For most attorney-filed USCIS cases in 2026, online filing through a USCIS representative account is the stronger default — it eliminates the edition-date risk and the paper-signature trap that, since July 10, 2026, can turn a technical defect into a full denial with no refund.
This post breaks down exactly when G-28 can be filed online versus on paper, what the USCIS online representative account workflow looks like, where paper filing is still necessary, and how the 2026 signature rule (8 CFR 103.2(a)(7)) changes the stakes for anyone still mailing a printed form.
What does Form G-28 actually do, and who needs to file it?
An attorney or accredited representative must submit Form G-28, Notice of Entry of Appearance as Attorney or Accredited Representative, to establish eligibility to represent a client in an immigration matter before USCIS. The form does two things: it proves the representative is eligible to appear, and it tells USCIS where to send notices. Without a properly filed G-28, USCIS communicates directly with the applicant — not their lawyer.
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If a benefit requestor is represented by an attorney or accredited representative, the record must contain a valid Form G-28 (or Form G-28I for matters outside the U.S.). The purpose of these forms is to establish the eligibility of the attorney or accredited representative to appear and to maintain a clear record of with whom communication is authorized. That authorization covers USCIS, CBP, and ICE — all three DHS immigration agencies.
USCIS only recognizes one notice of entry of appearance at a time. An attorney or accredited representative may file a notice of entry of appearance at any stage in the proceedings. A separate notice of entry of appearance must be submitted for each case in which the attorney or accredited representative seeks to appear. This matters for volume filers: there's no blanket G-28 that covers a client's multiple pending petitions.
For matters before the Board of Immigration Appeals (BIA), use Form EOIR-27 instead of Form G-28. G-28 is a USCIS/DHS form only. Filing it with an immigration court or the BIA is the wrong form entirely.
When can G-28 be filed online, and how does that workflow actually work?
File Form G-28 with the related application, petition, motion, or appeal — in your USCIS online account or by mail. Online: To file a form online on behalf of your client, along with Form G-28, you must first create a USCIS online account. The representative account and the client account are separate — the representative should not log in to the client's personal account.
In many representative-filed workflows, the lawyer and client do not use the same USCIS account. The lawyer prepares the case through a representative or organizational account. USCIS then generates a one-time representative passcode or electronic invitation. The client must use a separate personal or company account to review the draft, authorize Form G-28, and complete the required client-side signature or attestation. After the client returns the approved filing, the representative can complete the remaining payment and submission steps.
Online filing also covers subsequent appearances on already-pending cases. You can submit subsequent Forms G-28 online for certain pending forms. In your USCIS representative online account, navigate to File a Form, and choose Form G-28 in the dropdown. This is useful when a client switches counsel mid-case or when a firm needs to add a supervising attorney to the record after initial filing.
If a client asks you to represent them on a case they previously filed online for themselves, you can also file a separate G-28 online for that case. Likewise, if you filed by paper before, your old case will not show up in a new account on its own — you can link it using the online access code printed on a notice USCIS mailed you.
When must G-28 still be filed on paper?
Online filing of G-28 is only available when the underlying benefit request is also eligible for online filing. If the main form — I-485, I-130 filed by a petitioner without an online-eligible category, or any other form not yet available online — must go by mail, the G-28 goes in the same paper package. File Form G-28 with the related application, petition, or appeal. It is not a standalone filing. Filing on paper? Include the signed Form G-28 in the same package as your main case.
Subsequent paper filings on pending mailed cases also stay on paper in many situations. If you are mailing a subsequent Form G-28 related to the same matter or form, mail it to the office where your case is pending, or to the return address of the last notice you received. USCIS's filing instructions also specify writing "ATTN: G-28" on the mailing envelope and including the receipt number to ensure the form gets matched to the correct file.
The mandatory e-filing landscape is shifting. A new DHS interim final rule lets USCIS require electronic filing for any immigration form that has been available to file online for at least 180 days. The rule takes effect August 11, 2026. USCIS will post at least 60 days' notice on its website before a form becomes online-only, and people who cannot file online can ask for a hardship waiver. No G-28-specific mandatory e-filing notice has been published as of September 1, 2026 — but check uscis.gov before mailing.
