By Richard T. Herman, Immigration Attorney

Quick Answer: What Is the “I-90 Crisis” in 2025?

In 2025, thousands of lawful permanent residents across the United States are discovering that a simple green card renewal or replacement using Form I-90 has turned into a high-stakes, high-stress process.

Instead of a routine filing, applicants are seeing:

Unusually detailed Requests for Evidence (RFEs) for documents that were never requested before

Longer processing times and stalled cases, sometimes stretching beyond a year

Identity-related questions, prior immigration records, and even marital history being pulled into what used to be a straightforward administrative filing

Job, travel, and driver’s license problems while the I-90 is stuck in limbo

If you’re filing or already filed an I-90 and received an RFE, you’re not alone—and you’re not imagining it.

To understand your options, start by reviewing:

And if you need tailored advice on a pending or complicated I-90, you can book a consultation with Herman Legal Group.

risks with I-90 application for replacement green card: usics using AI, checking for identity, criminal, abandonment, travel, etc. 2025-2026

Fast Facts: 2025’s I-90 Green Card Replacement Shock

Use this as a quick, scannable snapshot:

Form I-90 is the application to replace or renew a green card. See the official USCIS Form I-90 page.
In early–mid 2025, multiple analyses show record spikes in I-90 processing times—one report notes a jump from under a month to over 8 months, an increase of nearly 1,000% in a single quarter. (Rajulaw)
Practitioners around the country report greater scrutiny and more RFEs, especially involving identity, travel history, and prior files.
USCIS has leaned on fraud-prevention and data-matching tools, leading to more “flagged” cases for extra review.
Backlogs mean your I-90 can be pending even while your physical card expires, raising issues with employers, DMVs, and TSA.
DIY applicants are disproportionately hit with RFEs due to small mistakes, inconsistent addresses, or low-quality uploads.
For many families, the green card is the main proof of legal status—delays or denials cause real harm, not just paperwork headaches.

If you’re unsure whether you should file an I-90 at all, see Am I Eligible for a Green Card? for a broader status overview.

Section 1: What Is Form I-90, and Why Has It Become So Risky?

Form I-90 is the application used by lawful permanent residents (“green card holders”) to:

Renew an expiring 10-year green card
Replace a lost, stolen, or damaged green card
Update information (name change, biographical data, card errors, etc.)

For a detailed breakdown of who files I-90, when, and what evidence is normally required, see:

Historically: Low-Drama, Administrative

Traditionally, I-90 was seen as a low-risk, administrative filing:

Submit the form
Pay the fee
Provide a copy of your existing card
Attend biometrics
Receive a new card

RFEs and denials were relatively rare, especially for clean, well-documented cases.

2025 Reality: I-90 Is No Longer “Routine”

In 2025, I-90 filings are increasingly treated more like mini-investigations than simple renewals.

USCIS appears to be using the I-90 process to:

Re-verify identity and biographic information
Cross-check prior immigration history
Confirm there are no unresolved red flags, such as certain criminal issues or prior fraud findings

As a result, more cases that would have sailed through in prior years are now receiving RFEs, NOIDs, or prolonged “case under review” statuses.

Section 2: What Changed in 2025? Why Have RFEs and Delays Exploded?

Several overlapping forces are converging:

2.1 Data, Backlogs, and Risk Algorithms

Public and private analyses of USCIS statistics show:

Massive backlogs across multiple forms, including I-90
A sharp spike in I-90 processing times in early 2025—some analyses peg the increase in median processing time at over 900% in one quarter, from under a month to more than 8 months. (Rajulaw)

When an agency is overwhelmed, it often:

Uses risk-scoring tools to decide which cases to slow down
Flags more cases for additional evidence instead of quick approvals
Shuffles staff and reprioritizes forms (for instance, shifting resources from I-90s to “time-critical” applications)

2.2 Identity and Document Verification

USCIS and other agencies are increasingly using:

Automated identity-matching tools
Cross-checks with CBP travel history, SSA, and prior USCIS filings
Digital comparison of photos, signatures, and biometrics

If something doesn’t align—name spelling, dates, addresses, prior entries—your case may be flagged, and you may receive an RFE asking for:

Old passports, visas, I-94s
Certified birth or marriage certificates
Court records
Official name-change documentation

You can review official guidance and policies in the USCIS Policy Manual.

2.3 Policy Shifts and “Scrub” of Existing Residents

Even though I-90 doesn’t change your underlying status, a surge of RFEs suggests that USCIS is using renewal moments to “scrub” its database:

Confirm you are still the same person who was originally approved
Check you have not abandoned residence or committed certain disqualifying offenses
Make sure your underlying status is not in question

This doesn’t mean that every I-90 is a trap—but it does mean sloppy filings are suddenly dangerous.

