Important Updates to the Naturalization Process in 2025: What Applicants Should Know
In August 2025, U.S. Citizenship and Immigration Services (USCIS) released several new policy memoranda that will affect people applying for U.S. citizenship. While these announcements do not change the actual legal requirements for naturalization, they signal shifts in how USCIS officers may review applications. Unfortunately, these changes grant unprecedented discretionary authority to USCIS officers and will likely result in increased naturalization application denials. This blog covers the key changes, what they might mean for new applicants, and practical steps to prepare before filing.
1. Good Moral Character (GMC) Generally
On August 15, 2025, USCIS issued a memo describing plans to take a more “rigorous” and “holistic” approach when deciding whether applicants meet the good moral character (GMC) requirement for naturalization.
Traditionally, good moral character has been judged by what an applicant has not done. For example, avoiding certain criminal acts, fraud, or willful failure to pay taxes. The law itself (found in the Immigration and Nationality Act § 101(f) and 8 CFR § 316.10) defines GMC only in negative terms, i.e., specific actions or behaviors that would prevent approval.
The new memo, however, encourages USCIS officers to look beyond the absence of wrongdoing and to actively consider whether an applicant has demonstrated positive attributes such as:
Ongoing community involvement and contributions
Family caregiving responsibilities
Educational achievements
Stable and lawful employment history
Compliance with tax obligations and financial responsibility
Length of residence in the U.S.
While this language sounds like a broader, fairer review, advocates warn that it may raise the bar for applicants, since these “positive factors” are not required by law. At this time, the statute, regulations, and USCIS Policy Manual have not changed, so until further notice, these criteria should be viewed as guidance — not binding rules.
Practical takeaway:
If you are preparing to apply, make sure your N-400 form is complete and accurate. It already asks for details that touch on most of these areas (residence, work history, taxes, and family ties). You do not need to submit extra documents unless specifically requested, but it can help to be ready to highlight your community ties, employment history, and positive contributions during your interview.
2. Good Moral Character - Rehabilitation and Past Issues
The same GMC memo also discusses how USCIS should review cases involving past mistakes, such as unpaid taxes or legal trouble. It suggests officers should look for proof of rehabilitation. For example, paying overdue taxes, completing probation, or providing testimony from community members.
However, under current law, good moral character is assessed using a totality-of-circumstances test, and applicants may still qualify if they can show good-faith efforts to correct past issues. Full repayment of taxes or other obligations is not automatically required.
Ultimately, if you have a past issue, like back taxes or child-support payments, be prepared to explain it honestly and show the steps you’ve taken to fix it. A payment plan or evidence of progress often helps demonstrate good moral character. Under this new policy, depending on your jurisdiction, you may or may not encounter a USCIS officer who will demand that you pay your back taxes or child-support payments in full prior to being able to approve the N-400 application. In the event this occurs, you should be prepared to make those payments in full or risk your application being denied.
3. The “Neighborhood Visit” Memo: Reviving Old Practices
On August 22, 2025, USCIS issued another memo proposing to bring back “neighborhood visits,” i.e., in-person investigations into applicants’ lives and communities.
This practice, which dates back to 1981, was discontinued only a decade later because it was time-consuming and rarely produced useful information. The memo now states that such visits could be used again to verify an applicant’s residence, good moral character, or attachment to the U.S. Constitution.
Under this policy, USCIS could ask for letters from neighbors, employers, or community members, and failure to provide them might trigger a neighborhood investigation. At this time, the details of how these visits will work are unclear, and there is no change to the regulations or Policy Manual. Applicants are not required to submit these letters proactively unless USCIS specifically requests them.
What this means for applicants: Where field offices are already busy, this policy could lengthen case processing times. For now, applicants should continue to prepare their applications carefully and respond promptly to any official requests for evidence (RFEs).
4. False Claims to U.S. Citizenship
USCIS also updated its Policy Manual on false claims to U.S. citizenship. The new guidance clarifies how these claims affect inadmissibility (for those applying for entry or adjustment of status), but it does not change how they impact naturalization.
A false claim to U.S. citizenship can still be a conditional bar to good moral character if made knowingly during the five-year statutory period. For most naturalization applicants, this change should not affect eligibility unless a false claim was made recently or in connection with another immigration benefit.
5. What Has Not Changed
Despite the new memos, the legal standards for naturalization remain exactly the same. To qualify, an applicant must still meet the core requirements under the Immigration and Nationality Act, including:
Being a lawful permanent resident for at least five years (or three if married to a U.S. citizen);
Continuous residence and physical presence;
Ability to read, write, and speak English;
Knowledge of U.S. history and government; and
Good moral character during the statutory period.
USCIS may interpret certain elements differently, but it cannot change the law through a memo.
6. Bottom Line
The August 2025 USCIS memos do not change who qualifies for naturalization, but they could influence how officers evaluate good moral character and the evidence they request.
Thinking About Applying for Citizenship?
If you are currently a green card holder and considering applying for naturalization, please do not hesitate to give us a call at (212) 547-8857 or schedule a consultation online and we'd be happy to assess your situation and discuss working together to build a strong application for U.S. citizenship. Contact us today and take the next step towards your naturalization journey!
Disclaimer: This blog post and similar posts are not to be considered as providing legal advice. The discussion here is meant for educational and informational purposes only and shall not create an attorney-client relationship with the readers of this content.
tags
- 90 Day Rule 1
- Addendum 1
- Adjustment of Status 15
- Advance Parole 1
- Affidavit of Support 1
- Americans with Disabilities Act 1
- Attorney-Client Privilege 1
- Attorney-Client Relationship 1
- Background Checks 1
- Bargaining Power 1
- Bars to Adjustment of Status 1
- Board of Directors 1
- Bona Fide Marital Relationship 3
- By-laws 1
- CIMT 1
- Certificate of Authority 1
- Certificate of Citizenship 1
- Child Citizenship Act of 2000 1
- Commercial Leases 1
- Conditional Green Card 6
- Confidentiality 1
- Consular Processing 3
- Consulting Agreements 1
- Continuous Residency 1
- Contract Clauses 9
- Contract Negotiation 6
- Contracts 12
- Coronavirus 4
- Corporations 6
- Correcting Errors 1
- Crime Involving Moral Turpitude 1
- Crime Victims 6
- DACA 1
- Dissolving LLCs 1
- ESTA 1
- Employees 3
- Employers 3
- Expanded Family/Medical Leave 1
- FOIA Requests 1
- False Claim to U.S. Citizenship 1
- Fiancé Visa Interview 1
- Fiancé Visas 10
- Force Majeure 2
- Foreign PLLCs 2
- Freedom of Information Act 1
- Good Moral Character 7
- Green Card Interview 2
- Greencard 17
- I-129F 1
- I-130 Application 3