USCIS Policy
USCIS Biometrics Update: September 2025
Real-world insights from recent cases. Learn what worked and how to apply these lessons.
Biometrics in the USCIS adjudication process
Biometrics collection — fingerprints, photographs, and signature — is a mandatory component of many USCIS benefit applications and serves multiple law enforcement and identity verification functions. USCIS uses biometrics to conduct background checks through FBI criminal history databases, to verify identity by comparing submitted biometrics against biometrics collected in prior immigration proceedings, and to issue documents such as green cards and employment authorization documents that incorporate biometric identifiers. The scope of biometrics requirements varies by application type: some applications require biometrics collection as a condition of adjudication, while others proceed without biometrics because the applicant's identity can be verified through other means or because applicable regulations do not require collection.
For O-1 petition applicants specifically, the biometrics requirement applies primarily to collateral applications rather than to the O-1 petition itself. The I-129 O-1 petition filed by the employer or agent is adjudicated without a biometrics appointment for the beneficiary, because nonimmigrant petition adjudication does not typically require biometrics collection from the beneficiary before the petition is decided. Biometrics become relevant for O-1 beneficiaries primarily when they or their dependents file applications associated with the O-1 status — such as Form I-539 applications to extend O-3 dependent status, Form I-765 employment authorization applications, or Form I-485 adjustment of status applications — each of which may trigger a biometrics appointment notice requiring appearance at an Application Support Center.
USCIS Application Support Centers are the facilities at which biometrics collection occurs for domestic applicants. Applicants who receive a biometrics appointment notice must appear at the designated ASC at the scheduled time to have their fingerprints, photograph, and signature collected by USCIS personnel. The biometrics appointment notice specifies the ASC location, the date and time of the appointment, and the documents the applicant must bring — typically the appointment notice itself and a government-issued photo identification. Failure to appear for a scheduled biometrics appointment results in the automatic suspension of action on the associated application until the applicant reschedules, which introduces delays into the adjudication timeline.
September 2025 biometrics developments for immigration applicants
USCIS has continued expanding its online self-scheduling system for biometrics appointments through 2025, allowing applicants to select appointment times directly through the USCIS online account system rather than waiting for USCIS to assign an appointment date. The self-scheduling system reduces the uncertainty associated with waiting for a USCIS-assigned appointment date, which historically varied from several weeks to several months depending on ASC capacity in the applicant's geographic area. Applicants with O-1 dependent (O-3) status who need to extend their status through Form I-539 or apply for employment authorization through Form I-765 can use the online system to schedule their biometrics appointments at a time that fits their schedule and minimizes delay in the associated application.
USCIS has also expanded the circumstances under which biometrics may be collected remotely or waived for specific applicant categories. Applicants who have appeared at an ASC and submitted biometrics within a defined recent period may be eligible to have those biometrics reused for new applications without a new appointment, a process USCIS refers to as biometrics reuse. This is particularly relevant for O-1 beneficiaries who file successive applications within a short period — for example, an O-1 beneficiary who files both an I-539 for a dependent and an I-485 for themselves within the same year may find that USCIS can reuse biometrics collected at the first appointment for the second application, eliminating the need for a second ASC visit. Applicants should monitor their USCIS online account for notifications about whether reuse applies to their specific situation.
For applicants who are unable to travel to an ASC because of physical incapacity or other documented circumstances, USCIS maintains procedures for mobile biometrics collection and for biometrics waivers in hardship cases. These provisions are narrow and require specific documented circumstances — they are not available simply because an applicant finds scheduling an ASC visit inconvenient. O-1 beneficiaries or their dependents who face genuine medical or physical obstacles to ASC attendance should consult immigration counsel about the applicable waiver or accommodation procedures, including Form I-539A supplemental applications and supporting medical documentation, before the biometrics appointment deadline passes. Missed biometrics deadlines without prior notification to USCIS typically result in automatic suspension of the associated application.
How biometrics requirements affect O-1 applicants
The timing of biometrics appointments can materially affect the timeline for O-1-related applications, particularly adjustment of status applications filed by O-1 beneficiaries seeking to change to lawful permanent resident status. Form I-485 adjustment of status requires biometrics collection before USCIS will schedule the adjustment interview or issue an approval, and the wait between application filing and biometrics appointment adds to the overall adjustment timeline. In geographic areas with high application volumes and limited ASC capacity — major metropolitan areas with large immigrant populations — biometrics appointment wait times can extend the overall I-485 processing timeline by several months. Applicants who file I-485 concurrently with I-130 or I-140 petitions should factor expected biometrics wait times into their timeline projections.
O-3 dependent visa holders who wish to extend their status or change to a different nonimmigrant status using Form I-539 face biometrics requirements that create their own timeline considerations. The I-539 adjudication process does not begin substantive review until biometrics have been collected, meaning that a delayed biometrics appointment delays the entire adjudication timeline. O-3 dependents whose status is expiring should file Form I-539 well in advance of the expiration date to ensure that biometrics can be collected and the application adjudicated before the dependent's authorized stay expires. Filing in the final weeks before the status expiration date creates a significant risk that the biometrics appointment will not occur until after the expiration date, placing the dependent in an overstay situation that complicates future visa and immigration applications.
O-1 beneficiaries who concurrently file Form I-765 applications for employment authorization in anticipation of an adjustment of status application should also account for biometrics in their timeline planning. USCIS generally consolidates biometrics appointments for concurrent applications where possible, but applicants who file applications separately at different times may receive separate biometrics appointment notices for each application. Maintaining awareness of outstanding application-specific biometrics requirements through the USCIS online account system and ensuring that all scheduled appointments are honored on time is the most reliable way to avoid biometrics-related delays across multiple concurrent applications.
