US CBP biometrics: BizAv rollout still unclear

Update Jan 2026

Universal is reporting a clarification from US CBP that the widely cited 26 Dec 2025 date is not an implementation deadline for General Aviation. Although CBP now has legal authority to collect biometric entry and exit data from non-US citizens, it has not yet defined how this will work for GA/BizAv, and no operational rollout has been announced. Until CBP publishes specific guidance in the Federal Register, GA/BizAv operations will carry on as they did before! (Much of the confusion around this has come from treating the rule’s effective date as if it were an enforcement date – which is isn’t, apparently).

What’s changing

From 26 Dec 2025, a rule takes effect that authorises facial biometric collection for all non-US pax and crew entering or exiting the US, across all modes of travel, including Business Aviation. This is a legal change, not an operational one. The rule removes previous limitations on who CBP may collect biometrics from, including exemptions that applied to certain nationalities and categories such as many Canadian nationals and diplomats.

What’s actually new

CBP has been collecting biometric data on entry for years, and biometric exit already exists for airline flights at many commercial airports. What’s new here is the scope of the authority, not the process. The rule makes biometric entry and exit a nationwide requirement in law for all non-US nationals, regardless of how they travel, but CBP has not yet decided how that authority will be applied to General Aviation. For BizAv in particular, the unanswered question remains departure, where biometric exit has not previously been routine.

Airport reality and BizAv impact

Biometrics are already used at many large commercial airports, often via CBP mobile devices, and in some cases officers already capture facial images onboard aircraft. However, there is still no published airport-level or FBO-level guidance describing how this would be handled for BizAv, and no standard process has been defined. CBP has confirmed it does not yet have details on GA implementation, so some inconsistency by airport is likely once a rollout eventually begins.

What operators should do now

For now, do not treat 26 Dec 2025 as an enforcement deadline for BizAv. No immediate operational changes are required. Continue normal CBP arrival and departure procedures and avoid making assumptions about mandatory facial scanning until GA-specific guidance is formally published.

Separate proposal: ESTA changes under review

CBP has published a separate proposal to significantly change how the ESTA works for non US travellers. These changes are not final and are open for public comment until 9 Feb 2026. You can check the official proposal here, and send an email to CBP_PRA@cbp.dhs.gov if you want to submit any comments.

If adopted, ESTA would become far more app based and data heavy. That may be billed as modernisation, but for BizAv it likely means more steps, not fewer.

Proposals include a mobile app only ESTA, mandatory live selfies, and a big expansion in the personal info travellers must provide. That includes several years of social media history, along with phone numbers, emails, and family and business contacts. Yes, they really want the socials!

There is also a proposal to let travellers confirm their departure via a CBP app using a selfie and location data. That would help CBP close long standing exit gaps, but it sounds like it wouldn’t remove any existing operator admin.

Bottom line, these are proposals, not requirements. If adopted, ESTA would shift more work onto individual travellers and add new “failure points” to pre-trip planning. Expect more chasing pax for app downloads, selfies, and old social accounts. Yay! 😁

US CBP biometrics: BizAv rollout still unclear