U.S. Citizenship and Immigration Services has told its officers that green card holders applying for citizenship can be found to lack Good moral characterA requirement for naturalization. Applicants must show good moral character during the statutory period, generally the five years before filing (three for certain spouses of U.S. citizens), and continuing until the oath. USCIS decides each case individually, and the standard of proof is preponderance of the evidence.See it in the glossary for failing to support dependents, breaking Affidavit of supportForm I-864, in which a sponsor promises to financially support an intending immigrant so that the immigrant is not likely to rely on public benefits.See it in the glossary promises, or using means-tested public benefits in a way the agency treats as avoiding self-sufficiency.
The guidance is in Policy Memorandum PM-602-0201, dated November 4, 2026. It governs how officers review Form N-400, the Application for NaturalizationThe process by which a permanent resident becomes a U.S. citizen, generally after three or five years of residence, by filing Form N-400.See it in the glossary, and USCIS says a revised N-400 and new Policy Manual content will follow.
Applicants have always had to show good moral character for the statutory period before filing, usually five years. What is new is how directly the agency now ties that test to money: child support, sponsorship contracts and public benefits.
What the good moral character memo covers
The memo lists six kinds of conduct that can lead an officer to find an applicant lacks good moral character:
- Willfully failing or refusing to support dependents.
- Being convicted of, or admitting to, an offense involving fraud or deception in seeking or using public benefits.
- Committing such a benefits fraud offense, even without a conviction or admission.
- Failing to meet obligations on an affidavit of support (Form I-864, I-864EZ or I-864A) while it is enforceable.
- Failing to meet support commitments on Form I-134 or I-134A while they were in effect.
- Receiving means-tested public benefits for a reason that average members of the community would see as intentionally avoiding self-sufficiency.
Public benefits: what counts and what does not
The memo says lawful receipt of public benefits is not a bar to naturalization and is not always a negative factor. Officers must run an individualized, case-by-case review that weighs why benefits were used, the applicant’s efforts toward self-sufficiency and any evidence of rehabilitation. An adverse finding has to rest on specific conduct, “rather than poverty, disability, or lawful benefit receipt,” the memo says.
It gives one example of conduct that could count against an applicant: a person who stops working or cuts hours to stay under a food assistance or housing subsidy limit, with no personal or medical reason. Officers may weigh that kind of conduct even when it is technically lawful, the memo says, under the “catch-all” clause in the Immigration and Nationality Act’s definition of good moral character.
It also describes the opposite case. Where local law adds benefits, or where most residents of a community receive means-tested benefits, an applicant’s use of them may meet the community standard and not reflect badly on their character.
Dependents and sponsors
Willful failure to support dependents was already a conditional bar to naturalization under federal regulations, unless the applicant shows extenuating circumstances. The memo adds that a dependent’s reliance on means-tested benefits can, depending on the facts, be evidence that the applicant failed to support that person, though it does not automatically block citizenship. Child support owed abroad can also be considered.
For sponsors, the memo focuses on people who signed an affidavit of support and are now applying to naturalize themselves. If a sponsor or household member did not provide the promised support, especially when the sponsored immigrant used means-tested benefits during the enforceable period, USCIS may count it as a negative factor. The same goes for supporters who signed Form I-134 or I-134A, including for ParoleDiscretionary, temporary permission for a person who may be inadmissible to enter or remain in the United States for urgent humanitarian reasons or significant public benefit, set out in INA 212(d)(5). Parole is not an admission, and a paroled person is still treated as an applicant for admission.See it in the glossary programs, even though the memo acknowledges those forms carry no statutory support obligation.
On benefits fraud, the memo lists giving false income or household information, receiving benefits while ineligible, failing to report changes such as long trips abroad that affect eligibility, and using multiple identities.
What changes for N-400 applicants
The memo does not set a separate effective date. USCIS says it will write Policy Manual guidance and revise Form N-400 to collect information about public benefit use and support of dependents. Once that guidance is published, officers will question applicants on these points at their interviews, the memo says.
The memo builds on an August 2025 USCIS memo that told officers to judge good moral character holistically, and it arrives weeks after a broader Public chargeA ground of inadmissibility for applicants an officer finds likely at any time to become a public charge. For Form I-485 filings on or after September 18, 2026, USCIS guidance lets officers weigh a wider range of means-tested public benefits, not only cash assistance.See it in the glossary standard for green card applicants took effect September 18. Public charge is weighed when someone applies for a green card. This memo applies later, when that green card holder applies for citizenship. The full process is explained in our naturalization guide.