Center for Federal Accountability

Online passport renewal for Americans abroad: what the State Department proposes and what its privacy records cover

A proposed rule would let Americans in designated countries renew passports online and drop the one-year remaining-validity limit, saving an estimated $148.7 million a year. The privacy notice it relies on for passport records was last published in 2015, and neither the rule nor the system's privacy assessments describe how applicants abroad will be verified. Comments close October 27, 2026.

2026-10-01 · State Department · Information

On August 28, 2026, the State Department proposed letting U.S. citizens in designated foreign countries renew their passports online (91 FR 55505). The Online Passport Renewal system, created by a 2021 rule (86 FR 72521) and opened to the public in 2022, accepts applications only from people in the United States. Comments close on October 27, 2026, on docket DOS-2026-0925 (RIN 1400-AF97). Four comments had been posted by late September. The Department classes the rule as economically significant.

## What would change

The proposal would amend 22 CFR 51.21. Countries would be added in phases and listed on the Department's online renewal page. It would also drop the rule that an applicant's last passport must have no more than a year of validity left; the allowed remaining validity would instead be set on the Department's website, so it could change without a new rule. Other limits stay: the previous passport must have been issued when the applicant was 16 or older, within the last 15 years, and be available to verify.

The Department considered two larger expansions and did not propose them: applicants whose passport was lost or stolen (about 300,000 a year) and a group of about 495,000 that it says would need technology it does not yet have.

## The numbers

For fiscal year 2027 the Department projects about 10.5 million renewals on Form DS-82, 6.3 million of them online, with up to 220,000 more from applicants abroad. It estimates savings to the public of $148,685,935 a year: $72.4 million in postage, $30.9 million in photos, $26.4 million in travel, $18.8 million in lost wages and $215,600 in staff time.

CFA checked the arithmetic. The photo line lists 2,060,234 photos at $15 each as $30,903,506; the product is $30,903,510, a $4 difference. The analysis discounts future years by multiplying by (1 − r) each year rather than dividing by (1 + r), the method in OMB Circular A-4. That makes the present value slightly lower, not higher. The lost-wage estimate rests on an hourly figure for Americans abroad derived from an OECD report; CFA could not confirm the underlying number.

## The privacy records behind the system

The proposal points to two Privacy Act system of records notices, the public notices that tell people what records an agency keeps about them and how they are used: STATE-26, Passport Records, and STATE-05, Overseas Citizens Services Records. STATE-05 was revised on November 20, 2023. The most recent STATE-26 notice CFA found in the Federal Register was published on March 24, 2015 (80 FR 15653), seven years before online renewal opened. Its text does not mention online applications.

The Department has published two privacy impact assessments for the system: one dated March 24, 2021, and one for "Online Passport Renewal 3.0," completed in October 2024 as a new system. Both cite STATE-26 by its 2015 date. The 2024 assessment answers "No" when asked whether the notice needs to be amended for the new system. It lists the personal information collected, including full Social Security number, passport number, photograph, credit card details and an emergency contact.

Neither assessment discusses applicants outside the United States. In the 2024 assessment, "overseas" appears only to describe Department staff who use the system. Neither describes how an online applicant's identity is confirmed. The proposed rule requires photographs "as prescribed by the Department" and leaves the details to its website. In the 2021 rulemaking, commenters raised identity theft; the Department answered that applications are handled on "controlled workstations accessed by authorized employees only" and that "The data is encrypted."

CFA observes that the proposal would extend the system to a new group of applicants without an updated passport-records notice or a privacy assessment that addresses them. That is CFA's reading of the published records; the Department may have unpublished plans.

## CFA's records

The State Department is not yet among the agencies CFA grades. CFA's index of Federal Register privacy notices holds 141 documents from the Department.

## What to watch

Whether the Department publishes an updated STATE-26 notice or a new privacy impact assessment covering applicants abroad before the first countries are added.

How applicants abroad will prove their identity online and how their photos will be checked, and whether the final rule says so or leaves it to the website.

Which countries go first, and what remaining-validity limit the Department sets on its website.

How the final rule answers the Department's own question about the time burden of Form DS-82 (OMB control number 1405-0020), which it expects to stay unchanged.

Comments can be filed on regulations.gov under docket DOS-2026-0925, or by email to the address in the notice, citing RIN 1400-AF97.

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