How does the US use facial recognition technology for international travelers?
Executive summary
The Department of Homeland Security finalized a rule requiring U.S. Customs and Border Protection (CBP) to collect facial images from virtually all non‑U.S. citizens entering and leaving the country by air, land or sea, effective December 26, 2025 [1] [2]. DHS and CBP say the system uses a cloud-based Traveler Verification Service (TVS) to compare live photos to passport/visa images, with CBP citing >98% match rates and faster processing times; critics warn of privacy, retention and misidentification risks [2] [1] [3].
1. What the rule does: mandatory facial capture at every port
The final DHS rule makes facial‑biometric capture mandatory for all foreign nationals — including green‑card holders and Canadians — at airports, land crossings, seaports and other authorized departure points; it removes prior age and port exemptions and extends capture to exits as well as entries, effective December 26, 2025 [4] [5] [1].
2. How CBP implements the checks: TVS, galleries and real‑time matching
CBP will rely on its Traveler Verification Service (TVS), a cloud‑based matching engine that creates galleries of expected travelers from advance passenger information and government photos, then compares live captures to those images. The agency frames the technology as automated identity checks that detect impostors, document fraud and visa overstays, and says most international passengers are already processed using facial comparison [1] [2].
3. Claimed benefits: speed, accuracy and enforcement
DHS and CBP argue facial comparison is accurate, unobtrusive and efficient; the Federal Register cites NIST testing showing matching rates greater than 98% and CBP says matches occur in under two seconds, which officials say streamlines processing and helps intercept fraudulent travel documents and overstays [1] [4] [2].
4. Data flows, retention and opt‑out limits
DHS documents describe building image galleries from passport/visa photos and advance data; CBP maintains some photos are deleted quickly (airline/airport servers within 12 hours), but images of non‑matched travelers or enforcement subjects can be retained much longer — reporting cites possible retention for up to 75 years for some non‑citizen records [4] [5]. Available sources do not detail every domestic or foreign data‑sharing partner beyond general references in the rule [1].
5. Where the checks are already visible: airports and pilots
Major U.S. airports and pilot programs have deployed facial‑comparison systems for years. Orlando International in particular has expanded facial biometric boarding and is testing “contactless corridors” to let passengers board without showing passports, reflecting the operational shift toward gate‑level biometrics [6] [7] [8].
6. Civil‑liberties and accuracy concerns from watchdogs
Privacy groups and civil‑rights watchdogs have warned that expanding facial recognition risks normalizing mass surveillance and can misidentify Black, Asian and other minority travelers; reporting references a 2024 U.S. Commission on Civil Rights report and other critiques about algorithmic bias and overreach [9] [3]. The Federal Register and DHS documents acknowledge manual review where matches fail, but critics stress real‑world error rates and unequal impacts on populations of color [1] [3].
7. Enforcement rationale and political context
DHS frames the expansion as a longstanding congressional mandate (entry‑exit tracking) finally implemented with modern biometrics to combat visa fraud and overstays; outlets tie the move to a broader push for tighter border controls in the current administration [2] [10].
8. Practical impacts for travelers and employers
Foreign nationals should expect mandatory photographs when crossing or departing the United States; business travelers and employers managing cross‑border staff must update guidance because green‑card holders and previously exempt nationals (e.g., many Canadians) will be captured under the new rule [4] [5]. CBP says manual checks will resolve mismatches, but travelers may face secondary inspection delays if images don’t match passport photos [4].
9. What remains unclear or disputed in reporting
Sources converge on the rule’s scope and effective date but leave gaps: the precise mechanics of long‑term retention and downstream sharing are described only in broad terms in DHS assessments, and independent audit, deletion practices and oversight details beyond annual privacy assessments are not fully laid out in available reporting [1] [5]. Where reports differ, government sources emphasize technical accuracy and efficiency while advocacy outlets highlight bias, retention and surveillance risks [1] [3] [9].
Bottom line: by late December 2025 the U.S. will systematically photograph and run facial matches on nearly all non‑citizen travelers at every mode of travel, using TVS to speed processing and detect fraud, while privacy advocates warn of long retention windows, potential misidentification and a broader normalization of biometric surveillance [1] [2] [3].