DHS Announces Revision to a Key System of Records on October 31, 2025
On October 31, 2025, the U.S. Department of Homeland Security (DHS) published a notice in the Federal Register proposing to modify and reissue the system of records notice (SORN) for the Systematic Alien Verification for Entitlements Program (SAVE), numbered DHS/USCIS-004. The modification provides enhanced details about how the system collects and uses records, updates covered individuals, and adds new routine uses. The changes are effective upon publication, with new or modified routine uses becoming effective December 1, 2025.
SAVE and the Privacy Act Framework
The Privacy Act requires federal agencies to publish a SORN whenever they maintain a “system of records” which is a group of records retrieved by individual identifiers such as name or Social Security number. The SAVE program administered by the U.S. Citizenship and Immigration Services (USCIS) enables federal, state, tribal, territorial and local agencies (user agencies) to verify immigration status or U.S. citizenship of individuals applying for public benefits, licenses or other government-authorized purposes. The underlying SORN (DHS/USCIS-004) was first published to cover this verification system and its records.
Key Modifications Announced on October 31, 2025
The published notice identifies a number of substantive updates to the system of records:
- Purpose(s) of the system: Expanded to clarify that SAVE now covers verification of U.S. citizenship (including for U.S. citizens by birth, naturalized citizens and certain acquired citizens) and not just immigration status
- Categories of individuals covered: Includes U.S. citizens by birth (in addition to immigrants and non-immigrants) when verification is requested by user agencies
- Categories of records in the system: Updated to include full and truncated Social Security numbers (other than those only collected on Form G-845), U.S. passport numbers, driver’s license numbers and data drawn from the Social Security Administration (SSA)
- Sources of records: Added record sources such as SSA’s “Master Files of Social Security Number Holders and SSN Applications” (SSA-60-0058) and state or national agencies that issue or maintain driver’s license information
- Routine uses: Two new routine uses were added: Routine Use L permitting disclosure to SSA and other federal organizations, and Routine Use M permitting sharing with federal agencies (for example the Department of Health and Human Services) to support auditing of federal programs administered by state, local or tribal governments
- Formatting and non-substantive changes: The notice reorganizes text, changes usage of terms such as “acquired citizenship” rather than “derived citizenship,” and clarifies references to forms and terminology
Why These Modifications Matter for Immigration Practitioners
- Broader verification scope: The expanded purpose means that SAVE verification may now be requested not only for immigration status but for U.S. citizenship status. This may increase verification activity and documentation required by user agencies
- Inclusion of U.S. citizens in covered population: Counsel should advise clients that U.S. citizens (by birth, naturalization or acquisition under certain conditions) may appear in the system when user agencies request SAVE verification
- Expanded categories of records: The fact that driver’s license numbers and passport numbers are now explicitly covered means more personal identifiers may be collected and processed under SAVE. Attorneys should check that the privacy notice provided by user agencies addresses these identifiers
- New routine uses increase inter-agency sharing: The updated routine uses reflect increased data sharing with SSA and other federal agencies, which may have implications for access requests or amendment rights under the Privacy Act
- Effective dates and public comment period: The effective date of the new or modified routine uses is December 1, 2025, and comments must be submitted by December 1, 2025. The modification is effective upon publication for other portions
The updated SORN for the SAVE program reflects the federal government’s evolving approach to verification, data sharing and identity management under the Privacy Act framework. For immigration practitioners, understanding these changes is essential to advising clients accurately about verification risks, privacy protections and compliance obligations. Clients who are proactive about verification, record access and amendment rights will be in the strongest position as SAVE verification continues to be used by an expanding number of agencies.
