Emergency Justification Memo

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

DECISION

MEMORANDUM FOR THE ACTING ADMINISTRATOR
TO:

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

THROUGH: R. D. Alles
Deputy Under Secretary for Management
U.S. Department of Homeland Security

RANDOLPH
D ALLES

Digitally signed by
RANDOLPH D ALLES
Date: 2025.03.04
11:10:18 -05'00'

FROM:

Jerry Rigdon
Acting Chief
Regulatory Coordination Division
USCIS Office of Policy and Strategy

SUBJECT:

Request for Emergency Office of Management and Budget Paperwork
Reduction Act Clearance – U.S. Citizenship and Immigration Services Form
G-325R, Biographic Information Registration

JERRY L
RIGDON

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

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.

PRE-DECISIONAL/DELIBERATIVE

PRE-DECISIONAL/DELIBERATIVE

Request for Emergency Office of Management and Budget Paperwork Reduction Act Clearance –
U.S. Citizenship and Immigration Services Form G-325R, Biographic Information Registration
Page 2
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 G325R, Biographic Information (Registration), for the purpose of allowing previously unregistered
aliens to electronically apply for registration and fingerprinting in the United States.
PRE-DECISIONAL/DELIBERATIVE

PRE-DECISIONAL/DELIBERATIVE

Request for Emergency Office of Management and Budget Paperwork Reduction Act Clearance –
U.S. Citizenship and Immigration Services Form G-325R, Biographic Information Registration
Page 3
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:
•
•

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.

PRE-DECISIONAL/DELIBERATIVE

Request for Emergency Office of Management and Budget Paperwork Reduction Act Clearance –
U.S. Citizenship and Immigration Services Form G-325R, Biographic Information Registration
Page 4
Recommendation: DHS recommends the emergency approval of this collection of information under 5
C.F.R. § 1320.13.

Approve/date

Disapprove/date

Modify/date

Needs discussion/date