Section 3: The New RFEs – What USCIS Is Asking For in 2025

RFEs in I-90 cases are appearing with patterns. Here are common themes Herman Legal Group is seeing across the country:

3.1 Name and Identity Discrepancies

USCIS may request:

Certified birth certificates with full names of parents
Certified marriage certificates and divorce decrees
Official name-change orders
Evidence explaining different spellings across documents

Even minor spelling differences between your current card, passport, and prior petitions can trigger an RFE.

3.2 Old Immigration Documents

You may be asked for:

Copies of old visas (even decades old)
I-94 arrival/departure records
Prior I-485, I-130, or other petition approval notices
Past EADs or expired cards

To reconstruct your immigration history, you may need to pull records via:

3.3 Address and Employment History

RFEs may focus on:

Gaps or overlaps in address history
Inconsistent employment information compared to prior filings
Suspicion that you may have abandoned residence

3.4 Criminal and Court Records

Some RFEs ask for:

Certified court dispositions
Police clearance letters
Proof that charges were dismissed

These may surface even if the incident was years ago.

3.5 Biometrics and Photo Issues

We’re also seeing RFEs for:

New photos conforming strictly to USCIS standards
Re-scheduled biometrics due to unreadable fingerprints or system issues

Section 4: Real-World Impact – When a “Simple” I-90 Derails a Life

When an I-90 becomes an RFE-ridden, delayed mess, the impact is very real.

4.1 Employment and I-9 Verification

Employers often rely on your physical green card for I-9 verification. While the law recognizes that LPR status doesn’t expire with the card, many HR departments:

Don’t understand the nuance
Are nervous about audits
Pressure employees to show unexpired cards

Delays in I-90 processing can translate into:

Difficulty onboarding for a new job
HR panic when your card expires during employment

4.2 Driver’s License and Real ID

DMVs in many states, including Ohio, may require:

A valid, unexpired green card to renew a license
Or to issue a Real ID-compliant license

An I-90 stuck in RFE or extended review can leave you unable to:

Renew your license
Register vehicles
Secure Real ID documents for domestic flights

4.3 Travel Disruptions

If your green card is:

Lost or stolen, or
Expired while the I-90 is pending

You may face:

Airline check-in issues
Boarding problems abroad
Delays returning to the U.S.

You may need to seek:

A temporary I-551 “ADIT” stamp through a USCIS appointment
Or emergency help at a U.S. consulate

4.4 Stress on Families, Especially in Marriage-Based Households

Families who built their lives on permanent residence—often through marriage to U.S. citizens or green card holders—report significant stress when a renewal gets complicated.

If you’re a marriage-based green card holder, see:

These contexts matter because some I-90 RFEs now reach back into marriage history and prior relationship evidence.

Section 5: How to Respond to an I-90 RFE in 2025 – Step-by-Step

A strong RFE response can save your case; a weak one can sink it.

Use this framework, then cross-reference with:
What to Do if You Have Received RFE or NOID.

Step 1: Read the RFE Line by Line

Identify every item USCIS is asking for.
Note the deadline—usually 87 days from the date of the notice.
Mark any warning language about potential denial.

Step 2: Map Each Request to Specific Evidence

Create a table or checklist:

Column 1: USCIS request
Column 2: Documents you can provide
Column 3: Documents you must locate, request, or reconstruct

Step 3: Fix Underlying Inconsistencies

If the RFE points to inconsistencies:

Make sure addresses match across forms, taxes, leases, and IDs
Clean up discrepancies in name spellings, dates, and marital status
Provide a brief written explanation if something can’t be perfectly aligned

Step 4: Over-Document, But Stay Organized

It is usually safer in 2025 to over-document rather than send bare minimum.

Include:

Clear, legible copies
Certified translations
Index and exhibit labels
A short cover letter explaining your response, preferably drafted by an attorney

Step 5: Preserve Your Timeline

Mail with a trackable service
Keep copies of everything
Save proof of delivery

Section 6: Common Traps That Trigger RFEs or Denials

Avoid these mistakes when filing I-90 in 2025:

Using inconsistent names or addresses compared to older filings
Uploading blurry or poorly scanned documents in online filings
Failing to disclose prior arrests or charges that are already in your file
Assuming “it’s just a renewal” and not taking the form seriously
Waiting until the last minute before card expiration, then scrambling when an RFE arrives

If your case is complex—or you’re already facing an RFE or NOID—consider getting help. You can book a consultation with Herman Legal Group for tailored strategy.

