A U.S. rule opens a path to mandatory online immigration filings, but no form can switch until the Office of Management and Budget (OMB) approves proposed Form I-936 and USCIS names covered applications.
The agency can apply the rule only to forms that have had an electronic filing option for at least 180 days. If USCIS selects a form, it must announce when paper submissions will end at least 60 days in advance. The regulation took effect Aug. 11 but did not designate any form for digital-only filing.
Applicants can already use USCIS accounts to complete a guided application or upload a filled PDF with supporting documents. Both methods were available before the rule took effect.
Proposed Form I-936 would let an individual requestor seek permission to file on paper because of undue hardship. USCIS has invited comments on the proposed information collection through Nov. 30 and plans to submit it to OMB for review afterward; OMB’s approval would not decide individual waiver requests.
The Department of Homeland Security (DHS) says digital records are easier to access and compare, which it expects to help with fraud detection, identity checks and security screening. USCIS also presents fewer filing errors and faster decisions as potential benefits.
DHS cited low voluntary use of online filing in fiscal 2025: about 43% of individual requestors filed digitally when they had the option, compared with fewer than 6% of attorneys and accredited representatives. The agency says the rule also supports reducing reliance on Treasury’s physical lockbox services and the handling and storage of paper requests.
For fiscal years 2027 through 2036, DHS projects about $533 million in annual gross savings for requestors, offset by roughly $15 million in yearly waiver-related costs. That leaves projected net cost savings of about $518 million a year. DHS also anticipates transition costs for some organizations with established paper processes. The next step is the Nov. 30 comment deadline, after which USCIS plans to submit the proposed collection for OMB review.
