The Immigrant Legal Resource Center (ILRC) submitted a comment strongly opposing the Department of Homeland Security’s Final Rule on “[Immigrant] Registration Form and Evidence of Registration.” The rule expands and formalizes a registration process that could expose millions of immigrants—and potentially U.S. citizens—to increased fear, confusion, racial profiling, and immigration enforcement.
In its comment, the ILRC provides that the Final Rule violates the Administrative Procedure Act and Paperwork Reduction Act, including by failing to provide meaningful notice and opportunity for public comment. The rule and accompanying Form G-325R are also vague, contradictory, and lacking in adequate instructions, creating serious risks for individuals who could face civil or criminal penalties for noncompliance.
The ILRC further warns that registration systems have a long history of enabling discrimination and government abuses. The current registration process threatens to similarly harm immigrant communities, particularly children, people with limited English proficiency or access to technology, people with disabilities, and survivors of domestic violence, crime, and human trafficking.
The ILRC urges DHS to rescind the Final Rule in its entirety and eliminate the registration requirement.