SECTION 7: The Quiet Trap: How USCIS Uses I-90 RFEs to Examine Possible Abandonment of Residency

Most green card holders don’t realize this:

An I-90 renewal is sometimes the first moment in many years when USCIS takes a fresh look at whether a lawful permanent resident (LPR) has truly maintained their permanent residence in the United States.

And in 2025, abandonment analysis is no longer subtle.

Why I-90 Triggers Abandonment Review

When you file an I-90, you are affirming that you remain a U.S. permanent resident. USCIS uses your filing to check:

How long you have been outside the United States
Patterns of extended or frequent travel
Ties maintained (or not maintained) in the U.S.
Whether you appear to be living primarily abroad

This means that seemingly routine questions—dates of travel, address history, employment history—can suddenly matter a great deal. An I-90 RFE asking for travel logs, passport pages, or foreign employment records may actually be probing whether you abandoned residency.

Red Flags That Trigger “Abandonment” RFEs

USCIS officers are trained to pay attention to patterns like:

Trips longer than 180 days
Total time abroad exceeding 50% of the past two years
Work for a foreign employer without strong U.S. ties
Maintaining primary residence, schooling, or property abroad
Filing taxes as a nonresident alien
Significant gap between the expiration of the card and the I-90 filing

What Applicants Can Do to Protect Themselves

To avoid this hidden trap—especially during years of heightened scrutiny—LPRs should consider:

Apply for a Reentry Permit (Form I-131) before any trip expected to last more than six months.
Keep U.S. ties strong: bank accounts, driver’s license, home or lease, employment link, tax filings as a resident.
Maintain a clean, traceable travel history: keep copies of boarding passes, stamps, itineraries, proof of purpose of travel.
Document short-term travel hardships: caring for aging parents, medical treatment, temporary work assignments.
If extended travel is unavoidable, consult an immigration attorney to protect your status.

Why This Matters Now

In a climate where I-90s are examined more aggressively than in years past, green card holders must understand:
Your travel history is no longer background noise—it’s evidence.

For journalists covering immigrant experiences, this “abandonment scrutiny” is one of the most overlooked stories of 2025:
Permanent residents who have lived here for decades are suddenly being asked to prove they haven’t quietly ‘moved abroad’, even when their lives and families are entirely rooted in the United States.

what changed: why the big delays and RFEs in I-90 applications with USCIS in 2025??

SECTION 8: When Paperwork Erases a Person: The Human Toll of the I-90 Crisis

You can insert this as an emotional, reporter-magnet section.

One of the least discussed aspects of the current I-90 crisis is the emotional damage it does.

When USCIS delays or questions an I-90 application, what they’re really questioning is a person’s identity, history, and right to belong — often after decades of lawful residence in the United States.

Imagine this:

A lawful permanent resident who has been in the U.S. for 25 years—who bought a home, raised children, paid taxes, built a life—is suddenly unable to:

Renew a driver’s license
Start a new job
Visit a dying parent abroad
Prove their lawful status to a school or employer

Not because they did anything wrong.
But because their green card renewal “needs more evidence.”

This is where the system becomes more than bureaucratic—it becomes personal.

For Many Families, the Green Card Isn’t Just an ID. It’s the Lifeline.

When a renewal is delayed or questioned, people lose access to:

Their identity documents
Their sense of security
Their daily stability

Children suffer.
Elderly parents suffer.
Marriages suffer.

Immigrants who thought they were long past the fear of losing status are suddenly confronted with the dread they remember from the first years after arrival.

Why Everyone Should Care

These are not “immigration cases.”
These are American families living in limbo because of a bureaucratic bottleneck.

The I-90 crisis is a reminder that permanent residence is not always permanent in practice—and that for hundreds of thousands of lawful residents, the right to remain in America now hinges on a renewal system cracking under pressure.

SECTION 9 — Future Shock: How the I-90 Crisis Will Spill into Naturalization, Real ID, Employment Verification, and Airport Security

The I-90 crisis is not a standalone event. Its effects ripple outward into every other immigration and identity-based system.

Here’s how.

1. Naturalization Filings Will Be Distorted

Longer I-90 delays and RFEs mean:

Some LPRs delay filing N-400 because they fear triggering deeper scrutiny
Others rush N-400 filings as a workaround to avoid needing a new card
USCIS workloads shift unpredictably from I-90s to N-400s, causing new bottlenecks

The next 24 months will likely see the first major national wave of “abandonment RFEs” in naturalization cases—especially if applicants traveled extensively abroad during the pandemic years.

