Applying for U.S. Citizenship: New Rules, Greater Scrutiny

Applying for U.S. citizenship is becoming more complicated. Naturalization denial rates more than doubled year over year, from 8.8% in the quarter ending June 2025 to 18.2% in the quarter ending June 2026, according to the latest official USCIS quarterly data. That increase comes amid greater scrutiny of naturalization applications and new policies on neighborhood investigations, financial responsibilities, and what constitutes “good moral character” for applicants.

The statistics do not establish that the new policies alone caused the increase. The newest USCIS memorandum, issued on November 4, 2026, is too recent for its effects to be known yet. The August 2026 neighborhood-investigation guidance was also published after the June 2026 reporting period, although USCIS had already re-established neighborhood investigations as part of naturalization background checks in 2025.

For those applying for naturalization, responding to a request for evidence, or reviewing a naturalization denial, the practical message is to prepare a substantial record with evidence of eligibility and good moral character.

What changed in the USCIS naturalization policies?

Three recent USCIS policy documents deserve close attention:

• August 15, 2025: The good moral character memorandum directs officers to evaluate positive attributes and contributions, as well as misconduct, under a holistic approach.
• August 25, 2026: The naturalization investigations policy alert explains neighborhood investigations and the evidence USCIS may consider when deciding whether to conduct or waive one.
• November 4, 2026: The public benefits and financial support memorandum addresses dependent support, unlawfully obtained benefits, sponsorship obligations, and intentional avoidance of self-sufficiency. It also calls for further implementation guidance and changes to Form N-400.

USCIS neighborhood investigations: What should applicants expect?

Under the USCIS Policy Manual, officers may investigate an applicant’s residence, conduct, reputation, and community connections. This can include speaking with neighbors, landlords, employers, coworkers, or other people who presumably know the applicant.

Investigations generally occur before the naturalization interview, but USCIS may conduct one later, before the oath ceremony. Officers decide whether to conduct or waive an investigation based on the circumstances. Not every applicant will receive a neighborhood visit.

USCIS officers conducting witness interviews should identify themselves and explain the nature of the inquiry while protecting confidential information. If USCIS intends to rely on adverse information unknown to the applicant, policies generally require giving an opportunity to the applicant to respond before denial.

What should character reference letters include?

USCIS policy now recommends at least two letters from people familiar with the applicant, preferably U.S. citizens who are not relatives. The letters are optional, and in fact the official form instructions from USCIS do not mention this policy recommendation. However, failing to submit such letters does not mean the applicant will be found to lack good moral character.

Letters of support for naturalization should be signed and dated and include:

• The writer’s name, contact information, and immigration or citizenship status, with supporting status documentation as contemplated by USCIS guidance.
• How the writer knows the applicant and how long they have known each other.
• Specific, firsthand examples of honesty, reliability, family responsibilities, work, or community involvement.
• The writer’s assessment of the applicant’s moral character and attitude toward the principles of the U.S. Constitution.

Concrete examples are more helpful than a generic statement that someone is a good person. Residence records, employment documentation, tax records, and evidence of family support or caregiving may also help USCIS evaluate the application and whether an investigation is necessary. Letters do not guarantee that USCIS will waive an investigation.

Good moral character requires more than a clean criminal record

Good moral character has long been a naturalization requirement. The August 2025 memorandum places renewed emphasis on affirmative evidence of positive conduct, rather than treating the absence of criminal problems as the entire inquiry.

Relevant evidence may include lawful employment, compliance with tax obligations, education, family caregiving, community service, financial responsibility, and rehabilitation after past misconduct. This does not make a college degree, volunteer work, or a particular income a universal requirement for citizenship. Applicants should explain their actual circumstances, including disability, retirement, unemployment, or unpaid caregiving.

The USCIS Policy Manual’s good moral character framework remains important. Favorable evidence does not automatically overcome a statutory bar, and naturalization eligibility is governed by law.

Two decisions cited in the policy materials illustrate the distinction:

• Hussein v. Barrett, 820 F.3d 1083 (9th Cir. 2016), emphasizes consideration of relevant circumstances when applying the general good moral character standard.
• Matter of Castillo-Perez, 27 I&N Dec. 664 (A.G. 2019), establishes a rebuttable presumption against good moral character for two or more DUI convictions during the relevant period.

