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By: Jennifer Fabian-Verzosa, Esq.
IN 2025, APPLYING FOR U.S. CITIZENSHIP UNDERWENT SEVERAL TRANSFORMATIONS: POLICY SHIFTS, HEIGHTENED VETTING STANDARDS, AND CHANGES IN TESTING. IF YOU WERE THINKING OF APPLYING, KEEP READING FOR AN OVERVIEW OF THE CHANGES, SO YOU CAN BE PREPARED.
First, applicants can now expect to be assessed not only on their current eligibility for U.S. citizenship, but there will also be a forensic audit of their entire immigration history. This includes reviewing history beyond just the 5 year statutory period (or 3 years for marriage-based naturalization) typically reviewed for naturalization applications.
Additionally, naturalization applications from nationals of the following countries will have their N-400 applications put “on hold”, for extensive vetting and re-review =
- Afghanistan
- Angola
- Antigua and Barbuda
- Benin
- Burkina Faso
- Burundi
- Chad
- Cote d’Ivoire
- Cuba
- Dominica
- Equatorial Guinea
- Eritrea
- Gabon
- The Gambia
- Haiti
- Iran
- Laos
- Libya
- Malawi
- Mali
- Mauritania
- Myanmar (Burma)
- Niger
- Nigeria
- Republic of Congo
- Senegal
- Sierra Leone
- Somalia
- South Sudan
- Sudan
- Syria
- Tanzania
- Togo
- Tonga
- Turkmenistan
- Venezuela
- Yemen
- Zambia
- Zimbabwe
This is pursuant to updated 01/01/2026policy
guidance from USCIS
(PM-602-0194)[FN1], supplementing the prior
June 4, 2025 Presidential Proclamation, “Restricting the Entry of Foreign Nationals to Protect the United States from Foreign Terrorists and Other National Security and Public Safety Threats.”
This is an administrative freeze. Although the application can be accepted, and fees will be cashed, processing may be paused for an undeterminable period thereafter. Alarmingly, the policy also mandates a "re-review" of individuals from these nations who received benefits after January 20, 2021. The second look could potentially to green card revocation if "derogatory information" is discovered.
Third, testing has also changed. For applicants filing after October 20, 2025, the "2008 Version" of the civics test is no longer available. All N-400s filed in December 2025 are subject to the "2025 Civics Test". In the new test, the number of questions has increased from 100 to 128. An applicant must also answer 12 questions correctly, and they already fail once they get 9 wrong.
Fourth, USCIS also published policy guidance on August 15, 2025 (PM-602-0188)[FN2], requiring affirmative evidence of an applicant's "good moral character". The absence of any criminal history is simply not 'good enough' anymore. An applicant must be prepared to bring and show proof of their character. Reversing a policy that stood for over three decades, USCIS has resumed "neighborhood investigations", giving USCIS the authority to conduct field investigations where officers can contact and interview an applicant’s neighbors, employers, friends, and associates, to verify an applicant’s residence and “good moral character.” While USCIS has stated this is to combat fraud, this poses new issues, as one can imagine the potential impact that a disgruntled employer or neighbor can have on a person’s application for naturalization
With that said, applicants with any criminal history can expect that their applications will be further scrutinized for evidence of rehabilitation.
So, given all these changes, should a current lawful permanent resident apply for U.S. citizenship now, or wait until later?
To assess that question, consider that these changes may only be the first of a string of significant changes in the naturalization process.
More changes are expected. The USCIS Director has
stated that the current presidential administration
wants to make the test
harder
in the future. They want harder civics questions, a subjective
essay test, and possibly changing the location of the test to a standardized test center (rather than administering it during the naturalization interview).
It is also clear from the current administration’s policies of the past year that increased scrutiny of applications is also a focus for the future.
If you are considering whether to apply for U.S. citizenship now, or whether you should wait, while it is true that the current immigration landscape currently seems “scary”, consider also what the future holds if you wait too long to apply. The changes to naturalization happened rather quickly in 2025, and new changes and stricter requirements may suddenly pop up quicker than you expected in the future. This might not seem like a good time to apply, but then again there might also not be a better time for a while.
If you think you might meet the eligibility requirements already, you may want to consider applying soon -- before it becomes a necessity, and before the application process becomes an even higher hurdle.
An immigration attorney can help you better assess your situation and answer your questions about the potential risks and benefits of applying now, versus later.
This might not seem like a good time to apply, but then again there also might not be a 'better time' for a while.
Our IMMIGRATION LAW OFFICE is experienced with assisting applicants navigate the naturalization application process. Our client-centered law office will be here for you every step of the way, from filing to interview preparation. We provide both in-person and remote immigration legal services to applicants all over the United States. Contact us today!
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[FN 1] "Hold and Review of USCIS Benefit Applications Filed by Aliens from Additional High-Risk Countries.” (last accessed 01/02/2026) = "chrome-extension://efaidnbmnnnibpcajpcglclefindmkaj/https://www.uscis.gov/sites/default/files/document/policy-alerts/PM-602-0194-PendingApplicationsAdditionalHighRiskCountries-20260101.pdf"
[FN 2] "Restoring a Rigorous, Holistic, and Comprehensive Good Moral Character Evaluation Standard for Aliens Applying for Naturalization.” (last accessed 01/02/2026) = "chrome-extension://efaidnbmnnnibpcajpcglclefindmkaj/https://www.uscis.gov/sites/default/files/document/policy-alerts/08.15.2025-Restoring_a_Good_Moral_Character_Evaluation_Standard_for_Aliens_Applying_for_Naturalization-Policy_Memorandum_FINAL.pdf"
*For Article Requests, Republications, or Speaking Engagements, please email: jennifer@law-jf.com
