If you don’t have time to read the whole article — here’s the gist in six points
- What changed. On May 11, 2026, the Federal Register published a new DHS rule titled Interim Final Rule (for short — IFR; below the word “rule”, “regulation” and “IFR” mean this document — 91 FR 25479). It becomes effective July 10, 2026. Under it, USCIS gains the authority to deny a form and retain the fee if, after acceptance, it determines the signature was invalid.
- Who it affects. Anyone filing any USCIS form either pro se or through an attorney — I-140, I-129/O-1, I-907, I-130, I-485, I-539, N-400, etc. Especially those collecting EB-1A and O-1 cases themselves.
- What counts as a bad signature. An image of a signature pasted into a PDF from another file. A stamp. DocuSign and Adobe e-signature placed on the form itself. An attorney’s or translator’s signature instead of yours. A typed name in the signature field.
- What is fine. Print the form, sign with a pen, and submit the original or its scan/copy/fax (these are the terms used in the regulation: scanned, copied, or faxed version). In practice, a photo of a paper-signed form from a phone usually also works as a copy, but the IFR category is specifically “copy.” This method worked before and continues to work.
- The main trap. At intake the difference between a real signature and a pasted image is often not visible. An officer may discover it months or even years later, when the case is already in adjudication. Then — denial; USCIS usually retains the fee; you may lose the filing date, queue position, cap opportunity, visa availability or another deadline important to your form. In green-card categories this often means loss of the priority date. You cannot re-sign retroactively.
<li><strong>I-485 and I-539 — particularly risky.</strong> These forms often serve as the basis for authorized stay in the U.S. while pending. If they are denied a year after filing and the prior I-94 has expired in the meantime — you may suddenly have no basis to remain in the U.S. These two forms are better not to file pro se with the risk of a signature slip-up.</li>
As of July 10, 2026, a signature pasted as an image, DocuSign and Adobe e-signature outside an USCIS-authorized process, a stamp or a typed name on forms I-140, I-129, I-130, I-485 or N-400 — these are risks of denial with loss of filing fee and queue position for EB-1A, EB-2 NIW, H-1B or family green-card filings. At the same time a scanned, copied, or faxed form that contains an original wet-ink signature remains fully permissible — this is important to distinguish, because many first-wave commentators called “faxed signature” a problem, which it is not. The fee amount depends on the form and is taken from the current USCIS Fee Schedule (G-1055, not from the IFR itself): ballpark — from a few hundred dollars for I-539 to one-and-a-half to two thousand for I-485. If I-907 premium processing was filed concurrently, its fate depends on separate I-907 rules (primarily whether USCIS completed adjudicative action within the required timeframe) — the IFR does not set a separate refund rule for I-907 fees. The DHS (Department of Homeland Security, parent agency for USCIS, ICE and CBP) codified this in a new regulation that was filed for public inspection May 8, 2026 and published in the Federal Register May 11, 2026.
(Technically the IFR explicitly lists only one amount — $800 for I-290B Notice of Appeal or Motion, in footnote 39 with a reference to the G-1055 Fee Schedule. All other fee figures cited in this article are taken from the current G-1055 and may change independently of the signature rule.)
(Terminology detail often mixed up. Petitions are, for example, I-129 (Petition for a Nonimmigrant Worker), I-130 (Petition for Alien Relative), I-140 (Immigrant Petition for Alien Worker) — where one person or employer petitions on behalf of another. Applications are, for example, I-485, I-539, N-400, I-765, I-131 — where a person files for themselves. USCIS’s umbrella term for both is benefit request. The regulation 91 FR 25479 applies equally to all these forms.)
Below is an analysis of what the regulation 91 FR 25479 explicitly says, what is permitted and not permitted under 8 CFR 103.2 and the USCIS Policy Manual, and what practical consequences this creates for different forms.
This is an independent analysis of the public rule 91 FR 25479, not legal advice. All links and quotes are from the IFR text and the public docket USCIS-2026-0166. The USCIS Policy Manual section on signatures is also referenced here.
