On March 12, 2025, the Department of Homeland Security (DHS) released an Interim Final Rule (IFR) titled “Alien Registration Form and Evidence of Registration”. This sweeping mandate requires millions of noncitizens in the U.S. to complete a new registration process, submit to fingerprinting, and always carry proof of registration with them—or risk criminal penalties.
Last week, Ayuda submitted formal comments urging DHS to immediately withdraw this rule. Its implementation will undermine the wellbeing of entire communities.
It Criminalizes Immigrants for Trying to Follow the Rules
This rule is not a simple request to fill out a form. It forces immigrants to navigate an online-only system available only in English, submit deeply personal information, and attend biometric appointments at government facilities. Meanwhile, they must carry proof of registration on them at all times or risk criminal prosecution.
Many of Ayuda’s clients are already engaged in lawful immigration processes. They’ve filed asylum claims, T or U visa petitions, or other forms that already include the personal and biometric information DHS is requesting. Yet unless they’ve received an employment authorization document, a process that can often be significantly delayed, they’re still considered “unregistered” under this rule.
In effect, the rule creates a legal trap—one that immigrants may fall into simply by trying to follow the law.
It Endangers Immigrant Survivors of Violence
Ayuda works daily with survivors of human trafficking, domestic violence, and other crimes—many of whom were victimized here in the U.S. and are now seeking protection. This rule exposes them to new risks.
We’ve already heard from domestic violence survivors who are afraid that their abuser will use the registration process to control or intimidate them—by blocking their access to the form, hiding their documents, or threatening to report them if they don’t comply. For survivors living in shelters or transitional housing, the rule’s vague requirements around addresses could lead to exposure or legal jeopardy.
It Hurts Children and Families
Under the rule, immigrant children as young as 14 are expected to register independently and understand their legal obligations—or face criminal penalties. Many of these kids have experienced trauma, don’t speak English fluently, or are navigating life without a parent or guardian. Some may not know how they entered the U.S., much less how to answer invasive questions about their immigration history.
Parents are also forced into impossible decisions: either register their children under-14 and risk deportation – or leave teenagers to manage the process alone. This does not strengthen families. It puts them in harm’s way.
It Encourages Racial Profiling and Violates Civil Rights
A mandate to carry proof of registration “at all times” is far from neutral. It opens the door to racial profiling, unlawful stops, and civil rights abuses. We are already hearing reports of U.S. citizens—especially those of Hispanic and Native American descent—being wrongfully targeted under this administration’s new enforcement initiatives. This rule will only worsen those patterns, making it more likely that people are stopped, detained, or harassed simply because of how they look or speak.
How You Can Help Us Fight Back
This rule is already causing confusion, fear, and distress. It will result in wrongful deportations, family separations, and the retraumatization of survivors. Per the government’s own calculations, it will impact more than 3 million people. The answer is clear: DHS must withdraw this rule immediately.
Take Action:
- Contact your members of Congress and urge them to speak out against this rule.
- Uplift this message to spread awareness about the harmful impacts of this rule on immigrants and our communities.
To find out more about the registration requirement, refer to this community resource from Immigrant Legal Resource Center (English-only at this time, with a Spanish version to be released soon).
Immigrants deserve dignity, clarity, and safety—not fear and criminalization. Together, we can stand against policies that target our communities and fight for a future rooted in justice, compassion, and humanity.