The U.S. Department of Homeland Security is implementing the most comprehensive border security changes since 9/11, with mandatory biometric collection beginning December 26, 2025, and proposed modifications to ESTA and I-94 processes under review. Business aviation passengers and crew should prepare for immediate facial-scanning requirements and potential future digital screening expansions.

Immediate Impact: Mandatory Biometrics Begin December 26

A final rule titled “Collection of Biometric Data from Aliens Upon Entry to and Departure from the United States” takes effect December 26, 2025, requiring immediate compliance from all business aviation operators.

Critical changes for business aviation:

• Facial scanning required for all foreign passengers and crew at both departure and arrival
• Applies to all U.S. airports, including those used by private aircraft
• Previous exemptions for diplomats and most Canadian citizens are removed
• Fingerprints and iris scans may be added at a later stage
• Non-compliance could result in refused boarding or entry

Implementation Uncertainty for General Aviation

While the biometric rule applies to general aviation, CBP has not yet determined how enforcement will be implemented for business aviation operations. According to the National Business Aviation Association (NBAA), CBP’s General Aviation team confirmed that the requirement will apply but advised that “CBP has not yet determined how biometric enforcement will be implemented for General Aviation, or for several other affected modes of travel.” They noted that while they “do not have many answers at this time,” “nothing definitive is on the imminent horizon.”

While the rule’s formal effective date remains December 26, 2025, CBP officials have also clarified that they do not have information on when or how implementation will actually occur for General Aviation. This suggests that although the regulation is final, the operational rollout may not begin immediately. The effective date represents a policy milestone rather than an operational deadline, creating uncertainty for business aviation operators who must prepare for compliance without clear procedural guidance.

Operator Checklist for December 26

• Verify FBO biometric capabilities at departure airports
• Brief foreign passengers on new facial-scanning requirements
• Update passenger manifests to identify foreign nationals
• Coordinate with handling agents on potential processing delays
• Monitor CBP guidance for general aviation implementation details

Proposed Changes: Major ESTA and I-94 Overhaul Under Review

CBP published a separate proposal in the Federal Register on December 10, 2025 (FR Doc. 2025-22461) that would overhaul both Form I-94 and ESTA processes. While these changes remain open for public comment until February 9, 2026, they represent a significant modernization of border identity verification.

Five Key Proposals Under Review

• Voluntary Self-Reported Exit (VSRE) – New CBP Home mobile app feature allowing travelers to self-report departures using passport details, live selfie, and geolocation data. Critical for private aviation where exit records have historically been weak.
• Mandatory Photo Uploads for ESTA – All ESTA applicants must upload live facial photos along with passport images to combat fraud.
• ESTA Website Elimination – CBP will retire web-based ESTA applications, requiring exclusive use of ESTA Mobile App with advanced verification features.
• Mandatory Social Media and Data Expansion – ESTA applicants must provide:
  • Social media accounts (5 years)
  • Phone numbers (5 years) and email addresses (10 years)
  • Family member information and contact details
  • Business contact information
  • Biometrics (fingerprints, DNA, iris data when feasible)
• I-94 Automation – Continued digitization eliminating paper forms.

Comments must be submitted by February 9, 2026 to CBP_PRA@cbp.dhs.gov.

Key Differences for Private vs. Commercial Aviation

Biometric Compliance Challenges:

• Commercial: Airlines handle biometric capture through integrated gate systems.
• Private: Responsibility shifts to operators and FBOs, many of which lack permanent biometric infrastructure. CBP officers more likely use mobile devices, creating potential delays if facilities aren’t ready. However, specific implementation procedures for general aviation remain undefined.

ESTA/I-94 Impact:

• VSRE Feature: Critical for private aviation. Commercial flight manifests automatically create exit records, but private flights have historically had exit-data gaps. VSRE offers official biometric departure confirmation.
• Mobile-Only ESTA: Flight departments can no longer handle centralized web submissions for clients—each traveler must use their personal smartphone for live selfie and NFC passport verification.

Bottom Line: Private aviation faces more complex implementation because compliance is distributed across operators, FBOs, and local CBP offices rather than managed by integrated airline systems. The lack of specific implementation guidance adds further operational uncertainty.

Key Dates and Action Items

Immediate (December 26, 2025)

• Mandatory biometric collection begins for all foreign nationals
• Coordinate with FBOs on biometric procedures now
• Brief passengers on facial-scanning requirements
• Monitor for CBP general aviation implementation guidance

Future ESTA Changes (Under Review)

• Comment deadline: February 9, 2026
• If approved: Mobile-only ESTA, expanded data collection, self-reported exit capability

Bottom Line

Business aviation operators face two major regulatory developments representing the most comprehensive border security overhaul in decades. While immediate compliance is required for biometrics starting December 26, the lack of specific implementation guidance for general aviation creates operational uncertainty. Proposed ESTA changes would further digitize border processes if approved.

These updates mean increased pre-trip planning, expanded data obligations, and heavier reliance on mobile technology for compliance—once implementation procedures are clarified.

Universal will continue monitoring both the biometric implementation guidance and ESTA rulemaking process, providing updates as CBP clarifies general aviation procedures.