The 111th Congress has considered the issue of possible exemptions to federal photo identification requirements under the REAL ID Act of 2005 (P.L. 109-13). The REAL ID Act contains a number of provisions relating to improved security for drivers licenses and personal identification cards. The REAL ID Act also requires, without exemption, that a digital photograph appear on each document. Some have argued that an exemption should be provided for individuals with religious objections to the photograph requirement to comport with the Free Exercise Clause of the First Amendment and the Religious Freedom Restoration Act of 1993 (RFRA, P.L. 103-141). The Free Exercise Clause prohibits Congress from enacting any law that prohibits the free exercise of religion, guaranteeing individuals the right to practice their religious beliefs without government interference. To comport with the Free Exercise Clause, any neutral law of general applicability (i.e., those that do not target religion or require individual assessments) must be rationally related to a legitimate government purpose. If a law with a photo requirement meets this standard of review, an exemption based on religion is not necessary under the federal constitution. Federal laws burdening religious exercise must also comport with RFRA, which provides a heightened level of review for such laws. Under RFRA, any federal law burdening religion generally must have a compelling governmental interest achieved by the least restrictive means possible. If the government can meet this standard of review, an exemption based on religion is not necessary under RFRA. This report will analyze the legal issues associated with religious exemptions to photo identification laws. Although no lawsuits appear to have challenged federal laws with photo requirements, state photo identification laws have been challenged for several decades. After discussing the legal requirements of the Free Exercise Clause and RFRA, the report will explain the elements of analysis necessary for legal challenges involving religious objections to photo requirements. The report will also analyze lawsuits that have challenged state photo requirements, including significant factors of consideration in such cases. Finally, the report will analyze what factors may be relevant in future decisions that may arise related to federal photo identification requirements.