Remote biometrics collection and waiver procedures
USCIS has piloted remote biometrics collection programs that use mobile units or partner facilities to collect biometrics from applicants in geographic areas without nearby ASC locations, or from applicants who face documented access challenges. These programs are available in specific geographic areas and for specific applicant populations identified through USCIS's operational planning process. O-1 applicants and their dependents who live in rural areas or in regions where the nearest ASC is several hours distant should monitor USCIS announcements about mobile biometrics events and self-service collection options that may reduce the travel burden associated with biometrics compliance.
Biometrics waiver procedures are available for specific categories of applicants where biometrics collection is not required by statute, where prior biometrics are sufficient for the background check purposes of the new application, or where a documented hardship makes ASC attendance genuinely impracticable. The waiver request process requires a specific written request submitted with the affected application, supported by documentation of the basis for the waiver request. General inconvenience, scheduling difficulty, or the cost of travel to an ASC does not constitute a basis for a biometrics waiver — the waiver procedures exist for genuine access barriers, not as a convenience option. Applicants who submit waiver requests that do not meet the applicable standards risk having the waiver request denied and the application suspended pending biometrics completion, which creates a longer delay than simply scheduling and attending the appointment.
For O-1 beneficiaries who are abroad when a biometrics appointment notice is issued — for example, those performing international engagements during the adjudication period — USCIS does not maintain the same biometrics appointment scheduling flexibility as for domestic applicants. An applicant outside the United States who receives a domestic biometrics appointment notice should contact USCIS through the available inquiry channels to notify USCIS of their abroad status and request guidance on rescheduling. Practitioners advising O-1 beneficiaries with pending applications should flag the possibility of abroad-while-pending scenarios during the application planning stage, particularly for performing arts professionals whose work patterns involve extended international travel, and should ensure that the client understands the obligation to comply with biometrics appointment requirements within the specified timeframe.
Change of status applications and biometrics timing
O-1 change of status applications — where the beneficiary is already in the United States on another nonimmigrant visa and files with USCIS to change to O-1 status rather than obtaining an O-1 visa through consular processing — do not typically require biometrics collection from the I-129 beneficiary as part of the petition adjudication. The I-129 petition adjudication itself, whether filed as an initial petition or as a change of status petition, does not require the beneficiary to appear at an ASC. Biometrics requirements arise only when the beneficiary or a dependent files a separate benefit application that specifically triggers biometrics collection under the applicable regulations.
Where an O-1 beneficiary changes status and later files for adjustment of status to lawful permanent residence, the adjustment of status application (Form I-485) will require biometrics collection at an ASC. This is a distinct step in the adjustment process that occurs separately from the I-130 or I-140 underlying petition adjudication. Beneficiaries who are planning to file for adjustment of status after achieving O-1 status should factor biometrics appointment wait times into their adjustment timeline projections. In high-volume field offices, the gap between I-485 filing and the first biometrics appointment has ranged from several weeks to several months, depending on local ASC scheduling capacity.
The fee associated with biometrics collection is governed by 8 C.F.R. § 103.7 and the associated USCIS fee schedule, which is updated periodically. Some application fee schedules incorporate biometrics fees into the overall application fee, while others list biometrics fees separately. Applicants filing multiple applications concurrently — for example, an I-485 and an I-765 together — should review the applicable fee schedule for each form to determine whether a combined biometrics fee or separate biometrics fees apply. Incorrect fee payment, including underpayment of biometrics fees, results in automatic rejection of the associated application without adjudication, which requires refiling and extends the overall processing timeline. Practitioners should verify current fee schedules at the time of filing rather than relying on fee information from prior filings that may have been superseded.
Practical guidance for September 2025 filers
O-1 beneficiaries and dependents with pending or anticipated applications that involve biometrics requirements should take proactive steps to minimize biometrics-related delays. First, ensure that any pending USCIS online account is active and that address information is current, so that biometrics appointment notices are received promptly. Notices that are mailed to outdated addresses may be considered received even if the applicant did not actually receive them, and failure to appear for a scheduled appointment — even one the applicant was unaware of — results in automatic suspension of the associated application. Second, schedule biometrics appointments as early as possible within the self-scheduling system, choosing appointment times that are consistent with the applicant's availability rather than waiting until the latest permitted date.
Practitioners advising O-1 beneficiaries with complex concurrent application portfolios — multiple overlapping applications at different stages of adjudication — should maintain a tracking system that identifies which applications have pending biometrics requirements, when biometrics appointments are scheduled, and whether USCIS has confirmed biometrics completion for each application. The USCIS online account system provides status updates on associated applications that may indicate whether biometrics have been received and processed, but these status updates are not always updated in real time. Practitioners should advise clients to retain their ASC appointment attendance receipt as documentation that biometrics were collected on the scheduled date, in the event that USCIS's records do not reflect the collection promptly.
For O-1 petitions and related applications filed in September 2025, practitioners should advise clients that biometrics delays are a predictable component of the processing timeline for applications requiring ASC visits and should build those delays into the overall timeline projection. Applications that proceed to biometrics promptly and without complications are adjudicated on the standard timeline; applications where biometrics are delayed — because of scheduling issues, rescheduling, or missed appointments — take longer regardless of the underlying petition's strength. Managing the procedural logistics of biometrics compliance efficiently is a low-cost, high-return element of overall application management that practitioners and applicants should treat with the same attention given to the substantive evidentiary record.