CBP Proposes Major Changes to Form I-94 and ESTA: Social Media, Biometrics, and Mobile-Only Applications

Overview

On December 10, 2025, U.S. Customs and Border Protection (CBP) published a 60-day notice in the Federal Register (Document 2025-22461) requesting public comments on proposed revisions to the Form I-94 Arrival and Departure Record and the Electronic System for Travel Authorization (ESTA). The comment period closes on February 9, 2026.

These proposed changes would significantly affect how international travelers enter and exit the United States, particularly citizens of Visa Waiver Program (VWP) countries who use ESTA to travel to the U.S. without a visa.

What Is Form I-94?

Form I-94 is the official Arrival/Departure Record issued to foreign visitors entering the United States. It documents the traveler's immigration status, including the date of entry and the authorized period of stay. Since 2013, most I-94 records are generated electronically at ports of entry, replacing the paper form that travelers once filled out on airplanes.

Every non-U.S. citizen admitted to the country receives an I-94 record, making it one of the most important documents in the U.S. immigration system.

What Is ESTA?

The Electronic System for Travel Authorization (ESTA) is a web-based system used by citizens of the 41 countries in the Visa Waiver Program. ESTA determines whether travelers are eligible to visit the United States for up to 90 days without obtaining a visa. An approved ESTA is valid for two years or until the traveler's passport expires.

Key Proposed Changes

1. Mandatory Social Media Disclosure

To comply with Executive Order 14161 (signed January 2025), CBP is proposing to make social media account information a mandatory field on the ESTA application. Applicants would need to provide all social media identifiers used in the last five years. This requirement was previously optional and is now being elevated to mandatory status.

2. Expanded Biometric and Personal Data Collection

CBP plans to add several "high value data fields" to the ESTA application, including:

  • Telephone numbers used in the last 5 years
  • Email addresses used in the last 10 years
  • Family member details (names, dates of birth, places of birth, residences, and phone numbers)
  • Business contact information
  • IP addresses and photo metadata
  • Biometric data including facial scans, fingerprints, DNA, and iris data (when feasible)

3. Photo Submission Requirements

ESTA applicants would be required to upload a facial photograph (selfie) along with a photo of their passport biographical page. This requirement applies to both direct applicants and those submitted by third parties such as travel agents or family members.

4. Mobile-Only ESTA Applications

Perhaps the most impactful operational change: CBP plans to decommission the ESTA website for new applications. All new ESTA applications would need to be submitted through the ESTA Mobile app. The website would remain available only for checking application status and accessing VWP information. CBP cites stronger mobile security features, including NFC passport verification and facial recognition capabilities, as justification for this shift.

5. Voluntary Self-Reported Exit (VSRE) Pilot

A new pilot program would allow travelers to voluntarily confirm their departure from the United States through the CBP mobile app. Participants would submit passport data, a facial image, and geolocation information. The system uses liveness detection software to verify that the photo represents a living person present at the time of submission.

6. Romania Removed from VWP

The notice also reflects Romania's removal from the Visa Waiver Program. Romanian citizens will no longer be eligible for ESTA and will need to apply for a B-1/B-2 visa through a U.S. embassy or consulate before traveling to the United States.

How This Affects Travelers

If implemented, these changes would affect millions of international travelers each year:

  • VWP travelers would need to download and use the ESTA Mobile app, provide significantly more personal information, and submit biometric data
  • All visitors using Form I-94 could be subject to enhanced data collection at ports of entry
  • Romanian citizens would need to visit a U.S. embassy or consulate to obtain a visa, rather than using ESTA
  • Frequent travelers may benefit from the voluntary departure confirmation system, which could streamline their exit records

Public Comment Period

The public has until February 9, 2026 to submit comments on these proposed changes. Comments should reference OMB Control Number 1651-0111 and can be submitted through the Federal Register. The contact person for questions is Seth Renkema, Chief of the Economic Impact Analysis Branch at CBP.

What Happens Next

After the comment period closes, CBP will review all submissions and may modify the proposals before final implementation. The timeline for when these changes would take effect has not been specified, but travelers should monitor CBP announcements for updates.