Short glossary so we don’t stumble later
- USCIS — the agency that accepts and adjudicates immigration forms
- IFR — the new rule published May 11, 2026 and becoming effective July 10, 2026
- 8 CFR 103.2 — the regulatory paragraph amended by this IFR
- RFE — a Request for Evidence from USCIS asking for additional documents
- Reject — the form was not accepted at intake; usually fees are returned; you can refile (there are limited exceptions on fee retention)
- Deny — the form was adjudicated and denied; the fee is usually retained
Contents
- Main point in one paragraph. What changed
- What was before July 10, 2026. Lockbox, PM 2018
- What signature is invalid for USCIS?
- Full list of what is no longer considered a signature
- What is considered a valid signature
- The worst part for attorneys and large HR
- Case with I-129 and 20+ petitions. One boss, image-signature and a conveyor
- Case with I-140 and ~3000 petitions. One residential US address
- Denial statistics 2021-2025. Tenfold growth
Main point in one paragraph
DHS (Department of Homeland Security — which includes USCIS, U.S. Citizenship and Immigration Services, the agency that adjudicates immigration forms) codified in a new regulation USCIS’s authority to deny a benefit request and retain the fee if, after acceptance, it is discovered that the signature was invalid.
Previously this was a 2018 policy, published as a PM (Policy Memorandum — an internal USCIS document explaining how officers should apply the law, but not itself a statute and not published in the Federal Register). Specifically, the policy was PM-602-0134.1 and existed since February 15, 2018. On March 5, 2020 it was incorporated into the USCIS Policy Manual, Volume 1, Part B, Chapter 2 (Signatures), where it can be read in current form.
Now this is 8 CFR 103.2(a)(7)(ii)(A) — a paragraph in the Code of Federal Regulations. Read: Title 8 (immigration), Part 103 (general filing rules), Section 2 (submission and adjudication of benefit requests).
In the new wording there is one magic word — “may”. That is, “may.” Not “must” or “shall,” but “may” — discretionary. This is legally important because it turns the routine decision into a discretionary one. There is a separate section on discretion later, because discretion creates new problems.
(The Federal Register is the U.S. official journal where agencies publish new rules. IFR is the interim-final rule format, when an agency publishes a rule as effective immediately while still collecting comments. This rule becomes effective July 10, 2026; comments are being collected until that date.)
(1) Every form, benefit request, or other document that requires a signature must be submitted with a valid signature.
(2) If USCIS accepts a benefit request and determines later that the request was not submitted with a valid signature, USCIS may reject or deny the request, except
(3) An Application for Certificate of Citizenship or Application for Citizenship and Issuance of Certificate Under Section 322 of the INA filed by an applicant seeking a certificate of citizenship may only be rejected if the only deficiency with the request is that it was not submitted with a valid signature.
What was before July 10, 2026
To understand what changes, you must understand how USCIS accepts a form. Two stages.
Stage one — intake. When you submitted the form (paper or via myUSCIS), the USCIS intake unit first checks it. This is like reception at a clinic: they don’t adjudicate, they just verify you filled it correctly. Is the fee paid, is there a signature in the right field, is it not typed. If something is wrong — reject: the form is returned, the money is returned, the filing is as if it never existed. You can refile.
Stage two — adjudication. If intake is OK, the form goes to a USCIS officer who adjudicates it on the merits. This is where the main signature story happens. Often a signature is pasted as an image, and at intake it may not be noticeable (it looks like a real signature), but the officer, when comparing signatures across different forms, sees the forgery.
What happened previously and what will happen from July 10, 2026.
Before: under the 2018 internal USCIS instruction the officer was supposed to deny. But that instruction existed as an internal PM (PM-602-0134.1) on the website — not as part of the regulation.
From July 10, 2026: the same rule about denial becomes part of the codified regulation (8 CFR 103.2(a)(7)(ii)(A)), published in the Federal Register. That substantially increases its legal weight: an instruction could be contested on appeal more easily; a regulation is much harder to challenge.
