USCIS Introduces New Policy Changes for Naturalization and Discretionary Immigration Benefits

In a recent series of policy changes, the U.S. Citizenship and Immigration Services (USCIS) has shifted its approach towards evaluating good moral character (GMC) for naturalization applicants and increasing scrutiny of discretionary immigration benefits. These changes aim to promote a more comprehensive assessment of applicants' backgrounds, behaviors, and community involvement. As a result, applicants seeking naturalization or discretionary benefits must prepare more thoroughly, gathering documentation of their positive contributions and reviewing their social media presence.

Key Takeaways:

• The USCIS has introduced a new approach to evaluating GMC, moving from a checklist-based approach to a comprehensive "totality of circumstances" evaluation.
• Applicants seeking naturalization will be required to provide comprehensive documentation of their positive contributions to their communities, including community service records, volunteer work, and employment history.
• The USCIS will place greater emphasis on an applicant's positive attributes and contributions in GMC determinations, including sustained community involvement, caregiving, and stable employment history.
• Officers will focus greater attention on whether applicants have engaged in disqualifying behavior, including murder, aggravated felony, crimes of violence, and anti-American ideologies.
• Rehabilitation and reformation consideration will play a significant role in GMC determinations, with evidence of genuine rehabilitation potentially supporting a finding of GMC.
• The USCIS will also review a beneficiary's social media for content promoting anti-American views when exercising discretion in immigration benefits requests.
• The updated policy manual directs officers to give "significant negative discretionary weight" for anti-American ideologies or activities.
• Applicants seeking discretionary immigration benefits, such as EB-5, National Interest Waiver, and I-765 Employment Authorization, should be aware of the increased scrutiny and potential indicators of anti-American ideologies or associations.
• These policy changes will require more comprehensive preparation for naturalization applications and increased awareness of how certain behaviors can result in the denial of an immigration benefits request.

Statistics:

• The new naturalization civics test will increase the number of questions from 10 to 20, with applicants required to correctly answer 12 questions to pass.
• The new test will be administered to applicants filing their naturalization applications on or after October 17, 2025.
• Over 90% of naturalization applicants will be required to pass the new civics test.
• GMC evaluations will now involve a holistic assessment of the applicant's behavior, adherence to societal norms, and positive contributions.
• The USCIS will focus greater attention on 8 CFR 316.11, requiring applicants to be "favorably disposed toward the good order and happiness of the United States."
• The updated policy manual emphasizes the importance of considering an applicant's positive attributes and contributions in GMC determinations.

Sources:

• August 15, 2025, policy memorandum: "Restoring a Rigorous, Holistic, and Comprehensive Good Moral Character Evaluation Standard for Aliens Applying for Naturalization."
• August 22, 2025, policy memorandum: "Reintroducing Neighborhood Investigations of Naturalization Applicants to Corroborate Their Eligibility for U.S. Citizenship."
• September 17, 2025, announcement: "Implementation of the 2025 Naturalization Civics Test."
• August 19, 2025, USCIS announcement: "Updates to the Policy Manual Expanding Officers' Discretionary Authority for Certain Immigration Benefits Requests."