The U.S. Department of Homeland Security has published a final rule that will require photographs—and eventually full facial-recognition scans—of all non-U.S. citizens entering or leaving the country, including Canadians travelling by land, air or sea. The regulation appeared in the Federal Register on 27 October 2025 and is slated to take effect on 26 December, although nationwide deployment could take several years.
While U.S. Customs and Border Protection has captured biometrics from many foreign travellers since 2004, exits were patchy and Canadians were largely exempt. The new mandate closes that gap, creating a cradle-to-grave travel history that DHS says is essential to national security and visa-overstay enforcement. Photo records may be stored for up to 75 years.
For Canadian businesses, the change adds a new layer of compliance for cross-border commuters, truck drivers and frequent flyers enrolled in programs such as NEXUS. Employers will need to review privacy policies and advise staff that images will be taken on both sides of the journey. Travellers who decline can be denied entry.
Privacy advocates on both sides of the border warn of mission creep and data-breach risks. The Canadian government has not yet indicated whether it will introduce reciprocal measures, but officials told reporters they are “analyzing impacts” in consultation with Public Safety Canada.
Global mobility managers should update travel briefings by year-end, ensure that employee consent forms cover biometric capture, and monitor port-of-entry roll-outs to anticipate delays during the holiday season.
While U.S. Customs and Border Protection has captured biometrics from many foreign travellers since 2004, exits were patchy and Canadians were largely exempt. The new mandate closes that gap, creating a cradle-to-grave travel history that DHS says is essential to national security and visa-overstay enforcement. Photo records may be stored for up to 75 years.
For Canadian businesses, the change adds a new layer of compliance for cross-border commuters, truck drivers and frequent flyers enrolled in programs such as NEXUS. Employers will need to review privacy policies and advise staff that images will be taken on both sides of the journey. Travellers who decline can be denied entry.
Privacy advocates on both sides of the border warn of mission creep and data-breach risks. The Canadian government has not yet indicated whether it will introduce reciprocal measures, but officials told reporters they are “analyzing impacts” in consultation with Public Safety Canada.
Global mobility managers should update travel briefings by year-end, ensure that employee consent forms cover biometric capture, and monitor port-of-entry roll-outs to anticipate delays during the holiday season.