In short for filers: the rule that “accepted, later found an invalid signature, deny and do not return the fee” is now in the regulation itself. A regulation is a binding norm. You can litigate it, but that’s difficult and slow; practically you must live with it.
"The 2018 PM provided, in relevant part, that if USCIS determines that the requisite signature on the request is not valid, USCIS will reject the request and return it under 8 CFR 103.2(a)(7), however, if USCIS accepts a request for adjudication and later determines it has a deficient signature, USCIS will deny the request."
Previously this was a PM (internal memorandum). From July 10, 2026 it becomes part of the codified regulation published in the Federal Register as an interim final rule. Legal effect — stronger: you can no longer argue “this is just a policy memo.”
What signature is considered invalid for USCIS?
Full list of what is no longer considered a signature
The regulator and the 2026 edition of the Policy Manual list the following that are not acceptable:
- An image copied from another document (paste image)
- Generated by software such as DocuSign on the form where it is not allowed
- Stamped (with rare exceptions)
- An attorney’s, translator’s or instructor’s signature instead of the applicant’s
- Typewritten (typed) name
(Civil surgeon is a physician accredited by USCIS to perform the immigration medical exam. I-693 is that form. Under the Policy Manual the civil surgeon is allowed to stamp instead of a handwritten signature if blanket-designated. This is a rare exception, not the general rule.)
What is considered a valid signature
- Handwritten signature (wet-ink signature) on paper
- A scanned, copied, or faxed version of the original that bears that handwritten signature (exact IFR phrasing: scanned, copied, or faxed version)
- Electronic signature through guided e-filing on myUSCIS (but only there)
- Parent signature for a child under 14
- Legal guardian signature for an adult lacking capacity
The worst part for attorneys and large HR
Electronic signature via an attorney’s myUSCIS account is not available at all. If an attorney uploads a PDF on your behalf through their account — it must be a scan-copy with your wet-ink signature on paper. No DocuSign, no program-generated signatures.
Why USCIS did this. Denial growth figures in 2025
The IFR preamble includes surprisingly candid numbers. The AAO (Administrative Appeals Office, which reviews appeals of denials for most forms except family-based and asylum) reviewed 758 appeals where the denial was specifically due to a copied signature.
And DHS cites specific examples in the rule text:
Case with I-129 and 20+ petitions. One boss, image-signature and a conveyor
An authorized signatory (an employee authorized in corporate documents to sign petitions on behalf of the employer — usually CEO, COO, VP HR or a designated officer) signed once on a blank sheet. Their subordinate — apparently an assistant or paralegal in HR — cut that signature out in a photo editor and pasted it as an image into more than 20 different I-129 petitions. (I-129 — Petition for a Nonimmigrant Worker, used to petition for H-1B, L-1, O-1, P, R and others. Filing cost depends on category and company size; current figures are in the G-1055 Fee Schedule, not the IFR.) All 20+ petitions were filed with the same scanned signature identical to the pixel.
Case with I-140 and ~3,000 petitions. One residential US address
A consulting firm (name and origin not disclosed in the rule) filed approximately 3,000 I-140 petitions using the same image-signature. (I-140 — Immigrant Petition for Alien Worker, the first step in employment-based green-card processing: EB-1, EB-2, EB-3 including EB-1A, EB-2 NIW and labor-certification routes.) The IFR (section IV.A and footnote 21) states that all 3,000 petitions were filed without completing the preparer section, without a G-28 attorney notice, with the same in-care-of person and a single residential US address (i.e., a home address, not a corporate address). G-28 is the Notice of Entry of Appearance by attorney; preparer is the person who prepared the package. By description it was a conveyor of thousands of unattended petitions with no clear author behind the filings.
