In a 9 July "Practice Alert," the American Immigration Lawyers Association reports that USCIS has issued internal guidance on when officers may reuse previously captured photographs instead of requiring new biometrics for adjustment-of-status and DACA renewals. The policy—quietly posted on 12 December 2026 but only now explained—states that photos taken more than 12 months ago, or images that lack required resolution, cannot be recycled. For corporate transferees applying for green cards, the clarification is important. Applicants who completed fingerprints abroad for a non-immigrant visa and then file I-485s in the United States often assume no new biometrics appointment will be needed. The updated standard means many will still receive ASC notices, which can complicate business travel if the appointment conflicts with international meetings. On the positive side, cases that do qualify for photo reuse should see marginally shorter processing times because ASC capacity is no longer a bottleneck. Employers should adjust timelines: anticipate roughly four additional weeks if new biometrics are required. Attorneys also warn that foreign nationals should not depart the U.S. after filing but before attending an ASC appointment unless they have valid advance parole or a dual-intent status. Practitioners welcomed the transparency but urged USCIS to publish the criteria publicly rather than through liaison minutes. Until then, HR teams should budget for possible travel to ASC sites and communicate contingencies to assignees.
Source: AILA Practice Alert
