanding concerns:

• Error rates can be higher for some demographic groups (age, skin tone), increasing the risk of false matches.
• Worries exist about mission creep—the possibility that data collected for exit checks might be repurposed for broader law‑enforcement searches.
• Critics demand stronger proof that deletion and retention policies are followed and auditable.

CBP’s stated safeguards:
– Images of U.S. citizens are deleted within 12 hours and are not enrolled into biometric databases.
– Images of non‑U.S. citizens may be retained longer and cross‑checked against Department of Homeland Security identity systems.
– CBP says photos taken at exit are used solely to confirm identity and create a reliable departure record.

For more details on CBP’s biometric and privacy rules, see the CBP biometrics page: https://www.cbp.gov/travel/biometrics

Important takeaway: CBP maintains a manual backup for cases where TVS cannot confirm identity, but civil‑liberties groups want clearer, verifiable audit trails and more visible opt‑out notices.

Operational impact: carriers, cruise lines, and ports

The expansion affects airlines, cruise lines, land ports, and travelers:

• Many carriers and cruise lines have already invested in cameras, network capacity, and TVS connections to meet federal data duties and to speed boarding lines.
• Gate staff may rely more on live image matches and less on passport handoffs, reducing bottlenecks during busy departures.
• Cruise terminals and land ports have variable physical layouts; some will require more time and investment to install hardware.

CBP and industry say a successful rollout could:
– Reduce document handling at gates,
– Improve departure processing speed,
– Help create consistent arrival‑and‑departure records to better target overstay enforcement.

Impact on travelers and practical advice

Immigrant communities, international students, and temporary workers will see the greatest immediate effect because checks will become consistent across more locations. Practical guidance:

1. Expect a live photo at the gate if you’re a non‑U.S. citizen departing internationally.
2. If you’re a U.S. citizen and prefer not to be photographed:
   • You may opt out and request a manual check.
   • Allow extra time, as manual verification can take longer.
3. Keep travel documents readily available in case a manual inspection is needed.
4. Follow posted signs and gate‑agent instructions—equipment and layouts vary by port.
5. Families should stay together during boarding so officers can verify everyone accurately.

A mismatch usually leads to a quick manual check rather than immediate removal from the flight. To reduce delays, arrive at the gate early, keep your passport handy, and be prepared for staff to request documents.

Debate and accuracy concerns

• Researchers and rights groups note facial‑recognition systems can vary in performance across age groups and skin tones.
• CBP counters that TVS uses high‑quality reference photos and controlled capture at the gate to improve accuracy.
• The agency maintains manual processes to resolve mismatches and says the program is designed for travel‑identity checks only.

Summary of policy points (table)

Final context and outlook

The interim final rule completes a long‑running objective to close gaps in departure records that have persisted since the post‑9/11 period. As systems and hardware roll out, travelers will encounter more signs, cameras near boarding lines, and staff trained to explain the process.

The change will likely speed boarding for many but magnifies ongoing debates about fairness, error rates, retention practices, and civil‑liberties safeguards. CBP says a complete entry–exit record will help target enforcement on real cases and avoid duplicate records, while advocates press for transparency, visible opt‑out notifications, and verifiable deletion/audit mechanisms.

For travelers: non‑U.S. citizens should plan on a quick photo at exit; U.S. citizens can opt out and request manual verification; and nationwide expansion will follow the September 2025 approval as ports install equipment and networks.