Denial statistics 2021-2025. Tenfold growth
| Year | Signature-related denials | Growth vs 2021 |
|---|---|---|
| 2021 | 300 | - |
| 2022 | 436 | +45% |
| 2023 | 727 | +142% |
| 2024 | 1,545 | +415% |
| 2025 | 2,953 | +884% |
| 5-year average | 1,192 | - |
Over four years growth is almost tenfold. DHS projects about 1,200 denials a year going forward, but that projection assumes the IFR will have a deterrent effect and filers will become more careful.
Source of the figures is the IFR preamble: Department of Homeland Security, USCIS Office of Performance and Quality, NPD, ECHO, queried 1/2026, PAER0020097.
The worst part. You cannot cure retroactively
Previously many relied on a simple scheme: signature turned out to be bad, USCIS sent an RFE, you submit a correct signature — case proceeds. With the new rule that no longer works.
If USCIS already accepted the form and later finds a bad signature — you cannot send a new signature and ask to have it counted retroactively. USCIS may send a Request for Evidence (RFE), but not to allow you to fix the signature; rather to prove that the signature was original and valid at the time of submission. If you prove it — the case continues. If you cannot — reject or deny, and you will not be allowed to re-sign retroactively.
In short: the door “oops, I’ll sign properly now, forget about it” is closed.
The regulator’s logic is straightforward. If cure were allowed, filers (especially those fighting for priority dates in queues like EB-2/EB-3 India or for an H-1B cap slot) would deliberately file with a defective signature just to get an early receipt date, then “fix” it months later when USCIS noticed.
Direct quote from footnote 31 of the rule 91 FR 25479, footnote 31 (text after [31] in section IV.E.)
"USCIS has anecdotal evidence of practitioners who submit a known bad signature so they can get their spot in the processing line with their plan being to fix it later."
Plainly: USCIS names this scheme and closes it by regulation. If before July 10, 2026 one could play “oops I forgot, send an RFE for cure” — now that’s a risk of reject or deny at USCIS discretion. Deny is more likely if USCIS sees a pattern or practice — copy-paste signatures across multiple filings, signature software, systematic circumvention. Reject is more likely if the defect looks like an inadvertent error.
"While there is discretion under the regulations to allow submission of required evidence post-submission, USCIS officers have no discretion to 'cure' an invalid signature or deficient signature that would have rendered the filing invalid at the time of submission."
That is: motions or appeals remain possible, but not as “here’s a new signature, count it retroactively.” You can only contest USCIS’s finding that the signature was invalid. You must prove it was valid at filing.
What is the difference between deny and reject regarding signature?
Procedure-wise there are three differences. This is important because the word “deny” sounds worse than “reject”, but in practice it gives the filer one protective option that reject does not.
| Reject | Deny | |
|---|---|---|
| Money | Usually returned | Usually retained (USCIS may retain fee) |
| Can refile | Yes, same form | Yes, but you must pay again |
| Appeal available | No | Often yes (depends on form) |
| Place in queue | Lost | Lost |
| N-600 and N-600K | Yes | No (if a bad signature is the only defect) |
Main advantage for the filer: after a deny there may be a path to appeal or motion — but only if the particular form and decision type allow it. For many AAO-jurisdiction forms (I-129, I-140, many N-forms) the route is I-290B (fee $800). For I-130 the route is typically different. After a reject appeals are usually not available. This is thin consolation, but a potential opening — if you are confident the signature was genuine and the officer erred.
(APA — Administrative Procedure Act, the main federal statute to challenge federal agency actions in court. The general statute of limitations under 28 U.S.C. § 2401(a) is 6 years, but since Corner Post v. Board of Governors (2024) an APA claim accrues when a plaintiff first suffers injury from final agency action. For a facial challenge the accrual may not be the rule publication date but when the rule first affected that plaintiff. AAO — Administrative Appeals Office inside USCIS; for many AAO-jurisdiction forms the I-290B is used, but not for all forms.)