Online vs. paper: which channel has fewer rejection traps?
The comparison below captures the most operationally significant differences between the two filing channels for G-28 in 2026.
| Issue | Online Filing | Paper Filing |
|---|---|---|
| Edition date risk | None — USCIS account always uses the current version | High — wrong edition triggers rejection; currently accepted: 09/17/18 and 05/23/18 |
| Signature risk (post-July 10, 2026) | Low — electronic signature valid only when captured through USCIS online account | High — invalid paper signature (typed name, DocuSign, stamp) can result in denial, fee forfeiture, no cure |
| Missing-page risk | None — system prevents incomplete submissions | Real — mixed editions or missing pages cause rejection |
| Receipt / confirmation | Instant electronic confirmation | Mailed receipt notice; delay possible |
| Availability | Only when the underlying form is online-eligible | Always available for paper-filed underlying forms |
| Client authorization step | Client must have/create their own USCIS account and authorize representative via invite | Client signs paper form; photocopy/scan/fax of original handwritten signature is valid |
| Eligible for subsequent appearances on pending cases | Yes, for certain pending online-eligible forms | Yes, mail to office where case is pending |
What counts as a valid signature on a paper G-28 in 2026?
The 2026 signature rule is the single biggest operational change affecting paper filers this year. On May 11, 2026, the Department of Homeland Security published an interim final rule (91 FR 25479) amending 8 CFR 103.2(a)(7)(ii)(A). Effective July 10, 2026, USCIS can deny a petition or application discovered to have an invalid signature after intake acceptance, retain the filing fee, and offer no opportunity to correct the signature on the existing filing.
The practical difference between rejection and denial is significant. A rejection means the filing fee is returned and the petitioner may refile the case. A denial means the filing fee is retained, the case is treated as fully adjudicated against the petitioner, and the only path forward is either an appeal on Form I-290B or a new filing with a new fee. Under the new rule, that choice belongs to the USCIS adjudicator. There is no cure mechanism.
For Form G-28 specifically: USCIS will consider a photocopied, faxed, or scanned copy of the original handwritten signature valid for filing purposes. That means a wet-ink signature scanned and emailed to the representative before filing is acceptable on paper. What is not acceptable: many common modern signing methods are strictly prohibited for paper-based USCIS filings. Using any of these after July 10, 2026, puts your application at risk of immediate denial: typed names (e.g., "/s/ Jane Doe") are not a signature; and unless you are using the specific USCIS-authorized online filing system, you cannot use DocuSign, Adobe Sign, or other digital signature software on paper forms.
One important carve-out: a Form G-28 by itself does not authorize a representative to sign a request or other document on behalf of a person or legal entity. Further, an attorney or representative may not use a POA to sign a Form G-28 on behalf of a person or legal entity to authorize his or her own appearance. Both the attorney and the client must personally sign.
What does the USCIS Policy Manual say about representation and G-28?
The governing Policy Manual chapter is USCIS Policy Manual, Volume 1, Part D, Chapter 4 — Establishing and Changing Representation. It confirms the core rule: if a benefit requestor is represented by an attorney or accredited representative, the record must contain a valid Notice of Entry of Appearance as Attorney or Accredited Representative (Form G-28) or a Notice of Entry of Appearance as Attorney in Matters Outside the Geographical Confines of the United States (Form G-28I).
The signature requirements that now carry denial consequences are addressed in USCIS Policy Manual, Volume 1, Part B, Chapter 2 — Signatures, updated July 10, 2026 pursuant to Policy Alert PA-2026-03. DHS published an interim final rule on May 11, 2026, to clarify USCIS procedures relating to the rejection or denial of benefit requests that do not meet regulatory requirements to ensure better enforcement of signature requirements. The Policy Manual update also covers revisions to Section A (Signature Requirement) throughout, and revisions to the second paragraph and table in Section B (Valid Signature).
