An RFE on a Form I-90 Application to Replace Permanent Resident Card almost always traces back to one of six specific problems — and since August 5, 2026, USCIS can skip the RFE entirely and deny your application outright if required initial evidence is missing.
This post walks through a realistic scenario — a lawful permanent resident renewing an expiring 10-year card — and maps every decision point where an officer might issue an RFE or, under current USCIS policy, simply deny. We also cover the signature rules that changed in July 2026, the filing-reason mismatch trap, and what the I-90 instructions actually require at each step.
The Scenario
Hypothetical (clearly labeled): Ana is a lawful permanent resident who received her 10-year green card in 2016. Her card expires in four months. She downloads the I-90, fills it out at home, has her employer's HR coordinator print and sign it for her as a convenience, and mails it with a personal check. This scenario is used throughout the post to show how RFE triggers stack.
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Ana's scenario is not unusual. LPRs use the Application to Replace Permanent Resident Card (Form I-90) to request that USCIS replace their Permanent Resident Card. What trips people up isn't the concept — it's the operational details that determine whether an officer can approve on the initial record or has to stop and ask for more.
Trigger 1: Filing-Reason Mismatch in Part 2
Part 2 of the I-90 asks the applicant to select the reason for filing. You select the reason in Part 2 that matches why you need a new green card. Reasons include an expired or expiring card, a lost or stolen card, a damaged card, incorrect information, or a legal change to your information. The filing reason affects the evidence and requirements.
Selecting the wrong reason is one of the most reliable ways to generate an RFE — or worse. If Ana checks "lost or stolen" when her card is actually expiring, USCIS will expect identity documents that substitute for a physical card she claims not to have, and may request them when the application doesn't add up. Conversely, if she checks "expiring" but the card already expired more than six months ago, the facts on the form won't match the card date. Select the reason that accurately matches the facts. Choosing the wrong reason can affect both the evidence required and the applicable fee.
Trigger 2: Missing or Insufficient Supporting Evidence
Each filing reason in Part 2 comes with its own required-evidence list in the I-90 instructions. When you file your application, you must submit all evidence and supporting documents listed in the Specific Instructions sections of the I-90 Instructions. Missing even a single required document gives an officer grounds to issue an RFE — or, under the policy effective August 5, 2026, to deny without one.
The evidence requirements vary by scenario:
| Filing Reason (Part 2) | Key Evidence Required by Instructions | Common RFE Trigger |
|---|---|---|
| Expiring/expired 10-year card | Copy of existing card (front and back) | No copy of card submitted |
| Lost, stolen, or destroyed card | Copy of card if available; if 18+, government-issued photo ID if no card copy | No identity document when card unavailable and applicant is 18+ |
| Name change (applicant error) | Legal name-change document (marriage certificate, court order, divorce decree) | No certified legal document; uncertified translation of foreign-language document |
| Commuter taking up U.S. residence | Evidence of U.S. residence (lease, deed, utility bills) | Insufficient or undated residence proof |
| Card never received | Copy of I-797 for the I-485 or I-90 that should have produced the card | No receipt notice submitted; card actually delivered but applicant lost it (wrong box checked) |
Failure to provide required information, and any requested evidence, may delay a final decision or result in denial of your Form I-90. That language has been in the I-90 instructions for years. What changed in 2026 is how quickly USCIS will act on it.
One common documentation gap: foreign-language documents. Any foreign-language document must be accompanied by a full English translation that the translator has certified as complete and correct, and by the translator's certification that they are competent to translate the foreign language. A marriage certificate in Spanish submitted without a certified translation is a straightforward RFE trigger.
Trigger 3: Invalid Signature — Now a Denial Risk, Not Just a Rejection
This is the most consequential change in 2026 for I-90 filers. In Ana's scenario, her HR coordinator signed the form on her behalf as a convenience. That is an invalid signature — and under the DHS interim final rule amending 8 CFR 103.2(a)(7), effective July 10, 2026, it can get her application denied, not just rejected and returned.
Under the rule (Federal Register, 2026-09289), only a handwritten ink signature — or a scan, photocopy, or fax of one — is valid on a paper-filed I-90. Typed names, cursive fonts, stamps, and e-signature software outputs such as DocuSign are not valid on paper. Electronic signatures are valid only when captured through a USCIS online account during online filing. The rule specifies that an invalid signature on a paper-filed benefit request can result in denial — USCIS keeps the filing fee and there is no opportunity to cure. Forms N-600 and N-600K are the only two exempt from the denial consequence (those remain reject-only for a signature defect). The I-90 is not exempt.
The practical message: if you or your client is filing on paper, the applicant must sign in their own handwritten ink. No exceptions. If filing online through a USCIS account, the electronic signature captured in the portal is valid.
Trigger 4: Wrong Fee or Wrong Form Edition
A wrong fee and a wrong edition date are both rejection triggers — and a rejection resets the clock on an already-slow caseload. The current edition date for Form I-90 is 01/20/25 , per the official USCIS I-90 page. If you complete and print this form to mail it, make sure 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.
The current government filing fee is $415 for an online Form I-90 or $465 for a paper application in most fee-paying cases. Always verify the current fee on the USCIS Form G-1055 fee schedule before filing — fees have changed multiple times in recent years. A personal check from Ana's scenario is an acceptable payment method for paper filings, but the amount must be exact.
