The United States Citizenship and Immigration Services (USCIS) published a notice in the Federal Register this Friday to create the new form I-936, titled "Request for Waiver of Electronic Filing Requirement," which will allow applicants for immigration benefits to request authorization to continue submitting their applications in paper form when online submission poses an undue hardship.
The notice, identified as FR Doc. 2026-22139 (USCIS-2026-0463), opens a 30-day period for public comments under the Paperwork Reduction Act.
The deadline is November 30, and until the Office of Management and Budget (OMB) approves the form, it will not be available to the public.
The I-936 is the missing piece in the digitization process that USCIS initiated in August 2026 with a final interim rule on mandatory electronic filing, which received only five comments during its 60-day period.
Este formulario podría afectar a miles de cubanos que gestionan sus trámites migratorios en EE.UU. Sigue todos los detalles sobre visas, USCIS y procesos de inmigración en nuestra sección de
The agency will use the I-936 to decide, on a discretionary basis, whether an applicant or beneficiary can submit an immigration application in paper form.
According to the official notice, "USCIS will consider all relevant evidence provided by the applicant, such as geographic location, socioeconomic conditions, and the availability of public technological resources."
However, the document issues a key warning: being unfamiliar with the USCIS online system or lacking a registered account "generally will not be sufficient to demonstrate that the applicant qualifies for a waiver."
Anyone who does not have personal access to the Internet must also explain why they cannot connect through alternatives such as public libraries, community centers, friends, or family.
This requirement is especially relevant for thousands of Cubans in South Florida. The average age of Cuban immigrants in the United States is 55 years, compared to 47 years for other groups, according to the Migration Policy Institute.
In the city of Miami, 32.2% of households do not have an Internet subscription, and in Miami-Dade, that percentage is around 20.5%.
Many of those Cubans process forms such as the I-485 (permanent residency), the I-765 (work permit), or the I-131 (travel document) without a computer, stable connection, or online account.
There are practical details that should be clear. The I-936 must be submitted and approved before filing the main application on paper; it cannot be submitted retroactively along with the benefit application.
A separate form is required for each immigration procedure to be submitted on paper, and one for each applicant. The approval is valid for 30 days from the date of issuance.
USCIS estimates that approximately 248,905 individuals will submit the I-936 each year, with a burden of 30 minutes per application, resulting in an annual total cost of $6,094,493.
While the application form is not approved, the practical recommendation is to open an account on myUSCIS and seek guidance from accredited organizations such as Catholic Legal Services, Church World Service Florida, or the pro bono project of the Cuban American Bar Association (CABA).
It is essential not to pay unlicensed intermediaries.
Digitalization arrives at a time of new USCIS fees that came into effect on October 16, which raised the parole fee to $1,050 and the initial work permit to $570, with no possibility of waiver. Those in need of guidance on can consult the online resources available before making any decisions.
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