Exception for N-600 and N-600K
DHS left one exception — for two forms:
- N-600 — Application for Certificate of Citizenship (for those who are already U.S. citizens by law but want the paper)
- N-600K — certificate application for children of U.S. citizens born abroad
For these two forms, if the only defect is a bad signature, USCIS must use reject (with fee return), not deny. This is because these forms can in practice be filed only once — if denied, refiling is often not possible, and the person would be left without a citizenship document. Hence DHS preserved this protective valve.
Important: if the application has other problems besides signature, the protective valve does not apply — regular deny applies.
How to sign USCIS forms after July 10, 2026?
In short — what the regulation says to do and not to do with signatures on USCIS forms.
- ✓ Sign each form separately with a live pen
- ✓ If many signatures are needed across forms (e.g., corporate filing of ten H-1Bs) — each must be its own live signature; do not copy as an image
- ✓ A scan or photo of a paper-signed form is acceptable
- ✓ DocuSign and Adobe e-signature on USCIS forms — not allowed (except one case noted below)
- ✓ Electronic signature is valid only if you file via guided e-filing on myUSCIS (the website prompts the signature). Attorney accounts on myUSCIS do not currently have that electronic signature option
Simple signing algorithm that always works
Not in Adobe e-sign mode, not in DocuSign. Just a printer and paper.
Sign every page where a "Signature" field is present with your live hand.
If filing via myUSCIS PDFi or through an attorney portal — upload the scan. If paper filing — send the original in the envelope.
If USCIS later asks you to prove the signature was genuine — the original paper is the best evidence.
This algorithm works for any USCIS form and will remain safe even if rules change later.
"In one case, the authorized signatory signed a blank sheet of paper and had their subordinate copy that signature onto at least 20 Petitions for Nonimmigrant Worker (Form I-129). In another case, a consulting firm completed and filed approximately 3,000 Petitions for Immigrant Worker (Form I-140) where the signature was pasted on the Form I-140."
This is precisely the corporate pattern now targeted. Correct process: the signatory signs each form by hand; the company retains originals; USCIS receives the original or an acceptable copy/scan/fax of the exact signed form. You cannot copy one image signature across dozens of forms.
What to do about already-filed forms
The regulation applies to filings made on or after July 10, 2026. Older filings already in process remain under the prior regime. But the 2018 policy already allowed denial — so denials are possible for them too, just not based on the new regulation but based on the PM. If you worry about an already-filed application — prepare copies of all originals with wet-ink signatures in case of an RFE/NOID.
Separate warning for those filing I-485 or I-539
Most EB-1A and O-1 cases at some point go through I-485 (adjustment of status to green card when the person is already in the U.S.) or I-539 (extension or change of nonimmigrant status).
The new rule hits these two forms especially hard. Reason: while USCIS is adjudicating I-485 or I-539, the person usually remains in authorized stay — legally in the U.S. while the form is pending. Sometimes that takes months, sometimes a year or more.
Important nuance: pending I-485 is not a status per se but a basis for legal stay and derivative benefits (EAD — work authorization, AP — advance parole). It does not extend your underlying H-1B, F-1 or O-1 status as such. If the underlying status (e.g., valid H-1B I-94) is gone, the person is in the U.S. solely on pending AOS grounds.
What happens if a denial comes after a year: the pending-AOS basis disappears. EAD and AP issued on that basis become void. If at that time there is no other valid status (for example, H-1B expired) the person has no lawful basis to remain in the U.S. Unlawful presence starts accruing. If you accrue 180+ days and then depart — a 3-year bar may apply; 365+ days — a 10-year bar. The denial itself does not immediately impose the bar; it creates situations that have consequences when leaving or seeking status changes.
Simple takeaway
I-485 and I-539 — a signature mistake can cost not only money but the very right to stay in the U.S. Here it’s cheaper to work with an attorney than to try to save on filing.
Complete table. Which signature is valid, which is not
The tables below each include a third column with a direct link to the regulatory paragraph, Federal Register section or Policy Manual section from which the statement is taken. This makes clear: nothing is made up; everything is from the source texts.
