NumbersUSA’s public comment on biometrics rule for immigration benefits

December 31, 2025

U.S. Citizenship and Immigration Services
U.S. Department of Homeland Security
5900 Capital Gateway Drive
Camp Springs, MD 20746

RE: DHS Docket No. USCIS-2025-0205
Collection and Use of Biometrics by U.S. Citizenship and Immigration Services

NumbersUSA welcomes U.S. Citizenship and Immigration Services’ (USCIS) Notice of Proposed
Rulemaking (NPRM) related to the collection and use of biometrics, and submits the following
comment for consideration as the agency seeks to finalize the rule.

Founded in 1996, NumbersUSA is a nonpartisan, nonprofit organization that believes better
immigration policy is possible and needed. As America’s largest single-issue advocacy group,
NumbersUSA is focused exclusively on immigration reform. NumbersUSA empowers over 8 million
grassroots supporters spread across every congressional district to impact immigration policy with
information, tools, access, and influence. We advocate for sensible immigration policies that put
Americans first, and a system that prioritizes security and economic fairness while protecting the
environment and quality of life.

Since taking office, President Trump has been committed to securing our borders and
protecting the homeland, and has repeatedly stated that his administration’s top priority is
ensuring the safety and security of the American people. Hundreds of thousands of foreign
nationals are granted asylum each year to our country, more than one million people are
granted green cards, and more than 14 million people applied for nonimmigrant visas. Whether
they are visitors, students, workers, family members, or investors, foreign nationals must be
thoroughly screened and vetted in order to mitigate risks, detect fraud, and keep Americans
safe. That is why USCIS’ rule to enhance biometrics collection is so important.

We understand that USCIS’ proposal would require the submission of biometrics by any
individual, regardless of age, filing or associated with an immigration benefit request, other
request, or collection of information, unless exempted. As stated in the rule, the number of
immigration applicants/petitioners submitting biometrics today is about 21% of the total
volume of applications/petitions. And, on average, only 2.07 million of the people who request
benefits annually from USCIS submitted biometrics (and it was less than 2 million collections in
fiscal year 2022).

We agree that the U.S. should require more foreign nationals to submit biometrics so we know
the person’s identity and background, including criminal history. We agree that the U.S. should
not restrict the collection of biometrics based on age, making all persons subject to submitting
biometrics. The current policy of only subjecting individuals between the ages of 14 and 79 is
flawed and does not serve our national interest. This provision alone will greatly deter
immigration fraud, detect identity theft, and enhance the integrity of our immigration system.

We also understand the proposed rule will modernize and expand the modalities used,
including by allowing the agency to use newer technologies, such as DNA, iris scans, face
recognition and voice recognition. We urge the department to consider expanding authority to
use emerging technologies as they become available. We agree, as noted in the rule, that “DHS
needs to keep up with technological developments that will be used by the FBI and agencies
with which [it] will be sharing and comparing biometrics and adjust collection and retention
practices for both convenience and security, and to ensure the maximum level of service for all
stakeholders.” Further, we agree that the collection of certain biometrics, such as DNA, will
assist in verifying genetic relationships, thus protecting children who are vulnerable to
trafficking and exploitation.

Finally, we understand the proposed rule will expand biometrics collection authority upon an
alien’s arrest, and that this rule will go a long way to preventing criminals from obtaining
immigration benefits. As noted in the proposed rule, “Biometrics collection upon apprehension,
arrest, or encounter by DHS will allow DHS in subsequent encounters or filings to accurately
identify the individuals encountered, and can prove or disprove any claimed, or unclaimed,
genetic relationship.” We agree that this will provide more reliable data about their identities
and allow DHS to make better informed decisions.

Given the national security and public safety risks our nation faces, we strongly urge USCIS to
finalize this regulation to expand and enhance the biometrics collection of those who seek
immigration benefits. We should be utilizing every biometric tool available that can verify one’s
identity and prevent criminals and imposters from obtaining immigration benefits. We should
do more to prevent human trafficking and protect children who are at risk of being exploited.

The American people want our laws enforced and want an immigration system that prioritizes
integrity and accountability. DHS must carry out its responsibilities and faithfully enforce our
immigration laws. We urge DHS to finalize the rule without watering down the proposed
regulatory amendments.