On Wednesday, March 12, 2025, the administration posted an interim final rule (a regulation that allows for public comment but goes into effect as written while comments are being reviewed) which will require certain undocumented immigrants to register with USCIS using a new registration form called the G-325R, which is only available online through the myUSCIS web portal. This interim final rule amends an existing DHS regulation to add this new registration requirement for noncitizens. The government has said that registration will be required starting on April 11, 2025. Unlike an NPRM, or “notice of proposed rulemaking,” this rule will take effect as written even as comments submitted by experts and advocates are being reviewed.
The registration requirement is different and separate from any application for a benefit or status like asylum, a T visa, U visa, or VAWA self-petition. To be clear, registering will not provide a pathway to any form of immigration status, benefit, or relief. For example, registering does NOT lead to a green card or permanent resident status, and it does NOT make someone eligible for a green card or anything else. Instead, registration is a tool for the government to gather information about immigrants so that they can track and locate them.
The federal regulations include a list of forms that are considered proof of being already registered. In fact, some immigrant survivors may be considered already registered. For instance, any of these documents would count as proof of registration: an EAD (work permit), I-94, notice to appear (NTA), or green card – if those in possession of such documents have already been fingerprinted. Immigrants are likely to need to carry these documents as proof of their registration with them at all times if they want to avoid criminal charges.
While some immigrants are considered already registered, many are not. The federal government has threatened to start criminally prosecuting anyone who is subject to the registration requirement but fails to register after April 11, 2025. Again, this new registration form is an enforcement tool. It does NOT confer an immigration benefit.
This puts “unregistered” immigrants in an impossible situation. The two options in front of them both involve risk and a lot of unknowns. Choosing to submit the registration form could put them at risk of being targeted and placed in removal proceedings. Choosing not to submit the registration form may put them at risk of future criminal prosecution for failing to register if they are apprehended by ICE or if immigration authorities reviewing their immigration application note their missing registration. It also raises the possibility that immigrants who are already registered—including those with legal status—may be arrested and prosecuted for failing to carry proof of their registration with them at all times or failing to provide it to law enforcement when asked.
Many immigration advocates have likened this to other dark moments in history where oppressive governments required already vulnerable and targeted groups to carry a unique form of identification or risk persecution.
Impact on Survivors
This registration requirement creates a “dammed if you do and dammed if you don’t” scenario for many immigrants, including survivors who have not yet otherwise satisfied the registration requirement. For survivors, the situation is even more complicated. Immigrant survivors living in domestic violence shelters or residing at safe addresses to avoid being found and harmed by their abusers do not have a clear and consistent way to ensure that the information they submit via this new registration form will have the confidentiality protections required under 8 U.S.C. 1367. People applying for or receiving immigration relief as survivors—specifically under the Violence Against Women Act (VAWA) and T and U visa programs—have legal protections under that U.S. law (8 U.S.C. 1367) including the protection of their information (especially where they live) in immigration databases to prevent abusers from misusing the immigration system to control or harm their victims.
It is also not clear if using a shelter P.O. Box or a P.O. Box associated with the address confidentiality program will be allowable on the G-325R form. Given the lack of clarity about 8 U.S.C.1367 confidentiality protections and what address information will be acceptable on the form, along with a lack of standard form instructions to help individuals complete the form correctly, immigrant survivors are being left to make high risk decisions with little information. The risks are real and retraumatizing for immigrant survivors as they work to comply with the law and secure the rights they are entitled to and rebuild their lives.
Tahirih is working alongside our allies to push back against this requirement via comments and, if the requirement stands, we are also advocating to ensure that this new databased is in compliance with and appropriately implementing the legally required survivor protections under the law (8 U.S.C.1367).
