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USCIS Says It Will No Longer Accept Self-Submitted Photos, and Limits Reuse of Photos

On December 12, 2025 USCIS announced that it has updated is policy on photographs used in connection with immigration benefit requests, by no longer accepting self-submitted photos and limiting the circumstances in which even USCIS-taken photos may be reused in benefit requests.

For reference, "The term benefit request means any application, petition, appeal, motion, or other request submitted to USCIS for adjudication." 1 USCIS-PM A, footnote 10. This NAFSA advisory uses the example of Form I-765, Application for Employment Authorization, as a lens for exploring the new policy, but the questions may be applicable to other applications that require photographs.

Requiring all applicants to be scheduled for and attend a Biometric Services Appointment (BSA) at a USCIS Application Support Center (ASC) could in many cases present one more obstacle in the smooth operation of immigration benefits processing.

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Basic Mechanics

Regarding the USCIS policy of no longer accepting self-submitted photographs:

NAFSA note: "Self-submitted" likely means any photographs that are submitted by the applicant rather than a USCIS Application Support Center, even if the photos were taken by a commercial entity.

Form I-765 instructions already describe the mechanics of ASC appointments:

"Biometric Services Appointment. USCIS may require that you appear for an interview or provide biometrics (fingerprints, photograph, and/or signature) at any time to verify your identity, obtain additional information, and conduct background and security checks, including a check of criminal history records maintained by the Federal Bureau of Investigation (FBI), before making a decision on your application or petition. After USCIS receives your application and ensures it is complete, we will inform you in writing if you need to attend a biometric services appointment. If an appointment is necessary, the notice will provide you the location of your local or designated USCIS Application Support Center (ASC) and the date and time of your appointment..."

Since this is a new policy communicated out by limited USCIS language, the scope of the policy is not yet entirely clear, i.e., but it appears that all Form I-765 applicants will now be scheduled for a BSA at an ASC.

Penalty for Failing to Attend a Biometrics Services Appointment

8 CFR 103.2(b)(13)(ii) provides that:

"if USCIS requires an individual to appear for biometrics capture, an interview, or other required in-person process but the person does not appear, the benefit request shall be considered abandoned and denied unless by the appointment time USCIS has received a change of address or rescheduling request that the agency concludes warrants excusing the failure to appear."

USCIS Policy Manual 1 USCIS-PM A, Biometric Services Appointments, covers some details of making a timely request to reschedule a BSA as well as the details of missed BSAs. This is not a new rule, but understanding it in the current context is important.

Discussion Questions

The USCIS documents contain very little procedural information so there are several points that are still unclear. We have the following questions, using Form I-765, Application for Employment Authorization as our example:

  • Applicants who file their Form I-765 on and after December 12, 2025. Will all I-765 applicants now have to wait for USCIS to issue a Biometrics Services Appointment (BSA) notice at an Application Support Center (ASC) in order to have a photograph taken (if they do not already have on file a USCIS-taken photograph that is less than three years old)?
    • Reports from the field are that OPT applicants have begun receiving ASC notices and/or RFEs relating to the biometric collection requirement.
  • Applicants whose pending Form I-765 was filed before December 12, 2025 with self-submitted photographs, as per Form I-765 instructions. Will these applicants be "grandfathered" in any way, i.e., will USCIS adjudicate their applications based on their self-submitted photographs? Or will they too be issued and required to appear for a BSA at an ASC?
  • Should I-765 applicants continue to submit 2 passport-style photographs as per Form I-765 instructions?
    • Form I-765 Instructions 08/21/2025 (version 08/21/25) still tell applicants to submit two passport-style photos with their applications. USCIS's Checklist of Required Initial Evidence for Form I-765 (05/15/2025) likewise still tells applicants to submit two photographs. Must applicants continue to provide these self-submitted photographs, even though it is now USCIS's policy to not accept them? [NAFSA note: it would be prudent to continue submitting these photographs until USCIS updates the Form I-765 instructions to state otherwise]
    • Regarding any necessary changes to the language of the Form I-765 instructions, can USCIS put revised instructions on the Form I-765 launch page in the interim while the Form I-765 Instructions are being updated?
  • May an applicant who has already been issued a BSA at an ASC "walk in" to have biometrics collected before the appointment day and time?
    • The regulations at 8 CFR 103.2(b)(9) state that "Any person required to appear under this paragraph may, before the scheduled date and time of the appearance, either: (i) Appear before the scheduled date and time; (ii) For good cause, request that the biometric services appointment be rescheduled; or (iii) Withdraw the benefit request." If an applicant has received their BSA to go to an ASC, will ASCs accept them as a "walk-in" if they arrive before the scheduled date and time and present their appointment notice, under 8 CFR 103.2(b)(9)(i)?
  • May an applicant who has received an ASC appointment change the date and time of the appointment? Reports from the field are that the Potomac Service Center (PSC) provided the following language that can be shared with applicants:
    • "If you need to reschedule your current ASC Biometrics Appointment, you may log in to your USCIS online account to use the online Self-Rescheduling tool or go to my.uscis.gov/appointmentscheduler-appointment/ca/en. You will be able to change the date, time, and the location of the appointment.
    • Please Note: The Self-Rescheduling tool cannot be used to reschedule an appointment that has already been rescheduled two or more times, is within 12 hours, or has already passed."

Limits on USCIS Reuse of USCIS-Taken Photos

USCIS Policy Alert PA-2025-29 and the related USCIS News Alert also communicate that it will limit its reuse even of photographs taken during a BSA at an ASC.

No reuse of photos. Prior photographs and other biometrics collected by USCIS for other purposes will never be reused for the following applications. These applications will always require the collection of new biometrics through a BSA, including a new photograph:

  • Form I-485, Application for Adjustment of Status
  • Form I-400, Application for Naturalization
  • Form N-600, Application for Certificate of Citizenship
  • Form I-90, Application to Replace Permanent Resident Card

Limited reuse of photos. For all other benefit requests other than the ones listed above (e.g., an EAD/Form I-765), USCIS Policy Manual 1 USCIS-PM D.2 specifies:

  • "USCIS may reuse a previously collected BSA photograph if, at the time of filing, no more than 36 months (3 years) have passed since the date that USCIS or an authorized entity collected the photograph at a BSA."

USCIS Policy Alert PA-2025-29, December 12, 2025 also clarifies that even if a BSA photograph is less than 3 years old "USCIS has the discretion to require a new photograph from requestors in lieu of reusing an existing photograph."

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