More face scans at the US border: BizAv now included

Mandatory facial recognition for all non-US citizens entering or exiting the US remains on track for 26 Dec 2025. BizAv is included, but CBP has not yet defined how it will be implemented, and the actual operational roll out may take some time.

What’s changing

From 26 Dec 2025, CBP can require facial biometrics for all foreign passengers and crew at both arrival and departure, at all US airports, including those on BizAv flights. You can see the official rule here.

Previous exemptions are removed, including for most Canadian nationals and diplomats. Facial scanning will no longer be limited to selected categories or locations.

What’s actually new

CBP has collected entry biometrics for years, and exit biometrics already exist for airline flights.

What’s new is the scope. This rule makes biometrics a nationwide requirement, removes exemptions, and extends biometric collection to BizAv, including at departure from the US. This closes long standing exit data gaps in private aviation.

Airport reality and BizAv impact

Biometrics are already used at many large commercial airports, often with CBP mobile devices. We still haven’t seen any new airport or FBO level guidance for BizAv, and no standard process has been published.

CBP has confirmed BizAv is included but says it does not yet have details on how this will be implemented. So expect some inconsistent application by airport in the early phase!

For now, assume facial scanning applies, allow extra time on the ground, and check locally with the FBO or CBP at the airport level as to exactly what to expect on arrival and departure.

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! 😁

More face scans at the US border: BizAv now included