U.S. Biometric Entry/Exit System Takes Effect December 26, 2025

Beginning December 26, 2025, the United States will implement a significant expansion of its Biometric Entry/Exit Program, requiring mandatory biometric collection at both entry and exit points for virtually all non-U.S. citizens traveling to or from the United States. This change represents a major operational shift at U.S. ports of entry and departure and has important implications for travelers, employers, and immigration practitioners.

Who Is Affected

The new biometric requirements apply to all non-U.S. citizens, including:

• Lawful permanent residents (green card holders)

• Nonimmigrant visa holders (e.g., H-1B, L-1, O-1, TN, E-2)

• International students and exchange visitors

• Tourists and business visitors

• Temporary workers and dependents

Previously recognized exemptions have been eliminated. Diplomats, Canadian travelers, and children under the age of 14 will now be subject to biometric collection under the updated system.

What Biometrics Will Be Collected

The primary biometric identifier collected will be facial recognition photographs, taken at airports, land borders, and seaports during entry and exit processing.

The Department of Homeland Security (DHS) has also indicated that the system may incorporate additional biometric identifiers, including Fingerprints; Iris scans; Other biometric modalities as technology evolves.

Data Retention and Privacy Considerations

Under DHS policy, biometric data collected from non-U.S. citizens may be stored in the DHS Biometric Identity Management (IDENT/HART) system for up to 75 years.

This long-term retention raises privacy considerations, particularly for frequent travelers, long-term residents, and individuals with multiple entries and exits over time

Consequences of Refusal

Participation in biometric collection is mandatory for non-U.S. citizens. Travelers who refuse biometric processing may face serious consequences, including:

• Denied boarding by airlines

• Refusal of admission at a U.S. port of entry

• Potential delays or secondary inspection

Compliance is therefore critical to avoid travel disruption.

Practical Takeaways for Travelers and Employers

• Expect expanded biometric screening during international travel beginning December 26, 2025.

• Non-U.S. citizens should plan for additional processing time, especially during peak travel periods.

• Employers with foreign national employees should update travel guidance and advise employees of the new requirements.

• Lawful permanent residents and long-term visa holders should be aware that biometric records will be retained long-term.

How Our Firm Can Help

Changes to border processing and biometric requirements can have real-world consequences for international travel, reentry planning, and immigration status compliance. Our firm assists clients with:

• Travel risk assessments

• Pre-departure planning for visa holders and green card holders

• Addressing entry or exit complications

• Ongoing compliance guidance in light of DHS policy changes

If you have questions about how the new Biometric Entry/Exit System may affect your travel or immigration status, we encourage you to seek legal guidance before traveling.