July 28, 2025
Kids in Need of Defense (KIND) submitted a public comment in response to proposed revisions to the Form G-325A, Biographic Information (for Deferred Action). KIND is deeply concerned that the proposed revisions, which would eliminate reference to deferred action for Special Immigrant Juveniles in Form G-325A, coupled with USCIS’s subsequent Policy Alert on Special Immigrant Juvenile Classification and Deferred Action, will eviscerate critical protection against removal to harm for thousands of children and youth to whom USCIS has granted Special Immigrant Juvenile Status (SIJS). Consequently, children and youth recognized by USCIS and state courts as having experienced abuse, abandonment, neglect, or other similar harm such that return to their country of origin is not in the child’s best interest could be deported by the Department of Homeland Security as they await visas—risking the very outcomes that Congress enacted specific protections to prevent. The changes would also eliminate access to and renewal of work authorization for thousands of SIJS recipients–impeding access to safe and lawful employment opportunities for eligible youth that can reduce vulnerability to labor exploitation and trafficking, while also eliminating a vital form of government-issued identification that is often necessary for children and youth to access essential services, including medical care.
The proposed changes to the Form G-325A, which foreclose the form’s use by Special Immigrant Juveniles to request or renew deferred action, are especially alarming amid the Administration’s efforts to dramatically expand immigration enforcement and rapid deportations nationwide, including of children and youth, and to implement a range of measures that restrict access to due process, legal services, and humanitarian protection for unaccompanied children and other vulnerable populations. Contrary to the Administration’s broader goals of combatting trafficking, exploitation, and other harm to children, the changes only increase the likelihood of such dangers. We urge USCIS to immediately rescind the notice and resume allowing Special Immigrant Juveniles to seek deferred action using Form G-325A.
