USCIS Policy
USCIS Biometrics Update: May 2025
Real-world insights from recent cases. Learn what worked and how to apply these lessons.
How biometrics fit into the O-1 immigration process
Biometric collection — fingerprinting, photographs, and signature collection — is a component of many immigration applications processed by USCIS, but its relevance varies significantly depending on the specific benefit being sought and the applicant's current immigration status. For O-1 nonimmigrant petitions filed by an employer or agent on behalf of a beneficiary who is outside the United States, USCIS does not collect biometrics as part of the I-129 adjudication. Biometric collection for O-1 beneficiaries who are outside the U.S. occurs during consular processing at the U.S. embassy or consulate, where fingerprints and photographs are taken as part of the visa issuance process.
Biometric collection by USCIS becomes relevant when an O-1 beneficiary in the United States files for adjustment of status — the process of changing from a nonimmigrant status to lawful permanent resident status. The Form I-485 adjustment of status application includes a biometric services requirement, and USCIS schedules applicants for biometric appointments at Application Support Centers (ASCs) following receipt of the I-485. The biometric appointment results in the collection of the applicant's fingerprints, which are submitted to the FBI for background check processing as part of the adjustment of status adjudication. The adjustment of status process for O-1 beneficiaries who qualify for employment-based immigrant categories follows the same biometric requirements as any other I-485 applicant.
Some USCIS applications that O-1 holders commonly file during their nonimmigrant period — such as applications for employment authorization for derivative family members — also require biometrics. An O-1 beneficiary's accompanying O-3 dependent family members who file for employment authorization may be subject to biometric collection depending on the specific application type. Practitioners advising O-1 holders should review the biometric requirements for each specific application type when advising on the overall immigration strategy, rather than applying a blanket assumption about when biometrics will or will not be required.
Biometric appointment logistics for immigration applicants
USCIS schedules biometric appointments at Application Support Centers, which are located in major metropolitan areas across the United States. After an application requiring biometrics is filed and receipt is confirmed, USCIS mails a biometric appointment notice to the address on file, typically within several weeks of the initial receipt. The notice specifies the assigned ASC location, date, and time, and instructs the applicant to bring the notice, a valid government-issued photo ID, and any other documents specified on the notice. Applicants who need to reschedule the assigned appointment can do so by contacting USCIS, though rescheduling may delay the overall adjudication timeline.
The biometric collection process at an ASC typically takes less than 30 minutes. The applicant's fingerprints are captured using an electronic fingerprint scanner, a photograph is taken, and a signature is collected. The collected biometrics are transmitted electronically to the FBI for background check processing. The FBI's response to the background check request is incorporated into the USCIS adjudication; if the background check reveals information that requires additional review, the adjudication may be placed in a hold status pending resolution. USCIS does not routinely disclose to applicants the specific status of FBI background check processing, which can make it difficult to diagnose cases that have been delayed by background check processing issues.
Applicants who are unable to attend the scheduled biometric appointment — due to illness, travel, or scheduling conflicts — should contact USCIS before the appointment date to reschedule. Failure to appear at a scheduled biometric appointment without rescheduling may be treated as abandonment of the application, which can result in the application being denied. For adjustment of status applicants whose underlying nonimmigrant status is time-limited, any delay in the adjudication timeline — including delays caused by biometric rescheduling — should be assessed against the underlying status expiration to ensure that the applicant remains in authorized stay throughout the adjustment of status process.
Recent USCIS updates to biometric requirements
USCIS has implemented several updates to its biometric collection procedures in recent years, reflecting both operational improvements and security policy changes. The agency has expanded the use of reusable biometrics — a program under which previously collected fingerprints are reused for subsequent applications where the applicant's biometric record already exists in USCIS systems and the record is not outdated. Under the reusable biometrics program, some applicants receive a notice that their biometric appointment has been waived for a specific application because USCIS will use their previously collected biometrics rather than scheduling a new appointment. This waiver reduces the administrative burden on applicants with active USCIS files but does not apply universally.
The biometric fee structure for USCIS applications has been subject to revision as USCIS has updated its fee schedule. The biometric services fee, when separately charged, covers the cost of collecting and processing the biometric data. Recent USCIS fee rule updates have integrated some previously separate biometric fees into the overall application fee for certain application types, while retaining separate biometric fees for others. Practitioners advising clients on USCIS filing fees should verify the current fee schedule for each specific application type at the time of filing, as fee structures have changed and may continue to change as USCIS revises its fee rules.
USCIS has also updated its procedures for handling biometric collection for applicants with physical conditions that make standard fingerprint collection difficult or impossible. Applicants who are unable to provide acceptable fingerprints due to medical conditions or physical characteristics may be exempted from the fingerprint requirement or may be asked to provide alternative biometric identifiers. The process for requesting a biometric exemption involves documentation from a medical professional and submission to the relevant ASC. Practitioners advising applicants with biometric collection challenges should address this issue early in the application process and obtain appropriate medical documentation before the biometric appointment is scheduled.
