Which noncitizen categories remain eligible for federal SNAP after the One Big Beautiful Bill Act of 2025?

Checked on January 23, 2026
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Executive summary

The One Big Beautiful Bill Act of 2025 (OBBB) narrowed federal SNAP eligibility for noncitizens effective upon enactment, July 4, 2025, and USDA/FNS directed state agencies to apply the new criteria immediately for new applicants and at recertification for current recipients [1] [2]. Official and secondary reporting converge on a short list of noncitizen groups that remain federally eligible—chiefly Lawful Permanent Residents (LPRs), Cuban/Haitian entrants, and Compact of Free Association (COFA) migrants—while previously eligible groups such as refugees, asylees and trafficking victims are treated differently under the new law [3] [4] [5].

1. What the law changed and when it took effect

OBBB’s Section 10108 amended section 6(f) of the Food and Nutrition Act to redefine which “alien” groups qualify for SNAP, and those changes became effective immediately on July 4, 2025; FNS issued memoranda and Q&A guidance to states explaining that implementation for new applicants must be immediate and that current households would be reviewed at recertification [1] [2] [6].

2. The groups that remain eligible under federal SNAP after OBBB

Multiple implementation guides and policy summaries list Lawful Permanent Residents (LPRs), Cuban-Haitian entrants, and Compact of Free Association (COFA) migrants as the primary noncitizen categories that remain eligible for federally funded SNAP benefits under OBBB [3] [5]. USDA’s web pages and implementation memos reflect those statutory changes and are in the process of being updated on public-facing pages to reflect the narrowed list [7] [1]. These sources make clear the statute itself—and subsequent FNS guidance—now limits the universe of noncitizens who may count as eligible under federal SNAP rules to those specific statuses [2] [3].

3. Groups effectively removed or left in legal limbo

Refugees, asylees, trafficking victims and some other previously eligible categories that had been able to receive SNAP under the pre-OBBB framework are highlighted in NGO reporting and implementation summaries as no longer covered by the statute’s enumerated eligible alien groups, meaning many of those people could lose federal eligibility at recertification or when applying as new applicants [4] [3] [5]. Several outlets and advocacy organizations warned that the narrowing would “shorten the list” of eligible immigrant populations and that state agencies would need to reassess households’ eligibility once the FNS guidance was applied [4] [1].

4. Implementation mechanics, exceptions and outstanding rules

FNS told states the changes are not contingent on future regulations and reiterated that longstanding rules like the PRWORA five‑year waiting period and its exceptions remain intact, so some LPRs who otherwise qualify might still be subject to waiting-period rules established in 1996 [2]. FNS also issued additional implementation memoranda addressing related SNAP provisions (work requirements, payment error incentives and SNAP‑Ed funding) and signaled that public-facing pages were being updated to reflect the new policy realities [6] [8] [7].

5. Conflicting reports, ambiguity and why the discrepancy matters

Some news and advocacy accounts list slightly different groupings—one article referenced noncitizen U.S. nationals, lawful permanent residents, Cuban and Haitian entrants and even people without legal status in summaries of affected groups [9]—but authoritative implementation summaries from USDA, Ballotpedia, NACO and refugee advocacy groups consistently single out LPRs, Cuban‑Haitian entrants and COFA migrants as the explicitly preserved noncitizen categories under the statute, while flagging that refugees, asylees and trafficking victims are no longer on the enumerated list [3] [5] [4]. Given FNS’s instruction that the statutory text governs immediately and that states must follow agency guidance, the clearest, source‑based reading is that federally funded SNAP now limits noncitizen eligibility to those specific statuses, though differences in downstream reporting and the need for state-by-state administrative action create real uncertainty for affected households [2] [1].

Want to dive deeper?
Which states have issued their own policies or protections for immigrants facing SNAP eligibility changes after OBBB 2025?
How does the OBBB change interact with the PRWORA five‑year waiting period for Lawful Permanent Residents?
What is the projected fiscal and humanitarian impact of narrowing noncitizen SNAP eligibility under OBBB, according to independent analyses?