U.S. Citizenship and Immigration Services (USCIS) rolled out a New Photo Policy on December 12, 2025 that changes a small detail with big ripple effects: how “fresh” a photo must be before USCIS will place it on an immigration identity document. Under the new guidance, USCIS will generally only reuse a photo if it was taken within 36 months (three years) of the day a person files their request. USCIS also says it will not use or reuse self-submitted photos—meaning a photo you upload or mail in yourself will not be accepted for this purpose. Instead, USCIS will rely on photos taken by USCIS or by other approved entities through USCIS-approved processes.
The agency says this shift is meant to strengthen identity checks, cut down on document fraud, and support national security in the United States 🇺🇸. It is effective immediately and applies to benefit requests filed on or after December 12, 2025, according to the USCIS Policy Alert PA-2025-29, issued by the Office of the Director in Camp Springs, MD.
December 12, 2025: the change and why it matters immediately
USCIS issues many secure documents that people use to prove who they are and what immigration status they hold. Photos are a core part of that process. When USCIS can’t confidently match a person to the photo on a document, the system becomes easier to exploit for impersonation, stolen identities, and other fraud.
The New Photo Policy tightens identity verification by setting a clearer time limit on photo reuse. The main rule is simple: USCIS may only reuse a previously collected photograph if, at the time of filing, no more than 36 months (three years) have passed since the photo was taken at a USCIS biometrics collection event.
USCIS refers to these events as Biometric Services Appointments (BSA), which often occur at an Application Support Center (ASC) or through “another approved submission process authorized by agency policy.”
USCIS also states it has discretion to require a new photo even when an older photo might still fall within the three-year window. That means the three-year rule is not an absolute guarantee you will avoid a new photo appointment.
What “photo reuse” means in plain language
Many people assume that every time they file a form with USCIS, they must take a new photo. In practice, USCIS sometimes reuses a photo already in its system—if it thinks the photo is still accurate and reliable for identity checks.
Under the policy alert, the photo USCIS may reuse is one collected during a BSA—meaning it was taken as part of biometrics collection connected to an immigration benefit request. Biometrics can include fingerprints and a photograph; this update focuses on the photograph.
Key measurement point:
– USCIS measures the photo’s age at the time of filing.
– If your last USCIS-taken (or otherwise authorized) photo is older than 36 months (three years) on the day you file, USCIS says it may not be reused.
“No self-submitted photos”: what USCIS is cutting off
USCIS states directly in the policy highlights that it will not use or reuse self-submitted photographs. In everyday terms, that means photos you provide yourself—whether printed, scanned, uploaded, or otherwise sent in by you—won’t be used for the secure document photo under this guidance.
USCIS frames this as part of ensuring each photo used on a secure document is “recent, accurate, and reliable,” and as a measure to stop fraud and identity theft.
Practical effect for applicants:
– The change is about process control, not photography skill.
– If USCIS only accepts photos taken through its own capture processes (or another authorized entity), it reduces the risk of altered images, mismatched photos, or photos that don’t reflect the person who will receive the document.
Check the date of your last USCIS photo. If it was captured more than 36 months before you file, be prepared for a new photo capture through a biometrics appointment.
How USCIS got here: COVID-era flexibilities and the 10-year limit in September 2024
During the COVID-19 pandemic, USCIS reused older photographs for certain requestors to reduce in-person appearances at ASCs. USCIS says that approach had an unintended result: it “resulted in the issuance of secure documents where the photograph could be up to 22 years old by the expiration of the secure document’s validity period.”
After the end of those COVID flexibilities, USCIS adopted a September 2024 adjustment limiting photograph reuse to a maximum of 10 years on an agency-issued secure document. Under the September 2024 approach:
- For requestors 26 years of age and older, USCIS considered the age of the photograph at the time of initial reuse and ensured it did not exceed 10 years during the secure document’s validity period.
- For requestors 25 years of age and younger, USCIS required that the photo could not exceed 30 months during the validity period of the secure document.
The December 12, 2025 policy alert changes the approach again. It removes the need for multiple calculations tied to age and document validity time by using a single three-year test measured at filing, and it applies broadly.
The core rule and the main exceptions
Baseline three-year rule for most benefit requests
USCIS states it may only reuse a previously collected BSA photograph if, at the time of filing, no more than 36 months (three years) have passed since that photo was collected at a BSA. This policy “applies to all immigration benefit requests,” unless the filing falls into one of the listed exception forms.
USCIS also notes it may require a new photo instead of reusing an existing one. That discretion is important if USCIS believes the older photo does not support strong identity screening.