One procedural note that catches law-school clinic filers: law students and law graduates may not submit their own Form G-28. Instead, their supervising attorney or accredited representative must file Form G-28. The supervising attorney or accredited representative should list the law student or law graduate on the Form G-28 according to the form instructions, and both the attorney or accredited representative and the law student or law graduate must sign the Form G-28.
What's the current edition date for paper G-28, and what happens if you use the wrong one?
The current accepted paper editions are 09/17/18. USCIS will publish a new edition soon. In the meantime, you may continue using the 09/17/18 and 05/23/18 editions despite the expiration date. Edition dates are printed at the bottom of each page in mm/dd/yy format — check every single page, because USCIS rejects mixed-edition packets.
If you complete and print this form to mail it, make sure that the form edition date and page numbers are visible at the bottom of all pages and that all pages are from the same form edition. If any of the form's pages are missing or are from a different form edition, USCIS may reject your form. This is a hard rejection — not something USCIS will overlook.
If you do not properly complete your Form G-28, USCIS will not accept it. This means USCIS will process the benefit request as if you did not submit Form G-28. The underlying petition continues, but the representative is invisible to USCIS — notices go only to the applicant, RFE deadlines pass without the attorney seeing them, and the entire purpose of filing the G-28 is defeated.
Note: A new G-28 edition is expected from USCIS. Always download the form directly from uscis.gov/g-28 immediately before preparing a filing, never from a saved local copy.
About FormGuard: We help immigrants, sponsors and the practices that represent them check USCIS forms for filing errors before submission. We publish guides on USCIS forms, edition dates, RFEs, and processing times, updated as USCIS policy changes.
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Frequently asked questions
Can I file Form G-28 by itself, without attaching it to any other form?
No. Form G-28 is not a standalone filing — it must be submitted with the related application, petition, motion, or appeal, either online or by mail. If you need to enter an appearance on a case that is already pending with USCIS, you can file a subsequent G-28 online through your USCIS representative account (for online-eligible forms) or mail it to the office where the case is pending, including the receipt number on the envelope. USCIS's instruction to write "ATTN: G-28" on the mailing envelope is a practical tip worth following, since USCIS receives thousands of filings weekly and needs to match the form to the correct file. Without the receipt number and proper addressing, the form risks being processed without connection to the pending case.
What happens to my case if USCIS rejects or does not accept Form G-28?
If the G-28 is not properly completed, USCIS will process the underlying benefit request as if no G-28 was ever submitted. That means USCIS sends all correspondence — RFE notices, interview notices, approvals, and denials — directly to the applicant rather than to the attorney of record. In a high-volume practice, this creates serious case-management risk because attorneys may miss response deadlines entirely. If the G-28 is also rejected for an edition-date error or missing pages, the form does not get attached to the case. Filing a corrected G-28 promptly with the receipt number and correct edition is the fix, but you cannot retroactively receive notices already sent.
My client signed the G-28 using DocuSign. Is that valid for a paper-filed case?
No. Under the interim final rule that took effect July 10, 2026 (amending 8 CFR 103.2(a)(7)), DocuSign and other electronic-signature software outputs are not valid on paper-filed USCIS forms. The only valid signatures for paper filings are original handwritten (wet-ink) signatures, or photocopies, scans, or faxes of an original handwritten signature. Electronic signatures are valid only when the client completes their authorization through a USCIS online account. A paper G-28 bearing a DocuSign output — even one that looks like a handwritten signature — can now result in a denial at the adjudication stage, with the filing fee retained and no opportunity to refile on the existing case.
Does each attorney in a firm need to file their own G-28, or does one G-28 cover the whole firm?
Each attorney or accredited representative appearing in a case must submit their own Form G-28. USCIS only recognizes one notice of entry of appearance at a time per case. If a supervising attorney and a law student or law graduate are appearing together, the supervising attorney files the G-28 and lists the law student or graduate in the appropriate section — the law student cannot file their own G-28 independently. When representation changes (for example, a new attorney takes over a case), a new G-28 is filed and replaces the prior attorney of record. At that point, USCIS will direct all communications to the newly entered representative.