USCIS moves toward modernized fee payments—but e-filing still lags behind

The U.S. Citizenship and Immigration Services (USCIS) has announced a major procedural shift: paper checks and money orders will no longer generally be acceptable for paying filing fees, effective October 2025. Instead, most fees must now be paid electronically unless a rare exemption applies.

This move reflects USCIS’s broader push to modernize and streamline its services—an effort long called for by attorneys, advocates, and applicants alike. For immigration lawyers, the new rule is more than an administrative tweak. It changes how firms manage client payments, forces a rethinking of data security, and highlights how far USCIS still has to go to provide true end-to-end digital filing.

This post explains the new rule in depth, explores its benefits and challenges, and outlines what law firms should know about exemptions, emergency payments, and fee waivers.

What the new USCIS filing fee rule does

The core of the rule is simple but sweeping: USCIS will no longer routinely accept paper checks and money orders for filing fees. Instead, all payments must be made electronically, either by ACH debit or credit/debit card. Applicants can use Form G-1450 to authorize a credit or debit card charge or the newly introduced  Form G-1650 to authorize an ACH debit from a U.S. bank account when submitting filings by mail, with paper payments allowed only under narrowly granted exemptions.

Previously, the default method for many applications was to include a check or money order with a paper filing package. That practice is now essentially over. Going forward, unless you secure a formal exemption, any paper-based payment method will be rejected.

For the agency, the change means:

• Less manual processing of paper checks and money orders.

• Fewer payment errors and mismatches between applications and fees.

• Faster deposit of funds into USCIS accounts, improving cash flow.

For law firms and applicants, it means rethinking long-standing workflows built around assembling paper filings with attached checks.

Modernizing one piece of the process

This shift represents progress, but it also underscores how piecemeal USCIS’s modernization has been. The agency has been talking about “end-to-end digital filing” for years. Yet, as of now, many high-volume forms still cannot be filed online.

The e-filing gap

While payments are moving into the 21st century, e-filing remains incomplete. For example:

• Some family-based applications and humanitarian forms can be filed online, but many employment-based petitions still require paper.

• For many types of cases, attorneys will still need to mail physical application packets while paying fees electronically by authorizing a credit card charge or ACH debit.

• There is no universal dashboard for tracking all cases across form types.  Online-filed cases are tracked through myUSCIS, while mail-filed cases are tracked through the separate “Case Status Online” tool using receipt numbers.

This hybrid environment creates friction. It can be confusing for clients, duplicative for firms, and inefficient for USCIS. Without simultaneous modernization of form submission, the payment rule is still a half-measure rather than a full transformation.

The upsides and tradeoffs for attorneys and clients

Benefits

• Efficiency: Electronic payments post instantly or within hours, reducing delays caused by mailing and check clearing.

• Reduced mail loss: No more worries about checks lost in transit or separated from application files.

• Immediate confirmation: Electronic payment allows faster proof of payment for records and audits.

Drawbacks

• Security demands: Firms now must send an authorization for a credit or ACH charge via the postal mail, which introduces security concerns and the need for staff training.

• Complex hybrid processes: When forms must be mailed but fees paid via credit card or ACH, staff must ensure the correct linkage of payments to applications since there will be no correlation of check number to case or check image.

• Accessibility concerns: Some applicants — especially in rural areas, low-income households, or older age groups — may not have easy access to credit cards or online banking.  This is less of an issue for law firms but is a drawback for unrepresented applicants.

Data security concerns for law firms

For immigration practitioners, this rule isn’t just an operational change; it’s a data security challenge.

Previously, firms would either pay fees with a check drawn on a firm account or else ask clients to provide checks drawn from their own bank accounts or a money order. The firm’s responsibility for sensitive data was limited. Now, if firms want to have the option of using the client’s card or bank account, firms might need to collect bank routing numbers or credit card details to process payments electronically on behalf of clients.

Most immigration law firms will be reluctant to use clients’ bank account information on Form G-1650 or clients’ credit card details on Form G-1450 because of the practical and ethical risks involved. Chief among these is the danger of a client having insufficient funds at the time of the ACH withdrawal or card charge, which could result in a rejected payment and delayed filing. The other major consideration is the risk of liability when handling the client’s payment details. As a result, most firms will prefer to use the firm’s own credit card to cover USCIS filing fees and then reconcile the charge with the client later.

However, putting the firm’s main credit card details on a form that is physically mailed to USCIS is not secure and increases the risk of fraud or misuse. In addition, firms need a way to match each electronic payment to the related case for accurate billing and trust accounting. A better approach is to use virtual credit cards that are tied to a specific client matter. Each virtual card could carry the client or case identifier, allowing easy correlation of the USCIS payment with the case file in the firm’s management system.