Biometrics and adjustment of status for O-1 holders
O-1 beneficiaries who are eligible for employment-based adjustment of status — because they have an approved immigrant petition and a priority date that is current in the relevant category — file Form I-485 concurrently with or following the approval of the immigrant petition. The I-485 triggers the biometric appointment requirement, and the applicant's fingerprints are submitted for FBI background check processing as part of the adjudication. For O-1A holders with EB-1A extraordinary ability or EB-1B outstanding researcher and professor petitions — categories where no labor certification is required and the priority date is often immediately current — the adjustment of status process can proceed relatively efficiently if the biometric and background check stages do not generate holds.
The interaction between O-1 nonimmigrant status and the adjustment of status process requires careful planning when the O-1 period is approaching expiration. An applicant who has filed an I-485 and whose O-1 status expires during the pendency of the I-485 adjudication is generally protected by the tolling provision under INA § 245(k) if the I-485 was timely filed. However, the applicant's employment authorization during the gap between O-1 expiration and I-485 approval depends on whether the applicant has a pending employment authorization document (EAD) application filed concurrently with the I-485. Practitioners advising O-1 holders on adjustment of status planning should assess the O-1 expiration timeline, the expected I-485 adjudication timeline, and the EAD timeline to ensure continuous employment authorization.
Biometric hold issues — situations where the FBI background check processing takes significantly longer than expected — can extend the I-485 adjudication timeline substantially beyond USCIS's published processing goals. USCIS's published processing times for I-485 adjudication reflect median processing times and do not account for cases held pending resolution of background check issues. Applicants who have been waiting significantly longer than published processing times should consider submitting service requests through official USCIS channels to inquire about the status of the adjudication. If the delay appears attributable to background check processing rather than to USCIS adjudication backlogs, practitioners may advise clients that the delay is outside USCIS's direct control and may require additional patience.
Planning around biometrics in comprehensive O-1 cases
Practitioners advising O-1 clients on comprehensive immigration strategies should build biometric appointment requirements into the overall timeline planning for any application that involves biometric collection. For adjustment of status cases, the biometric appointment typically occurs within 6 to 8 weeks of the I-485 filing, and the subsequent background check processing adds additional time before the advance parole and employment authorization documents can be issued. Clients who need travel authorization — advance parole — should be advised that the advance parole document will not be issued until after the biometric appointment has been completed and the biometric data processed.
Derivative family members — O-3 dependents of O-1 holders — have their own immigration applications with their own biometric requirements when those applications involve USCIS processing. If derivative family members file adjustment of status concurrently with the principal O-1 holder, each family member's I-485 generates a separate biometric appointment, and the family members may be scheduled at different ASC locations or on different dates depending on USCIS's scheduling practices. Practitioners advising O-1 holder families should account for the multiple biometric appointment requirements when advising on the adjustment of status filing timeline.
Cases involving applicants with prior biometric records from earlier USCIS applications may benefit from the reusable biometrics program but should not assume that the waiver will be granted in any specific case. USCIS's determination of whether previously collected biometrics are reusable depends on the age of the prior collection and the quality of the biometric data on file. Practitioners should advise clients that the biometric appointment notice they receive will indicate whether biometrics have been waived or whether a new appointment is required; clients should not assume a waiver has been granted simply because they have provided biometrics to USCIS in connection with a prior application.
USCIS operational updates affecting biometric processing in 2025
USCIS has been implementing operational changes to its Application Support Center network that may affect biometric appointment availability and scheduling in specific locations. Closure or consolidation of ASC locations in some markets has reduced appointment availability, which can extend the time between I-485 filing and biometric appointment completion in affected areas. Practitioners advising adjustment of status clients in markets with limited ASC availability should account for potential biometric appointment delays when estimating the overall adjudication timeline and advising clients on travel planning and employment authorization needs.
The agency's continued investment in electronic filing systems has extended to some biometric-adjacent processes. USCIS's online case management tools provide applicants with case status information, including confirmation of biometric appointment scheduling and processing, that reduces the need for direct USCIS contact to obtain status updates. Practitioners should advise clients to create USCIS online accounts and link their pending cases to receive automated status updates, which can provide earlier notice of biometric appointment scheduling and other case milestones than waiting for mailed correspondence. Electronic filing of applications where available also tends to produce faster initial receipt and faster biometric scheduling than paper filing.
Background check processing times at the FBI have fluctuated with workload and operational capacity, and extended background check holds are not uncommon for applicants from certain countries or with certain name patterns that require additional review. USCIS does not disclose the specific reasons for extended background check delays, and practitioners are generally limited in their ability to accelerate background check processing through USCIS inquiries. The most practical advice for adjustment of status clients facing extended biometric holds is to maintain valid O-1 status or valid EAD coverage throughout the pending period, avoid international travel without valid advance parole, and document the pending I-485 status in any employment or financial contexts where continued work authorization must be demonstrated.