Can public benefits affect a citizenship application?

Lawfully receiving public benefits does not automatically disqualify someone from naturalization. The November 2026 memorandum instead focuses on particular conduct, including fraud, willful failure to support dependents, failure to meet sponsorship obligations, and intentional avoidance of self-sufficiency.

Means-tested programs generally base eligibility on income or resources. Examples include Supplemental Security Income (SSI), SNAP food assistance, TANF, Medicaid, and certain housing assistance. Eligibility rules differ by program. This is not an exhaustive list, and the memorandum’s concern about unlawfully obtaining benefits is not limited to means-tested programs. Naturalization good moral character review should not be confused with the separate public charge rules.

Willful failure to support dependents

Willful failure or refusal to support dependents can prevent a finding of good moral character unless extenuating circumstances apply. A court support order is not always necessary, and the inquiry can extend beyond minor children or dependents living in the United States.

Inability to pay is different from deliberately refusing to pay. Evidence of unemployment, disability, actual financial circumstances, payments made, and good-faith efforts may matter under 8 C.F.R. § 316.10 and the USCIS Policy Manual’s discussion of conditional bars.

In Dos Reis v. McCleary, 200 F. Supp. 3d 291 (D. Mass. 2016), the court upheld a naturalization denial involving willful failure to support children and false testimony. The decision underscores the importance of financial records and truthful explanations.

Unlawfully obtaining benefits or helping dependents obtain them

Misrepresenting income, household members, identity, or other eligibility facts can create serious problems. The memorandum also addresses helping dependents unlawfully obtain benefits. An innocent mistake or overpayment is not automatically fraud, but applicants should retain notices, explanations, repayment records, and any agency findings.

The memorandum cites Matter of Pinzon, 26 I&N Dec. 189 (BIA 2013), concerning a false-statement offense involving fraud. That case involved passport-related misrepresentations, not public benefits, but illustrates why fraudulent conduct can carry immigration consequences.

I-864 sponsorship obligations and address changes

Signing Form I-864 or I-864EZ creates enforceable support obligations. A household member who signs Form I-864A may also assume contractual obligations. Applicants who have sponsored someone should review whether they have complied with the applicable commitments. A sponsored immigrant’s receipt of benefits does not, by itself, establish that the sponsor violated those obligations.

Another legal obligation triggered by signing the I-864 is that sponsors must notify USCIS of an address change by filing Form I-865, Sponsor’s Notice of Change of Address, within 30 days of moving, while the sponsorship obligation remains in effect. The rule applies to joint and substitute sponsors as well. See 8 C.F.R. § 213a.3. A noncitizen sponsor may have a separate obligation to report their own address change via Form AR-11 or the USCIS website.

The memorandum also discusses commitments made through Forms I-134 and I-134A. Those forms do not create the same statutory support obligation as Form I-864, a distinction the memorandum acknowledges.

Intentional avoidance of self-sufficiency

The new memorandum directs officers to consider whether someone intentionally avoided self-sufficiency to obtain means-tested benefits, such as deliberately reducing work for that purpose. It calls for an individualized analysis. Medical conditions, caregiving responsibilities, and other legitimate personal circumstances should be documented and distinguished from intentional avoidance.

What if you receive an N-400 RFE or a naturalization denial?

A request for evidence (sometimes labeled a “notice of continuance” for naturalization applicants) should be answered with records that address the specific concern, not simply more general character letters. Review the notice carefully, identify the applicable deadline, and provide a clear explanation supported by documents.

If USCIS denies the application, promptly review the decision and whether a Form N-336 request for a hearing, or a new N-400 application altogether, may be appropriate. Filing deadlines are short. Reapplying without addressing the reason for denial may lead to the same result.

Moro Legal, LLC, assists with naturalization applications, evidence requests, and review of denied N-400 applications. Contact our office to discuss your circumstances and the evidence your case may require.

USCIS naturalization data

The introductory comparison uses the USCIS N-400 performance data for fiscal year 2025, third quarter and the corresponding fiscal year 2026, third-quarter data. Additional reports are available through the USCIS immigration and citizenship data page.

The denial rate is denials divided by approvals plus denials, including military and nonmilitary cases, for each quarter ending June 30. It is not a June-only rate, a percentage of new filings, or a prediction of any individual applicant’s outcome.