Category 1. Directly valid
| Signature method | Condition | Source in regulation |
|---|---|---|
| Handwritten pen signature on paper | Always valid | Per 8 CFR 103.2(a)(2): "an acceptable signature on a benefit request... is one that is either handwritten or, for benefit requests filed electronically as permitted by the instructions to the form, in electronic format" |
| Scribble / any handwritten mark | Valid if it matches the requester’s usual signature | Per USCIS Policy Manual 1 USCIS-PM B.2(A): "any handwritten mark or sign made by a requestor... to signify his or her knowledge and approval of the contents of the request" |
| Initials or short signature | Valid if the applicant usually signs that way | Per USCIS Policy Manual 1 USCIS-PM B.2(A), any handwritten mark is acceptable |
| "X" instead of signature | Valid, but USCIS may request additional verification | Per the IFR (section III.B.3): "USCIS Lockbox business rules look for a 'valid signature,' or one that is... (4) an 'X'. If a requestor uses an 'X', USCIS usually engages in some additional validation to ensure the individual consistently uses an 'X'" |
| Thumbprint in place of signature | Valid | Per the IFR (section III.B.3): "(3) a thumbprint in place of a written signature" — in the Lockbox business rules list |
| Parent signing for child under 14 | Valid | Per 8 CFR 103.2(a)(2): "An applicant or petitioner must sign his or her benefit request. However, a parent or legal guardian may sign for a person who is less than 14 years old" |
| Legal guardian for mentally incompetent person | Valid | Per 8 CFR 103.2(a)(2) and USCIS Policy Manual 1 USCIS-PM B.2(A) |
| Scan / copy / fax of a form that was actually signed by hand | Valid if that submission method is permitted | Per IFR (section III.B.2): "A scanned, copied, or faxed version of the originally signed benefit request, with the wet-ink signature on it, suffices". Also see the USCIS Web Alert (July 25, 2022) that made this flexibility permanent: USCIS Web Alert |
| Secure electronic signature via myUSCIS guided e-filing | Valid, only in that process | Per IFR (section III.B.2): "When filing online through guided e-filing or PDFi via myUSCIS, a requestor's valid signature is a secure electronic signature prompted during the e-filing process" |
Category 2. Directly invalid
| Signature method | Why USCIS rejects it | Source in regulation |
|---|---|---|
| Typewritten (typed name in signature field) | Explicitly called invalid | Per IFR (section III.B.3): "Under the same business rules, an invalid signature is one that is typewritten or missing" |
| Empty signature field | Missing valid signature | Per IFR (section III.B.3): "an invalid signature is one that is typewritten or missing" |
| Image signature pasted into PDF from another file | Copy-paste signature explicitly named invalid | Per IFR (section IV.A): "requests submitted with invalid signatures created by copy-pasting or affixing an image of the same signature on multiple benefit requests in contravention of USCIS policy" |
| Signature copied from one paper document onto others | Concrete example in the IFR preamble | Per IFR (section IV.A case example): "consulting firm completed and filed approximately 3,000 Petitions for Immigrant Worker (Form I-140) where the signature was pasted on the Form I-140" |
| DocuSign electronic signature outside USCIS process | Not handwritten and not an authorized electronic signature | Per IFR (section III.B.2): "Beyond these processes, an electronic signature is not valid and only a requestor's handwritten signature is valid" |
| Adobe Acrobat e-signature / certificate / fill-and-sign | Electronic signature outside authorized process | Per IFR (section III.B.2) and 8 CFR 103.2(a)(2): electronic signature is valid only if the form is filed electronically as permitted by form instructions |
| Attorney signed in place of applicant | Attorney signs preparer section, not applicant signature | Per 8 CFR 103.2(a)(2): "An applicant or petitioner must sign his or her benefit request" |
