Advocates Object to Alien Registration Form and Process Under Interim Final Rule

On May 12, 2025, the American Immigration Lawyers Association (AILA) published comments on a U.S. Citizenship and Immigration Services (USCIS) interim final rule, “Alien Registration Form and Evidence of Registration,” published March 12, 2025, and the related Form G-325R (Biographic Information). Among other things, AILA asserts that:

• The interim final rule violates the U.S. Constitution, the Administrative Procedure Act, and the Paperwork Reduction Act; exceeds the agency’s authority; and is inconsistent with the statutory requirements.
• The requirement on Form G-325R to list all addresses over a five-year period is unduly burdensome and goes far beyond the kind of information that is referenced in the Immigration and Nationality Act.
• The only drop-down selections provided by the form are “Entered Without Inspection (EWI)” or leaving the section blank. There is no clear instruction on how to complete the form if the registrant did not enter EWI.
• Similarly, the G-325R asks for the registrant’s current I-94 number, which is confusing because someone who has been issued an I-94 is normally viewed as having already complied with the registration requirement.
• Another confusing section of the form asks for the date of immigration status expiration in month, day, and year format. With several nonimmigrant statuses, such as F-1, J-1, and M-1, individuals are present in the U.S. for the duration of status (D/S).
• Further confusing is the selection of immigration status on the form. In the dropdown menu used to select one’s status, it is unclear whether all potential immigration status options are made available.
• The form contains ambiguous questions that lack instructions clarifying how much information should be provided for each.
• In certain portions of the form, it is unclear which questions are required fields, and which fields are optional.
• Form G-325R’s requirement for full disclosure of all arrests, charges, and convictions—regardless of age, expungement, or relevance—raises significant legal and due process concerns.
• The rule skips the usual notice-and-comment process and, thus, there has been no opportunity to suggest clarifications to the form, resulting in unnecessary practical complications.

AILA therefore recommends that both the interim final rule and Form G-325R be withdrawn.

This is posting is for informational purposes and is not intended as legal advice. If you require further assistance or advice relating to the above, If you require further assistance or advice relating to the above, please contact our Principal Lawyer, Janice Flynn at janice@flynnhodkinson.com.