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On October 27, 2025, the US Department of Homeland Security (DHS) published a final rule requiring aliens to provide their biometric information when entering or exiting the United States. The final rule came into effect on December 26, 2025.
Background
DHS, through US Customs and Border Protection (CBP), has been collecting biometric data (i.e., a digital photograph and a fingerprint scan) from most arriving aliens (not including Canadian citizens) since January 5, 2004. However, there has been no comprehensive system in place to collect biometrics from aliens who are departing from the United States.
Changes implemented by the final rule
The final rule amends the DHS regulations to now require the collection of facial biometrics from all noncitizens upon their entry and exit at airports, land ports, seaports and other authorized points of departure. Prior exemptions, including those for diplomats and Canadian citizens, have now been eliminated. The final rule also removes limitations on pilot programs and expands biometric collection requirements to new methods of transportation, including sea exit, private aircraft, vehicle entry/exit and pedestrian exit.
CBP will be using existing advance passenger information along with photographs, which have already been provided by travelers for the purposes of facilitating their international travel (e.g., visa applications, immigration applications or interactions with CBP during prior border inspections), to create a gallery of facial images. Facial comparison technology will then compare a live photograph of the travelers to the gallery of facial images. If there is a facial image match, the traveler's identity has been verified.
In certain cases, fingerprints may also need to be collected. However, the final rule states that this will only occur as required "to better establish links to previously collected traveler biometric records."
CBP plans to eventually establish a biometric entry-exit system at all air, sea and land ports of entry. It estimates that a biometric entry-exit system can be fully implemented at all commercial airports and seaports for both entry and exit within the next three to five years.
Implications for Canadian citizens
As mentioned above, the previous exemption for Canadian citizens has now been eliminated. As a result, Canadian citizens will be required to provide their biometrics (a digital photo and potentially fingerprints also) when entering the US. They will also be required to provide biometrics when they depart from the US. Of course, it may take three to five years for CBP to fully implement its biometric entry-exit system.
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