Forms that always require new biometrics (including a new photograph)
USCIS identifies specific forms that require the collection of new biometrics, including a new photograph, even if a reusable photo exists:
- Form I-90, Application to Replace Permanent Resident Card
- Form I-485, Application to Register Permanent Residence or Adjust Status
- Form N-400, Application for Naturalization
- Form N-600, Application for Certificate of Citizenship
If you are filing one of these forms, the New Photo Policy’s three-year reuse rule does not eliminate the need for a new photo. USCIS says the forms above “require the collection of new biometrics,” which includes a new photograph.
Timing: what “effective immediately” means for real filings
USCIS is explicit about timing. The policy guidance is effective immediately and applies to benefit requests filed on or after the publication date, which is December 12, 2025.
This creates a clear dividing line:
– Requests filed on or after December 12, 2025: the three-year rule and the “no self-submitted photos” rule apply as written.
– The alert does not describe a grace period and states the Policy Manual guidance “is controlling and supersedes any related prior guidance on the topic.”
Important: USCIS measures the 36 months (three years) at the time of filing, not at the time of decision.
Do not rely on self-submitted photos. USCIS will not reuse uploaded or mailed-in images; use photos captured through USCIS or approved processes to avoid delays or missing identity verification.
Key takeaway: Your filing date matters. If your last USCIS-authorized photo was taken more than 36 months before you file, expect USCIS may require a new photo.
Where the change sits in the USCIS Policy Manual
USCIS says the guidance is included in Volume 1 of the Policy Manual. The policy alert cites:
– Volume 1: General Policies and Procedures
– Part C: Biometrics Collection and Security Checks
– Chapter 2: Biometrics Collection
– Reference: [1 USCIS-PM C.2]
– Affected location: Volume 1 > Part C > Chapter 2 > Section D, Biometrics Collected, with revisions in Subsection 2 (Photographs).
USCIS may make “minor technical, stylistic, and conforming changes” consistent with the update.
For the official Policy Manual page tied to this area, USCIS directs readers here: USCIS Policy Manual, Volume 1, Part C, Chapter 2. This link is where readers can check the agency’s posted materials connected to the alert.
Why USCIS says the New Photo Policy helps
USCIS anchors the change in screening and vetting: the update “enhances national security and prevents identity fraud.” In the policy alert background, USCIS is more direct about the operational problem: older photos, even if once valid, can reduce the agency’s ability to “verify, identify, and properly screen” people.
USCIS criticized the long tail of COVID-era practices, saying the flexibilities were “kept in place longer than necessary” and “compromised USCIS’ ability” to do strong identity checks.
The agency links the new policy to “Department of Homeland Security priorities to modernize screening and vetting processes and address the vulnerabilities in identity documents.” In short, USCIS treats photo freshness as a first-line defense: a photo taken within three years is more likely to match the person who appears for any follow-on steps.
What applicants can expect in practice
Even though USCIS does not list every process detail in the alert, the direction is clear: if USCIS cannot reuse a photo under the three-year rule, the agency will capture a new one through a BSA or another approved method.
This affects different groups:
- People who file infrequently:
- If you haven’t had a USCIS biometrics-based photo taken in more than 36 months (three years), be prepared for a new capture step.
- People who file often:
- If your last BSA photo was taken within the last three years, USCIS may reuse it—unless it decides to collect a new photo anyway.
- Applicants for I-90, I-485, N-400, or N-600:
- USCIS will collect new biometrics for these forms, including a new photograph.
According to analysis by VisaVerge.com, the biggest day-to-day change for many filers is not only the three-year cap, but the end of self-submitted photos and the stronger emphasis on controlled photo capture. That can mean fewer situations where a person thinks they provided a valid photo, only to learn later it won’t be used for the secure document.
Official help and verification
For authoritative information, USCIS points readers to its main site: USCIS. The policy update is framed as a Policy Manual change, and USCIS notes the Policy Manual guidance is controlling.
USCIS phone contact provided in the material: 800-375-5283.
Recommended steps to confirm how the New Photo Policy applies to your filing:
1. Read the USCIS Policy Manual section and the policy alert language tied to photo reuse.
2. Check when your last USCIS-authorized photo was captured at a BSA.
3. Determine whether your next filing is one of the forms that always requires new biometrics (I-90, I-485, N-400, N-600).
4. If uncertain, consult the USCIS Policy Manual page or contact USCIS using the channels above.
USCIS’s New Photo Policy, effective December 12, 2025, limits reuse of agency-collected photographs to those taken within 36 months of filing. Self-submitted photos are not eligible for secure documents; only photos captured by USCIS or approved entities at BSAs or ASCs qualify. Forms I-90, I-485, N-400, and N-600 always require new biometrics including a new photo. The rule aims to reduce identity fraud and strengthen identity verification; applicants should verify their last authorized photo date and schedule biometric appointments if needed.