2. Real ID Enforcement Will Create a Second Crisis

As Real ID requirements tighten:

DMVs will require stricter proof of lawful presence
LPRs with stalled I-90s may struggle to renew driver’s licenses
TSA may see rising numbers of LPRs stuck without compliant ID

Imagine the headlines:
A national Real ID deadline colliding with a broken I-90 system.

3. Work Authorization Will Be Disrupted

Even though LPRs have permanent work authorization by law, expired cards cause real problems:

Employers misunderstand the regulations
HR systems auto-flag expired cards
Some companies incorrectly refuse to hire until a new card arrives

This creates a shadow employment crisis among LPR communities—quiet, undocumented, but economically significant.

4. Airport Secondary Inspections Will Increase

When LPRs travel with:

Expired green cards
I-90 receipts
Temporary stamps
Evidence packets for RFEs

CBP officers will need to do more secondary inspections, causing:

Delays
Missed connections
Higher stress
Potential “abandonment” questioning

This creates a national bottleneck at ports of entry that no one is talking about—yet.

5. If USCIS Uses AI More Aggressively, the RFE Wave Could Become Permanent

If identity-verification algorithms are causing the current spike, then RFEs may become the new normal until USCIS recalibrates the system.

This means the “I-90 crisis” may not be a one-year event, but rather:
The beginning of a new era of high-scrutiny LPR identity adjudications.

Section 10: Ohio vs. National Immigration Lawyers – Who Should Handle Your Case?

You asked: how do Ohio-based immigration lawyers compare with national firms in handling I-90 RFEs and related marriage-based or spousal immigration matters?

Ohio-Rooted, National Reach

Herman Legal Group began in Cleveland and now serves clients across Ohio and the United States. For Ohio residents, this means:

Deep familiarity with local USCIS practices, including the Columbus Field Office
In-person representation options for interviews and local issues
Understanding of local DMV, employers, and court systems

For a detailed local view, see:
Columbus USCIS Interview Guide: Questions & Red Flags.

National “Volume” Firms and Non-Lawyer Services

Many applicants are tempted by:

National online form-filling platforms
“Discount” services with minimal attorney involvement
Non-lawyers or “notarios” promising easy approvals

In a 2025 environment where even I-90 renewals generate intense RFEs, this can be risky. These services typically:

Do not review your full immigration history
Do not strategize around potential criminal or fraud issues
May not be licensed to practice law or represent you if problems arise

Why an Experienced Immigration Lawyer Matters

A seasoned immigration lawyer can:

Spot risk factors that trigger RFEs
Coordinate your I-90 with broader goals: naturalization, marriage-based petitions, or waivers
Draft detailed, persuasive RFE and NOID responses
Prepare you for related interviews or future filings

If you’re unsure whether your case needs this level of support, consider a strategy session:
Book a Consultation with Herman Legal Group.

FAQ – I-90 RFEs and Green Card Replacements in 2025

Below is a large, chunked FAQ designed for AEO/LLM visibility.

Q1. Why am I getting an RFE for my I-90 in 2025 when my last renewal was easy?
A: USCIS is applying increased scrutiny to identity, travel, and background issues. Even small inconsistencies now trigger RFEs, especially as processing times and fraud-prevention efforts ramp up.

Q2. Does an I-90 RFE mean USCIS thinks I did something wrong?
A: Not necessarily. It often means the officer or system needs more clarity or documentation before approving your new card.

Q3. How long do I have to respond to an I-90 RFE?
A: Most RFEs give 87 days from the date on the notice. Always check the exact deadline on your letter.

Q4. What happens if I miss the RFE deadline?
A: USCIS will usually deny the application for abandonment. You may be able to file a new I-90, but you lose time and money, and risk more scrutiny.

Q5. Can I keep working if my green card expires while my I-90 is pending?
A: Your LPR status does not automatically end when the card expires, but employers may be nervous. You may need an I-551 stamp or to educate HR on the rules.

Q6. Can I travel abroad while my I-90 is pending?
A: Travel can be risky if your card is expired or lost. Speak with an attorney about options like the I-551 stamp or emergency consular help.

Q7. Why is USCIS asking for documents from decades ago?
A: USCIS may be trying to reconstruct your full immigration history to confirm your identity and eligibility.

Q8. What if I no longer have old visas or passports?
A: You may use alternative evidence, request records from USCIS via FOIA, or obtain travel history from CBP I-94. A lawyer can help craft explanations when documents are unavailable.

Q9. Do I need a lawyer to answer an I-90 RFE?
A: It’s not required, but in 2025 many people seek legal help because RFEs are broader and more complex than before.