Ideally, these virtual cards would include security features such as a credit limit set to the exact filing fee for that matter, and the ability to lock or deactivate the card immediately after the USCIS payment is processed. This minimizes the risk of unauthorized charges, keeps sensitive information off paper forms, and simplifies reconciliation by linking each payment directly to a case record.

Limited exemptions for paper payments: Form G-1651

Recognizing that not all applicants can make electronic payments, USCIS created a narrow exemption process. You can request permission to make a paper fee payment by filing Form G-1651, Exemption for Paper Fee Payment.

Who qualifies

Eligibility for this exemption is tightly limited. According to USCIS, you may qualify if:

• You do not have access to banking services or an electronic payment system.

• An electronic payment would cause undue hardship, such as in situations of disability or lack of technology.

• The case involves national security or law enforcement activities that specifically require a non-electronic payment method.

Applicants must clearly document their circumstances and explain why an electronic payment is not feasible. USCIS will evaluate these requests on a case-by-case basis, and approval is not automatic.

Paper checks in emergency situations

There is one additional carve-out. Personal or business checks may still be used in emergencies when filing an Application for Travel Document (Form I-131) directly at a USCIS Field Office for emergency advance parole.

This is a very narrow exception and is not available for standard filings. Examples of when it might apply include:

• A U.S. resident must travel abroad urgently to care for a critically ill family member.

• An applicant needs immediate humanitarian parole for medical treatment overseas.

In such cases, the individual may appear at a field office, file Form I-131, and pay by paper check. But outside of these emergencies, the new electronic payment rule prevails.

Fee waivers and reduced fees: Important reminders

Form I-912: Request for fee waiver

Despite the shift to electronic payments, USCIS continues to offer fee waivers for eligible applicants. Form I-912 allows individuals to request a full waiver of filing fees if they meet one of these criteria:

• Receipt of a means-tested benefit such as Medicaid, SNAP, or Supplemental Security Income.

• Household income at or below 150% of the Federal Poverty Guidelines.

• Financial hardship is documented by evidence such as medical bills or unemployment.

Fee waivers can significantly expand access to immigration benefits for low-income clients. However, USCIS has tightened evidentiary requirements, so attorneys should ensure clients submit thorough documentation.

Reduced naturalization fee on Form N-400

In addition to full fee waivers, USCIS offers a reduced filing fee for naturalization applicants who cannot afford the full cost but do not qualify for a complete waiver.

Eligible applicants—those whose household income is more than 150% but not more than 200% of the Federal Poverty Guidelines—can request this reduced fee when filing Form N-400.

Attorneys working with community organizations should highlight this option, as it can make the path to citizenship more accessible for working-class immigrants.

Positioning your firm for success under the new system

Given the breadth of these changes, immigration practitioners should take proactive steps now. Consider:

• Updating client intake and payment policies to reflect electronic payment as the default.

• Educating clients about the new rule and explaining why paper checks are no longer accepted.

• Training staff on the exemption process and emergency carve-outs so they can quickly identify when these apply.

• Investing in secure payment systems such as Smart Spend and cybersecurity to protect client data.

• Reviewing eligibility for fee waivers or reduced fees for every case to ensure clients don’t pay more than necessary.

• Monitoring USCIS updates for future expansion of online filing to more forms.

Firms that adapt early can position themselves as leaders in efficient, compliant immigration practice.

Broader implications for the immigration system

Beyond the mechanics of payment, this rule reflects a larger theme in U.S. immigration administration: the gradual but uneven march toward modernization.

On one hand, USCIS has embraced online tools such as case status tracking, premium processing portals, and automated appointment scheduling. On the other hand, many core functions still rely on paper, and digital systems often lack integration.

For applicants, this means a fragmented experience. For attorneys, it means managing multiple channels of communication and filing. And for USCIS itself, it means balancing innovation with the reality of legacy systems and diverse user populations.

If implemented thoughtfully, the new payment rule could be a stepping stone to a more seamless digital future — one where forms, fees, and case updates all live in a unified online environment. Until then, immigration practitioners will need to navigate the mixed terrain.

Preparing for what’s next

USCIS’s decision to phase out paper checks and money orders for filing fees marks a significant milestone in the agency’s modernization journey. It promises faster payment processing, reduced errors, and greater efficiency. But it also highlights the incomplete nature of USCIS’s digital transformation: while payments have gone electronic, comprehensive e-filing remains elusive.

For law firms, the new rule brings both opportunity and responsibility. By adopting secure electronic payment practices, educating clients about exemptions, and leveraging fee waiver and reduced-fee options, attorneys can help their clients transition smoothly into the new system.

As USCIS continues to roll out digital tools, immigration practitioners have a chance to shape best practices, advocate for broader e-filing, and ensure that modernization serves all applicants. Getting the right tools in your tech stack can help, learn how 8am™ Smart Spend can help you switch to virtual credit card payments.

FAQs on USCIS electronic fee payments for law firms