| Preparer or interpreter signed instead of applicant | Same limitation | Per IFR (section IV.A): "applications that are signed by someone other than the requestor (attorney, preparer, or interpreter)" — included in the list of invalid signatures |
| Stamped signature (general case) | Invalid except for rare form instructions | Per IFR (section IV.A): "signatures that are stamped" — listed among invalid signature types |
| Signatures created by signature software | Explicitly called a problematic pattern | Per IFR (section IV.A): "signatures created by signature software programs" — in the list of invalid signatures |
Category 3. Depends on the situation
| Signature method | When valid | Source in regulation |
|---|---|---|
| Civil surgeon stamp on I-693 | Only if the civil surgeon is blanket-designated and form instructions allow it | Per IFR footnote 20: "a health department physician who is acting as a blanket-designated civil surgeon... may provide an original (handwritten) or stamped signature, as long as it is the signature of the health department physician" |
| Signature via myUSCIS PDFi upload | The system may prompt a secure electronic signature if no handwritten mark is detected | Per IFR (section III.B.2): "if during certain PDFi upload processes, no handwritten mark or signature is detected on the uploaded form, an individual may be prompted to provide a secure electronic signature" |
| Signature via attorney myUSCIS PDFi | Electronic signature via attorney portal is not available. A scan with a wet-ink signature is required | Per IFR (section III.B.2): "This option only applies to benefit requestor-filed submissions; no electronic signature option is currently available for attorney-filed PDFi submissions" |
DocuSign and Adobe. Strict wording
Not “usually”. Not “in most cases”. But strict by regulation.
DocuSign electronic signatures outside an authorized USCIS electronic filing process are not a valid signature on the USCIS form (I-129, I-140, I-485, I-539, N-400, etc.). Period. Not “may be, but risky”, but “not valid.”
Important clarification this discussion does not cover. This rule concerns the signature on the USCIS form itself — the one filed to Lockbox or via myUSCIS that contains the phrase "I certify, under penalty of perjury." It does not cover signatures on recommendation letters for EB-1A/O-1, affidavits, expert opinion letters, or translations. Those have different policies, and DocuSign signatures from third-party recommenders or experts typically do not cause problems — but that is a separate topic and set of rules. Here we discuss only the signature box on the form.
Terminology note
The IFR text does not name brands “DocuSign” or “Adobe” directly. The regulation uses categorical phrases: "signatures created by signature software programs" (section IV.A) and "electronic signature is not valid… only a requestor's handwritten signature is valid" (section III.B.2). The interpretation that these categories include DocuSign and Adobe e-sign features is straightforward: DocuSign is a signature software program, Adobe e-sign is an electronic signature outside an authorized USCIS process. But there is no literal brand mention in the regulation.
The regulatory basis is clear. 8 CFR 103.2(a)(2) says acceptable signature for USCIS is either handwritten or electronic, but only for benefit requests “filed electronically as permitted by the instructions to the form.” In other words, an electronic signature is allowed not generally but only when USCIS itself has authorized it through form instructions or its online process.
The Federal Register states even more plainly. Quote from the IFR text 91 FR 25479:
The reason I previously wrote “usually” was due to nuance. The brand name “Adobe” can represent several actions. Filling a form in Adobe Acrobat, printing it, signing by hand, and mailing the paper — that is not Adobe e-signature; it is a handwritten signature and is valid. But inserting an image of your signature into Adobe or applying an Adobe certificate — that is an electronic signature.
