U.S. CBP Biometric Entry and Exit Rule: What Business Aviation Operators Need to Know

Recent announcements regarding U.S. Customs and Border Protection’s biometric entry and exit program have created confusion within the business aviation community. In particular, the December 26, 2025 effective date has been widely misunderstood as an immediate implementation deadline for biometric collection at U.S. airports.

CBP has since clarified that this interpretation is incorrect.

This article explains what the final rule does and does not do, how it applies to General Aviation, and what business aviation operators should expect moving forward.

What Changed on December 26, 2025

On December 26, 2025, CBP received legal authorization under a final rule titled Collection of Biometric Data from Aliens Upon Entry to and Departure from the United States. This authorization allows CBP to collect biometric data from foreign nationals entering or exiting the United States.

However, December 26, 2025 is not an implementation date.

CBP has confirmed that the effective date represents a regulatory milestone only. It does not trigger immediate biometric collection requirements for General Aviation or business aviation operations.

CBP Clarification for General Aviation

CBP has explicitly stated that it has not yet determined how or when biometric entry or exit requirements will be implemented for General Aviation, including private and business aviation operations.

CBP further clarified to Universal’s Regulatory Services team that any future rollout will be formally announced through the Federal Register and will include an opportunity for public comment:

“When CBP moves forward with a large-scale implementation of biometric entry-exit for vehicles at land ports and private aircraft or biometric exit at pedestrian land or sea ports, CBP will publish a notice in the Federal Register with information regarding details of implementation and request comments on the newly implemented transportation modalities.”

Until such notice is published, no biometric implementation procedures apply to General Aviation, and GA flights should continue to operate under existing CBP clearance processes.

What Business Aviation Operators Do Not Need to Do Right Now

Despite early speculation, business aviation operators are not required to take any immediate action related to biometric entry or exit collection.

Specifically:

• No mandatory facial scanning for GA passengers or crew

• No new biometric equipment requirements at FBOs

• No changes to GA arrival or departure clearance procedures

• No enforcement actions tied to biometric collection for GA flights

Absent published CBP implementation guidance, there is no operational change for General Aviation.

Why There Has Been Confusion

The confusion largely stems from misunderstanding the difference between a rule’s effective date and its operational rollout.

The biometric entry and exit rule applies broadly across multiple travel modes, including commercial aviation, land border traffic, maritime operations, pedestrian exits, and General Aviation. However, CBP has acknowledged that each mode requires separate implementation planning.

For General Aviation in particular, CBP has not yet established procedures, technology requirements, or enforcement mechanisms.

Separate Proposal: ESTA and I-94 Modernization

Separately, CBP has proposed updates to ESTA and I-94 processes that would further digitize traveler identity verification and exit tracking. These proposals were published in the Federal Register on December 10, 2025 and remain under review.

Key points for operators:

• These proposals are not final

• Public comments are open through February 9, 2026

• No operational changes are currently in effect for business aviation

These proposed changes should not be confused with the biometric entry and exit final rule.

Operational Guidance for Business Aviation

At this time, business aviation operators should:

• Continue standard CBP arrival and departure procedures

• Avoid making operational changes based on unannounced biometric requirements

• Monitor Federal Register notices for GA-specific CBP guidance

• Treat December 26, 2025 as a policy authorization date, not an enforcement deadline

Bottom Line

CBP now has authority to collect biometric entry and exit data, but no biometric procedures have been implemented for General Aviation. No timeline, enforcement process, or operational requirements have been announced for business aviation.

Until CBP publishes GA-specific implementation guidance in the Federal Register, General Aviation flights should continue to operate as usual.

Universal will continue monitoring CBP announcements and Federal Register activity and will provide updates as soon as implementation details for General Aviation are released.