By Andrea Bodine
Since the beginning of the second Trump administration, there has been growing confusion within the exchange community surrounding recent developments related to the Alien Registration Requirement and their potential implications for exchange participants. While these requirements do not apply to the majority of international students or exchange visitors, and no additional registration is necessary for individuals in these categories, it remains important to understand what they entail. Below is more information on what the Alien Registration Requirement is and to whom it applies.
Background
On Inauguration Day, one of President Trump’s first Executive Orders (EOs) instructed the Department of Homeland Security to enforce Section 262 of the Immigration and Nationality Act (INA), also known as The Alien Registration Act of 1940. This longstanding provision requires all foreign nationals aged 14 and older who reside in the U.S. for more than 30 days to register and be fingerprinted—unless they have already completed this step during their visa application process.
Following this EO, U.S. Citizenship and Immigration Services (USCIS) published a page on their website outlining the details of the Alien Registration Requirement, sharing which individuals must register or re-register with the Federal government and how they can do so. USCIS also published an Interim Final Rule effective April 11, 2025 that requires nonimmigrants who turn 14 while in the U.S. to re-register within 30 days of their birthday, even if they were previously registered and issued an I-94 Form when entering the country.
Impact
These updates have sparked questions about what this means for international students and exchange visitors. The good news? Most won’t be affected—but here’s what you need to know about the Alien Registration Requirement and the new USCIS rule:
Are there any new changes to the Alien Registration Requirement?
Yes, there are two key updates to the Alien Registration Requirement:
- The new requirement for young foreign nationals to re-register once they turn 14 (codified in the Interim Final Rule); and,
- Individuals who have not been registered in the past must now also register with the Federal government, including visa-exempt Canadian nationals who enter at land borders without an I-94 and stay 30+ days and foreign nationals who entered without inspection (EWI) and are in the U.S. 30+ days (i.e. those who crossed the border illegally)
Do international students and exchange visitors need to register under this policy?
No, most nonimmigrants (including F-1s and J-1s) are already registered when they enter the United States. When an individual receives a visa, is inspected at a U.S. port of entry, and receives an I-94 Form, this automatically counts as their registration and will not require them to re-register under this DHS program. Generally, re-registration will not be required if the participant entered the U.S. at age 14 or older and they received an I-91 Form on entry. See “Who is already registered” section on the USCIS Alien Registration Requirement web page.
Will the USCIS Interim Final Rule impact international students and exchange visitors?
This may affect J-2 dependents and any young F-1 and J-1 students who entered the U.S. prior to age 14 (e.g. boarding school students), but in most cases, no.