On October 12, 2026, the Immigrant Legal Resource Center (ILRC) submitted a comment opposing a new Department of Homeland Security (DHS) interim final rule that would make electronic filing mandatory for immigration benefit applications, along with a proposed form requiring applicants to request a waiver from that requirement.
The rule threatens to create additional barriers for immigrants seeking citizenship and other immigration benefits, particularly people with disabilities, individuals with limited English proficiency, and those without reliable internet access or the technology and digital skills needed to navigate USCIS’s online systems. The ILRC provides that the rule is unlawful because it fails to comply with federal disability protections and the Administrative Procedure Act, while the proposed waiver form imposes additional burdens without adequately accounting for the time, cost, and barriers applicants would face. The ILRC also raises serious concerns about USCIS’s existing electronic filing systems, including technical failures, rejected submissions, and other problems that can jeopardize applicants’ ability to meet deadlines and access benefits.
At a time when naturalization applications are facing declining completion rates, rising denial rates, growing backlogs, and longer processing times, mandating electronic filing could further restrict eligible immigrants’ access to citizenship and other benefits.
The ILRC urges DHS to withdraw the rule and proposed waiver form and ensure that immigration benefit applicants can access a fair, reliable, and accessible application process.