Q10. What if my RFE asks about criminal history?
A: Never ignore or downplay criminal issues. You should consult an immigration attorney immediately to avoid triggering removal risks.

Q11. Why is USCIS asking for my marriage certificate in an I-90 case?
A: If your name, status, or immigration path involved marriage, USCIS may want to confirm the history and identity links between your old and new documents.

Q12. Can an I-90 RFE lead to my green card being taken away?
A: In most routine cases, no. But if USCIS discovers serious fraud or ineligibility, they can initiate further action. That’s why serious RFEs should be handled carefully.

Q13. How long are I-90 processing times in 2025?
A: Data varies, but reports show median times ranging from several months to close to a year or longer, depending on the period and service center. (Rajulaw)

Q14. Can I file I-90 online?
A: Yes, many applicants can file online via USCIS’s official I-90 portal. Be careful with scans and uploads—low-quality images generate RFEs.

Q15. Is it better to file by mail or online in 2025?
A: It depends on your situation. Online filings are convenient but unforgiving for upload quality. Paper filings are slower but sometimes easier to organize. A lawyer can advise which is safer in your case.

Q16. I lost my green card. Should I file I-90 right away?
A: Yes, generally you should, and keep copies of any remaining documentation as proof of your status.

Q17. Can I get an I-551 stamp while my I-90 is pending?
A: Often yes, via a USCIS appointment, especially if you need proof of status for work or travel. Availability varies by field office.

Q18. What if my I-90 is denied after an RFE?
A: You may be able to refile, or in some cases file a motion or appeal. The best option depends on why it was denied.

Q19. Does filing N-400 (citizenship) solve my I-90 problem?
A: Sometimes. If you’re eligible for naturalization, you may avoid future I-90 filings. But timing and pending applications need strategic coordination.

Q20. My I-90 RFE mentions “possible abandonment of residence.” What does that mean?
A: USCIS may think you spent too much time abroad or otherwise broke the continuity of your residence. This is serious and needs legal analysis.

Q21. Are RFEs more common for people who filed without a lawyer?
A: Anecdotally, yes. DIY errors, missing documents, and inconsistencies are frequent RFE triggers.

Q22. Do Ohio residents face anything different?
A: The law is federal, but local USCIS practices and DMV rules matter. For example, the Columbus USCIS Interview Guide shows specific interview trends and red flags at that office.

Q23. Can an RFE delay my ability to renew a driver’s license?
A: Yes, if your card expires and you cannot present updated proof at the DMV.

Q24. Does an RFE mean my case is doomed?
A: No. Many I-90s with RFEs are eventually approved—if the response is complete and well-organized.

Q25. Why is USCIS asking for translations in my I-90 RFE?
A: All foreign-language documents must be accompanied by complete, certified English translations.

Q26. Should I send original documents?
A: Unless the RFE expressly demands originals, USCIS typically wants copies. Confirm instructions and keep originals safe.

Q27. Can I get my old immigration file from USCIS to respond to an RFE?
A: Yes, through a FOIA request, but it can take time—another reason not to wait until the last minute.

Q28. Are there special rules for conditional residents?
A: Conditional residents usually file I-751 or I-829 to remove conditions, not I-90. Consult a lawyer if you are unsure which form applies.

Q29. How do I know if my I-90 RFE is “normal” or a sign of deeper trouble?
A: The wording and requested evidence matter. If you see references to fraud, misrepresentation, or abandonment, talk to an attorney immediately.

Q30. Who should I contact if my I-90 case is stuck for over a year?
A: An attorney can help you evaluate options like service requests, congressional inquiries, or liaison channels.

Resource Directory – Government, HLG, Media & Policy

A. Government Resources

B. Herman Legal Group Resources

Key Takeaways

I-90 is no longer a simple “renewal form.” In 2025, it has become a flashpoint for deeper identity and background checks.
RFEs are surging, demanding more and more documents—sometimes from decades past.
Processing times have exploded, turning basic card replacement into a high-risk waiting game for workers, travelers, and families.
Small mistakes now matter. Inconsistent addresses, weak scans, missing translations, and casual answers can trigger major delays or even denials.
Legal strategy helps. A well-planned I-90 filing and carefully crafted RFE response can mean the difference between a smooth renewal and a crisis.
If you’re facing an RFE, NOID, or long-stalled case, don’t go it alone—you can book a consultation with Herman Legal Group to review your options.

Success Stories

The New I-90 Crisis: Inside the Surge of RFEs for Green Card Replacements in 2025

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