G-325R Emergency Memo

U.S. Department of Homeland Security
U.S. Citizenship and Immigration Services
Office of Information Technology
Washington, DC 20529

Memorandum
TO:

Dominic Mancini
Acting Administrator,
Office of Information and Regulatory Affairs,
Office of Management and Budget

THROUGH:

Randolph D. Alles
Deputy Under Secretary for Management,
U.S. Department of Homeland Security

FROM:

Jerry Rigdon
JERRY L
Acting Chief, Regulatory Coordination Division,
RIGDON
USCIS Office of Policy and Strategy

SUBJECT:

Digitally signed by JERRY L RIGDON
Date: 2025.02.25 12:30:09 -05'00'

Request for Emergency OMB Paperwork Reduction Act (PRA) Clearance – USCIS Form
G-325R, Biographic Information (Registration)

Purpose: U.S. Citizenship and Immigration Services (USCIS) is requesting emergency approval of the
USCIS Form G-325R, Biographic Information (Registration), which is a new collection of information.
USCIS is seeking approval for the new collection of information under 5 CFR 1320.13.
Background: Section 103(a)(1) of the Immigration and Nationality Act (INA), 8 U.S.C. § 1103(a)(1),
gives the Secretary of Homeland Security general authority to enforce and administer the immigration
laws. Section 103(a)(3) of the INA, 8 U.S.C. § 1103(a)(3), authorizes issuance of forms, instructions, and
guidance necessary to carry out the authority provided in section 103(a)(1) of the INA, 8 U.S.C. §
1103(a)(1).
The registration and fingerprinting requirements currently appear in INA sections 261-266. Under section
262 of the Immigration and Nationality Act (INA), with limited exceptions, all aliens above the age of 14
who were not fingerprinted or registered when applying for a visa to enter the United States or at the time
of their admission or parole and who remain in the United States for 30 days or longer, must apply for
registration and be fingerprinted before the expiration of the 30 days. Similarly, parents and guardians
must ensure that their children below the age of 14 are registered. 8 U.S.C. 1302(b). Within 30 days of
reaching his or her 14th birthday, the alien child must “apply in person for registration and to be
fingerprinted.” 8 U.S.C. 1302(b). Under INA 264, DHS is authorized and directed to prepare forms for
the registration and fingerprinting of aliens. Implementing regulations of the registration requirement are

found at 8 CFR part 264 and they provide that if an alien is not already registered, that within 30 days
after reaching the age of 14, any alien in the United States not exempt from alien registration under the
INA and Chapter I of Title 8 of the Code of Federal Regulations must apply for registration and
fingerprinting, unless fingerprinting is waived. See 8 CFR 264.1(g) and 8 CFR 264.1(e). Upon
registration, DHS must issue the appropriate registration documentation. See INA 264(d) and 8 CFR
264.1(b). The statute requires that the alien must always carry and have in their possession their
registration document. See INA 264(e). Any alien who fails to register or provide notification of a change
of address, makes fraudulent statements, or provides counterfeit documents during the registration process
is subject to criminal penalties. See INA 266.
Discussion:
On January 20, 2025, the President issued Executive Order (EO) 14159, Protecting the American People
Against Invasion, 90 FR 8443 (Jan. 29, 2025). Specifically, Section 7 of the Executive Order,
Identification of Unregistered Illegal Aliens, directs the Secretary of Homeland Security to take
appropriate action to ensure that all unregistered aliens in the United States comply with the statutory
registration and fingerprinting requirement and to immediately publicize information about the legal
obligations associated with registration. With over 8 million alien encounters nationwide over the past
four years, it is estimated that nearly 2 million aliens were successful in evading detection or capture by
immigration officials, many of whom may pose significant threats to U.S. national security and public
safety. Despite this imminent threat, none of those aliens have been identified nor have they undergone
any vetting by DHS. It is incumbent upon the Department to provide these aliens with a manner in which
they can be identified, counted, and ultimately screened in accordance with the registration requirements
of the INA and to support enforcement of our Nation’s immigration laws. As the United States continues
to take strides in securing the southwest border, DHS requires an immediately available streamlined
process to register and screen aliens, such that USCIS cannot comply with the normal clearance
procedures under the PRA, because, absent the collection of this critical information, public harm is
reasonably likely to result. See 5 CFR 1320.13(a)(2)(i).
Execution of the EO and compliance with the registration and fingerprinting requirement under the INA
and 8 CFR part 264 requires USCIS to create a new collection of information, Form G-325R, Biographic
Information (Registration), for the purpose of allowing previously unregistered aliens to electronically
apply for registration and fingerprinting in the United States. By adding the ability for unregistered aliens
to use the USCIS online account to apply to meet their registration obligations, USCIS should be able to
streamline processing efficiencies for this population to enhance security screening and promptly identify
threats.
We are creating a distinct electronic form specifically for the purpose of allowing for alien registration.
The electronic version, Form G-325R, Biographic Information (Registration), will be used by
unregistered aliens who remain in the United States for 30 days or longer to satisfy their duty to register
pursuant to INA 262. It will also be used by aliens who may have been registered previously by their
parents but who are required to register again and be fingerprinted within 30 days of their fourteenth
birthday. Biographic information about the alien provided on the online Form G-325R will be used to
schedule the alien for biometrics, including fingerprint submission and to allow aliens to comply with
statutory and regulatory registration requirements. Information provided on Form G-325R for biographic
security screening and vetting, and the results of fingerprint checks will be used to ensure national
security and public safety.
USCIS seeks emergency processing to create the Form G-325R in accordance with 5 C.F.R. § 1320.13.
USCIS certifies that the requirements of 5 C.F.R. § 1320.13(a) are met and that:

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It is essential to the mission of the agency; and,
The use of normal clearance procedures will result in public harm, prevent the collection of the
information, and results in aliens missing a statutory requirement for registration.

USCIS requests OMB OIRA approval or disapproval of the collection of information under 5 C.F.R. §
1320.13(b) by February 28, 2025.
Recommendation: DHS recommends the emergency approval of this collection of information under 5
C.F.R. § 1320.13.