What are the 2025 SNAP eligibility rules for lawful permanent residents (green card holders)?

1. What the new federal rule says about green card holders — the bottom line

The 2025 law limits SNAP eligibility to lawful permanent residents among noncitizens; in other words, only LPRs (plus a few other specific immigrant categories) remain explicitly eligible under Section 10108 ^{[1] [4]}. That change is a narrowing from prior practice that had allowed a wider set of lawfully present immigrants to qualify under certain conditions ^[4].

2. The five‑year waiting period: law, exemptions, and the current dispute

A 1996 statute created a five‑year waiting period for many qualified immigrants before they can receive SNAP, but that law also contained exemptions for refugees, asylees, Cuban/Haitian entrants, trafficking victims and others. Multiple legal‑advocacy groups say those 1996 exemptions remain in force despite OBBBA, meaning refugees and many humanitarian entrants who become LPRs should be immediately eligible if they meet other SNAP criteria ^{[4] [3]}. However, state agencies and local advocates report confusion: some states have begun applying a five‑year bar even to refugees and Special Immigrant Visa holders, and guidance from USDA/FNS has been criticized as unclear, creating inconsistent state implementation ^{[5] [3] [4]}.

3. Federal implementation timing and state-level discretion

FNS issued an information memorandum saying Section 10108 took effect on enactment (July 4, 2025) and that states must apply the new criteria to new applicants immediately and at recertification for ongoing cases; FNS allowed a 120‑day variance exclusion for misapplication with an end date of Nov. 1, 2025 ^[2]. SNAP is federally funded but state‑administered, so states build procedures and systems to implement federal law — and several sources report states are adopting differing, sometimes more restrictive practices than the federal statute requires ^{[2] [3]}.

4. Who remains clearly eligible among LPRs and what triggers extra checks

Under the new statutory framework, an LPR may be eligible for SNAP if they meet standard income, resource and work‑requirement tests; separate rules still govern age, disability, military service, or sufficient work history (40 quarters) that can exempt someone from the five‑year bar where it applies ^{[6] [7]}. Several state and nonprofit guidance pages emphasize that LPRs under age 18, LPRs with a military connection, those with qualifying work quarters, or people with disabilities typically qualify regardless of the five‑year clock ^{[6] [7]}.

5. Conflicting guidance and real‑world consequences

Advocates and legal clinics report that ambiguous federal guidance and rapid state policy changes have already led to denials, confusion, and fear among immigrant households; some states have reportedly cut off or are reinterpreting eligibility in ways that could exclude groups the law or longstanding exceptions were meant to protect ^{[3] [5] [8]}. The Congressional Budget Office estimated Section 10108 will remove roughly 90,000 people from SNAP in an average month, signaling measurable program impacts ^[1].

6. What applicants should do now — practical steps and limits of reporting

Advocates advise responding quickly to state agency requests about immigration status, documenting any humanitarian status or exempting factors (refugee/asylee status, military service, disability, 40 work quarters), and seeking legal help if benefits are denied improperly ^{[8] [6]}. Available sources do not mention a definitive, uniform federal list of every documentation item states must accept beyond FNS’s implementation memorandum ^{[2] [9]}.

7. Competing viewpoints and hidden agendas to watch

Pro‑immigrant advocates stress that longstanding humanitarian exemptions must be preserved and criticize federal guidance as “confusing,” urging states not to overreach ^{[4] [3]}. State agencies and some policy analysts emphasize the logistical burden of rapid system changes and cite statutory obligations to implement the new law immediately ^{[2] [10]}. Note the political context: sources frame OBBBA as both a fiscal tightening and an anti‑immigrant policy package, so advocates’ urgency and some state responses reflect contrasting policy agendas ^{[4] [3]}.

Limitations: this briefing uses only the provided sources; it does not include later FNS clarifications, pending litigation outcomes beyond what the sources cite, or individual state policy manuals unless cited above ^{[2] [10]}.