CBP Seeks Input on ESTA/I‑94 Updates

Key Point  

• CBP has issued a Federal Register notice seeking public comment on proposed updates to its Arrival/Departure (I‑94, I‑94W) and ESTA information collection under the Paperwork Reduction Act 

CBP Seeks Public Input on Proposed Updates to I‑94 and ESTA Data Collection 

On December 10, 2025, U.S. Customs and Border Protection (CBP) published a notice in the Federal Register announcing proposed revisions to its information collection for the Arrival/Departure Record (Forms I‑94, I‑94W) and the Electronic System for Travel Authorization (ESTA). The agency is conducting this review under the Paperwork Reduction Act (PRA), which requires federal agencies to evaluate the necessity, accuracy and burden of their information collections.

CBP is inviting public comments on whether the collection is essential to its mission, the accuracy of burden estimates, ways to improve clarity and quality and methods to reduce respondent burden through the use of technology.

Key Proposed Changes

The following highlights are drawn from CBP’s Federal Register public inspection notice. This version is currently unpublished and can be found in the inspection file. The official notice is scheduled to be published in the Federal Register on December 10, 2025. Envoy Global will continue monitoring for the formal release and any subsequent updates.

Voluntary Self‑Reported Exit (VSRE) Pilot

• CBP is piloting a new feature in the CBP Home mobile app that allows foreign nationals subject to I‑94 requirements to voluntarily confirm their departure.
• Travelers can submit passport data, a facial image and geolocation.
• CBP will use “liveness detection” software to ensure the photo is live and compare it to existing records.
• Confirmed departures will be recorded in CBP’s Arrival and Departure Information System (ADIS), providing travelers with proof of compliance.

Photo Upload Requirement for ESTA

• CBP plans to update both the ESTA website and mobile app to require a selfie photo in addition to the passport biographical page.
• Third‑party submissions (e.g., travel agents, family members) will also need to include a photo of the applicant.
• This change aligns website and mobile processes and strengthens identity verification.

Mobile‑Only ESTA Applications

• CBP intends to decommission the ESTA website application process, requiring all new applications to be submitted through the ESTA Mobile app.
• The website will remain available for program information and status checks, but not for new submissions.
• CBP cites stronger security features in the mobile app, including NFC passport chip verification, liveness detection and facial recognition.

Mandatory Social Media Disclosure

• To comply with Executive Order 14161 (Jan. 2025), CBP will add social media identifiers from the past five years as a mandatory data element in ESTA applications.

Expanded “High‑Value” Data Fields

• CBP will add several new fields to ESTA applications, when feasible, including:
  • Telephone numbers (last five years)
  • Email addresses (last ten years)
  • IP addresses and photo metadata
  • Family member names, dates/places of birth, residences, and phone numbers
  • Biometrics (face, fingerprint, DNA, iris)
  • Business phone numbers (last five years) and email addresses (last ten years)

Visa Waiver Program Adjustments

• CBP has updated collections to reflect Romania’s removal from the Visa Waiver Program.
• Burden estimates have been adjusted to account for potential new VWP countries over the next three years.

Looking Ahead  

While no immediate changes take effect, these proposals highlight CBP’s shift toward mobile‑first, biometric‑driven vetting. CBP is accepting public comments on these proposals. Envoy Global will continue to monitor developments and provide guidance for business travelers and HR teams navigating evolving border entry requirements.

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