Summary table of concrete actions with the source:
| What was done | Valid? | Source |
|---|---|---|
| Filled form in Adobe, printed, signed by hand, mailed paper | Yes | Per 8 CFR 103.2(a)(2): handwritten signature |
| Signed by hand, scanned the signed form, submitted the scan | Yes, if that submission method is allowed for the form | Per IFR (section III.B.2): "A scanned, copied, or faxed version of the originally signed benefit request, with the wet-ink signature on it, suffices" |
| Printed name as signature in Adobe or DocuSign | No | Per IFR (section III.B.3): "an invalid signature is one that is typewritten or missing" |
| Applied e-signature / certificate in Adobe or DocuSign | No, unless it is the USCIS-authorized e-filing process | Per IFR (section III.B.2): "Beyond these processes, an electronic signature is not valid" |
| Pasted an image of your signature into the PDF | No | Per IFR (section IV.A): "copy-pasting or affixing an image of the same signature on multiple benefit requests" |
| Copied a signature from another document and pasted into the form | No | Per IFR (section IV.A) and footnote 25 (AAO examples) |
| Used myUSCIS guided e-filing signature prompt | Yes, only if the form is filed through that process | Per IFR (section III.B.2): "valid signature is a secure electronic signature prompted during the e-filing process" |
What the regulation describes as the cleanest legal signing process
From the combination of 8 CFR 103.2(a)(2), IFR section III.B.2 and the USCIS Policy Manual: complete the form, print the final version, sign with a pen, date it, keep a copy or scan of the signed form, and submit that exact signed version (paper original or its acceptable scan). This process matches the definition of handwritten signature and the permitted scanned/copied/faxed version from the rule text.
Timeline and where to submit comments in 2026
May 8, 2026
The document was filed for public inspection signed by Markwayne Mullin, Secretary of Homeland Security. This is not the effective date nor necessarily the signature date; the Federal Register line reads "FR Doc. 2026-09289 Filed 5-8-26; 8:45 am".
May 11, 2026
Published in the Federal Register as 91 FR 25479. From this point the document is official and publicly available.
July 10, 2026
Becomes effective. Applies to filings from this date. Also the last day to submit comments on regulations.gov.
Autumn 2026 - 2027
Window for potential federal lawsuits with APA challenges to the IFR. Expect litigation arguing improper notice-and-comment or other procedural defects.
If you want to submit a comment before July 10, 2026
Go to regulations.gov, search docket USCIS-2026-0166. Useful comments cite specific paragraphs and propose changes with justification. Emotional complaints are not effective.
Short summary. What I will watch next in 2026
Open questions about how the situation will develop
- Will AAO non-precedent decisions applying the new regulation appear in summer-autumn 2026 — they will show how officers interpret the boundary between reject and deny in practice
- Will there be federal lawsuits with APA challenges to the IFR — likely following concrete denials where plaintiffs have standing and final agency action
- Will the practices of large corporate law firms (Fragomen, BAL, Ogletree) change regarding signing corporate H-1B packages
- Will USCIS publish separate statistics on the reject:deny ratio after July 10, 2026
- Will myUSCIS add an electronic signature option through attorney portals (currently it does not per IFR)
Related posts on USCIS filing topics
Filing and payment
How to pay for filing petitions O-1, EB-1A, EB-2 NIW at USCIS 2026: G-1450, G-1650, Asylum Fee
Petition for a U.S. visa 2026: should you print in color? USCIS and attorneys’ response with sources
Document translations for USCIS: 10 rules and what attorneys ask unnecessarily
Timelines and Processing
EB-1A Processing Time 2026: I-140 Timeline, Premium Processing, Service Centers
EB-2 NIW Processing Time 2026: I-140 Timeline, Premium Processing, Service Centers
USCIS deadline to adjudicate RFE responses — are there concrete timelines?
RFE and denials
Request For Evidence (RFE) — database of denials when USCIS says “no” (2026)
Responding to a USCIS RFE — is it acceptable if the scanned document cuts off information at the bottom?
Critical role 2026: analysis of 50 RFEs — 80 USCIS officer quotes with breakdown
Categories and strategy
EB-1A vs EB-2 NIW 2026: which green-card path suits you
EB-2 NIW (1) 2026: full guide from eligibility to filing with approved case examples
O-1 visa for citizens of Russia and Belarus 2026
Lawsuits and Final Merits
Mukherji v. Miller update May 15, 2026 — appeal that may remove Final Merits
Mukherji v. Miller three months later — status and USCIS actions
Fear and Loathing in USCIS: EB-1A approval on second filing
Success stories for context
Success stories 2026: 57 EB-1A cases — from denial to approval
Success stories 2026: 45 EB-1A, NIW and O-1 cases — real experience