Trigger 5: Status Issues That Surface During Adjudication (The "Deeper" RFE)
Most I-90 RFEs are about missing documents. But a subset of cases attract RFEs — or, under current policy, NOIDs — that go beyond the checklist. These arise when an officer's review of the application raises questions about the applicant's underlying LPR status.
The USCIS Policy Manual, Volume 11, Part B, Chapter 2, governs the adjudication of replacement card requests and sets out the eligibility framework officers use. Under that framework, an officer adjudicating an I-90 must confirm the applicant is still a lawful permanent resident. Common causes of I-90 denial include insufficient evidence, failure to respond to an RFE, or USCIS determining you're no longer eligible for permanent residence.
Indicators that can prompt deeper scrutiny include: extended absences abroad that may raise abandonment questions, a "yes" answer to the abandonment question in Part 3, or biographic information that doesn't match USCIS records. Some I-90 RFEs now reach back into marriage history and prior relationship evidence. If the language in an RFE references fraud, misrepresentation, or abandonment, the case has moved beyond a paperwork fix.
The 2026 Policy Shift: RFEs Are No Longer Guaranteed
Before August 5, 2026, USCIS policy generally required officers to issue an RFE or NOID before denying a case where evidence was missing. That safety net is gone. USCIS on August 5, 2026 issued Policy Alert PA-2026-05, which clarifies that USCIS, in its discretion, may deny immigration benefit requests that lack required initial evidence or otherwise fail to establish eligibility without first issuing a Request for Evidence (RFE) or Notice of Intent to Deny (NOID).
An RFE is no longer necessarily the next step when USCIS believes evidence is missing or insufficient. The initial filing may be the applicant's or petitioner's only opportunity to establish eligibility before USCIS makes its decision. And if USCIS does choose to send an RFE, the response window may be shorter than filers have historically expected. RFEs issued under the new framework have been providing 30 days to respond, rather than the 84-day response period practitioners commonly received in prior years. The regulatory limits remain up to 12 weeks for an RFE, but an officer can now set a shorter deadline.
The processing context makes completeness even more important. As of September 2026, green card renewals take about 10.5 months to process — that is the time USCIS needs to finish 80% of Form I-90 cases, per its published processing times. An RFE adds months to that already-extended timeline. A denial wastes the fee and requires refiling from scratch.
Decision Tree: Does My I-90 Filing Risk an RFE or Denial?
What to Do If You Receive an I-90 RFE
If USCIS does issue an RFE, read every word of the notice before assembling a response. Shorter RFE response periods are now a real operational factor: RFEs issued under the new framework have been providing 30 days to respond rather than the 84-day period practitioners commonly received before. Note the deadline on the day the notice arrives, not the day you get around to reading it — USCIS counts from the issue date.
Respond to every item the RFE identifies. A partial response — addressing some items and not others — is treated as a failure to respond to the unanswered items. If your I-90 is denied, you can file a motion to reopen or reconsider within 30 days if you have new evidence or believe USCIS made a legal error, or refile Form I-90 with corrected information. But motions take time and cost money; a complete initial response is the better path.
If the RFE references anything about your underlying status — abandonment, fraud, or removal proceedings — get an immigration attorney involved before you respond. If the denial questions your status itself, consult an immigration attorney immediately. A poorly assembled RFE response on a status-based challenge can accelerate a problem that might otherwise have been manageable.
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Frequently asked questions
What is the current edition date for Form I-90, and does it matter?
The current Form I-90 edition date is 01/20/25, per the official USCIS I-90 page. The edition date appears at the bottom of every page of the form. If you print and mail the form, all pages must be from the same edition — a missing page or a page from a different edition can result in rejection. Always download directly from uscis.gov before filing, since USCIS can update form editions without much public notice, and a prior downloaded version may already be outdated.
Can USCIS deny my I-90 without sending me an RFE first?
Yes, as of August 5, 2026. USCIS issued Policy Alert PA-2026-05, which updated USCIS Policy Manual Volume 1, Part E, Chapter 6, giving officers full discretion to deny a benefit request — including an I-90 — without issuing an RFE or NOID first, when required initial evidence is missing or eligibility is not established at the time of filing. This policy applies to all pending and newly filed cases as of that date. The practical implication is that you cannot count on receiving an RFE as a second chance to fix a deficient filing.
If I have my HR coordinator or a notary sign my paper I-90 for convenience, is that valid?
No. Under the DHS interim final rule amending 8 CFR 103.2(a)(7), effective July 10, 2026, only a handwritten ink signature by the applicant — or a scan, photocopy, or fax of one — is valid on a paper-filed benefit request. A signature by any third party who is not a legally recognized representative, typed names, cursive fonts, stamps, and e-signature software outputs like DocuSign are all invalid on paper. An invalid signature on a paper I-90 can result in denial — not a rejection and return — and USCIS keeps the filing fee. If you want to use an electronic signature, file online through your USCIS account.
My I-90 has been pending for over a year — is that normal in 2026, and should I be worried about a delayed RFE?
Processing times for Form I-90 have increased sharply. USCIS data shows the median processing time rose from 1.1 months in FY2024 to 8.5 months in FY2026 through May 2026, and USCIS's own published estimate places 80% completion at around 10.5 months as of September 2026. A case at or within that window is within normal range; USCIS has not necessarily identified a problem. If your case exceeds the posted processing time, you can submit a service request through your USCIS online account. If you receive an RFE at any point during a long-pending case, check the response deadline immediately — under the August 5, 2026 policy, officers can set deadlines shorter than the regulatory maximum of 12 weeks.