Leaving the U.S.? Expect a CBP Biometric Check

Frequent travelers know that immigration officers check your bags and passport when you enter a country, but there are no such checks when you leave. For passengers leaving the U.S. from now on, that is no longer true.

The Department of Homeland Security (DHS) and U.S. Customs and Border Protection (CBP) have been quietly expanding the use of biometric exit screening to check travelers' identity as they leave the United States.

Recent regulatory changes now give DHS more authority to collect biometric information, including facial scan and fingerprints, from foreign nationals at airports, seaports, and land border crossings.

As this program continues to expand, non-citizens and citizens alike should understand how the system works.

A Long-Planned System

Congress first required the creation of an entry-exit system in 1996 to track the arrival and departure of foreign nationals. The program, called NSEERS, was launched in 2002 and dismantled in 2011 amid concerns about systematic civil rights violations.

Today we have ADIS (Arrival Departure Information System), a centralized database of I-94 entry/exit forms, photographs, and in some cases fingerprints. ADIS was built to check departure logs submitted by air and cruise lines against I-94 records to catch and record visa overstays.

Over time, CBP tested various technologies to collect biometric data at departure, but exit screening was not deployed nationwide. These tests were not publicized and sometimes led travellers to believe they had been deported, when they had simply been screened at departure.

What Changed in 2025?

A DHS final rule that became effective on December 26, 2025, significantly expanded the agency's authority to collect biometric information from foreign nationals entering and departing the United States.

The rule allows DHS to require photographs of all foreign nationals upon entry and departure. It also authorizes the collection of other biometrics in some cases.

How the Biometric Exit Process Works

The new exit screening mosly relies on facial comparison technology.

In general, the process involves:

• Capturing a live photograph of the traveler at the departure gate or inspection point.

• Comparing that image to photographs already maintained in government records, such as passport or visa photographs.

• Verifying the traveler's identity.

• Recording the departure in DHS systems.

According to CBP, the process typically takes only a few seconds and is designed to be largely contact-free.

CBP has already installed facial recognition scanners extensively at U.S. international airports and is continuing to expand its use at seaports and land border locations.

Who May Be Affected?

Under the current regulations, all foreign nationals may be required to provide biometric information when departing the United States. This includes:

• Tourists

• Temporary visa holders

• Lawful permanent residents (green card holders)

Children under 14 must also be screened under the new rule.

Non-citizens (including permanent residents) cannot opt out of facial recognition screening.

Naturalized or native-born U.S. citizens can opt out by telling the CBP officer they are a citizen and that they do not want their photo taken.

Why This Matters

Until recently, for most people, leaving the United States was an immigration-free experience. That is no longer the case.

Most travelers will now look at a camera, receive a successful match, and board their flight without delay.

However, if an alert appears in the system, a CBP officer may need to review a person's documents and ask them questions about their time in the U.S. before allowing the traveler to continue.

This means that departing the United States may no longer be the routine, low-scrutiny experience that many travelers expect.

This does not necessarily mean that CBP will be conducting deportations at U.S. international airports, but it does give them more tools to do so.

Before You Go

If you have ever had immigration or law enforcement issues, you should be aware that leaving the United States may now involve contact with federal government officers who may discover and address those issues.

For example:

• Outstanding orders of removal may result in detention and a formal deportation

• Prior immigration violations, followed by a recorded departure, may lead CBP to deny you entry in the future

• Unresolved criminal matters may lead to arrest

• Identity or documentation concerns may delay travel

Here are some practical steps to take before your next international trip.

• Ensure your passport is valid for at least 6 months beyond your planned return.

• Review your immigration history for any unresolved issues.

• Carry documentation of any prior criminal or immigration matters.

• Allow extra time at the airport if you anticipate any potential complications.

• Consult with an immigration attorney if you have concerns about prior immigration violations, removal orders, or possible grounds of inadmissibility.

  • Do this as far in advance as possible.

  • Government records can take months or years to obtain.

  • Agencies frequently return incomplete responses or say no records exist when we know they do.

  • Responses that do come can number in the hundreds of pages.

Final Thoughts

CBP's biometric exit program represents another step toward a comprehensive entry-exit system that Congress first envisioned decades ago. The technology is intended to help the government verify identities, improve recordkeeping, and strengthen border security.

For most travelers, the process will likely be quick and uneventful. However, non-citizens should understand that departing the United States increasingly involves an immigration inspection process, and issues that might previously have gone unnoticed may now come to the government's attention before departure.

Sources

• DHS Final Rule, Collection of Biometric Data From Aliens Upon Entry to and Departure From the United States (effective Dec. 26, 2025).

• U.S. Customs and Border Protection, DHS Announces Final Rule to Advance the Biometric Entry/Exit Program.

• U.S. Customs and Border Protection, Biometrics: Environments.

This article is for general informational purposes only and should not be interpreted as legal advice.