Applying for U.S. citizenship is an exciting step. For many immigrants, it represents years of hard work, patience, and commitment to building a life in the United States. Unfortunately, recent reports about internal guidance within U.S. Citizenship and Immigration Services (USCIS) suggest that some naturalization cases may face longer waiting times than usual.
Here is what we know so far—and what it could mean for you.
What Are the Naturalization Delays?
You may be hearing rumors of delays in naturalization interviews. We can confirm that we’re seeing this in practice. Up through late last year, applicants would be scheduled for an interview three to four months after filing. Since January, we have only had one client scheduled for a naturalization interview. In 2025, we were averaging two interviews a month.
Traditionally, the naturalization process includes several steps:
- Filing the N-400 application
- Attending a biometrics appointment
- Being scheduled for a naturalization interview
- Taking the English and civics tests
- Receiving a decision and attending the oath ceremony
Our understanding is that this delay is being caused by two August 2025 policy memoranda. These policies announced significant changes, but they didn’t address how USCIS officers were going to implement them. We think that this recent pause is so that USCIS can create new internal guidance and then train their officers. What exactly, though, are these changes?
What Are the Policy Changes?
One of the most significant changes involves how USCIS evaluates good moral character.
In the past, the analysis often focused on whether an applicant had statutory bars, such as certain criminal convictions or immigration fraud. If no such bar existed, many applicants were able to demonstrate good moral character relatively easily.
Under the new guidance, officers are instructed to apply a “totality of the circumstances” analysis. This means they may evaluate a wider range of factors when deciding whether someone meets the good moral character requirement.
Positive factors that may support a finding of good moral character include community involvement, family responsibilities, education and professional development, long-term residence in the United States, stable employment, and tax compliance.
At the same time, officers may also consider conduct that is not criminal but may reflect negatively on character, such as repeated traffic violations, harassment complaints, aggressive or disruptive behavior, and financial irresponsibility.
In other words, the good moral character requirement is now viewed more broadly. Instead of simply checking whether a legal bar exists, officers may evaluate the applicant’s overall conduct and reputation.
The new guidance also directs officers to consider rehabilitation if an applicant has past misconduct. As such, officers may evaluate how long ago the conduct occurred, look for evidence that the applicant has changed their behavior, and consider whether the applicant has lived responsibly and contributed positively to their community since the incident.
This approach means the analysis may look more like a discretionary evaluation, similar to certain forms of immigration relief, rather than a purely technical eligibility determination.
As a part of this stricter evaluation, naturalization applications now have the potential for personal investigations.
What Are Personal Investigations?
Under a recent USCIS policy memo, officers have the authority to conduct neighborhood or community inquiries to verify information in a naturalization application. This authority comes from INA §335(a) but has largely not been used for decades.
Under this authority, officers have the ability to visit the applicant’s neighborhood, speak with neighbors or coworkers, verify that the applicant resides at the stated address, and ask about the applicant’s reputation and conduct in the community.
It is important to note that these investigations are discretionary and are not expected to occur in every case.
USCIS may also place greater emphasis on third-party testimony about an applicant’s character, either through the investigations or through written testimonials. As such, USCIS may request letters from members of their community, such as neighbors, employers, coworkers, community leaders, or members of their religious or civic organizations.
This reflects a renewed focus on community reputation and personal conduct. In practice, the inquiry may look at whether the applicant has demonstrated the type of responsibility and conduct expected of a U.S. citizen. At this stage, how broadly this concept will be applied in practice remains unclear.
How Will This Affect My N-400?
Advocates have raised concerns that these policies could lead to greater scrutiny of applicants’ beliefs or public conduct, particularly if they are seen as inconsistent with constitutional principles. Critics also argue that this could create room for subjective interpretations. Others believe it helps ensure that naturalization applicants are genuinely committed to the civic values of the United States.
For many immigrants, this delay can be frustrating and stressful. Citizenship provides important benefits, including the right to vote, the ability to petition certain family members, protection from deportation, and access to a U.S. passport.
Intentionally delaying the interview process could mean the entire naturalization process takes much longer.
However, it is important to remember that these reports involve internal guidance, and the situation may still change.
Should I Still File Your N-400?
In most cases, yes. If you are eligible for naturalization, filing your Form N-400 can still be the right decision. If you delay filing, you may simply be pushing your timeline further into the future.
Even if interviews are delayed, filing earlier means:
- You secure your place in line
- Your application begins processing
- You may still receive biometrics and other updates while waiting
If you are considering citizenship:
- Check your eligibility for naturalization
- File your N-400 when you are ready, rather than waiting for policies to change
- Keep records of your application timeline
That said, every case is different. If you have concerns about timing, travel, or other immigration matters, it may be helpful to speak with an immigration attorney before filing.
Does USCIS Have to Process Cases Within a Certain Time?
Yes—the government has a legal obligation to adjudicate immigration applications within a reasonable period of time.
When naturalization cases are delayed for too long, some applicants pursue a legal action called a 1446(b) lawsuit, which asks a federal court to order the government to act on a naturalization application.
If 120 days pass after the interview and no decision has been made, the applicant may be able to ask a federal court to step in and decide the case or require USCIS to do so.
This means that lawsuits are typically not an option for cases that are still waiting for an interview.
Stay Tuned for Updates
The naturalization process is one of the most important steps in an immigrant’s journey. Policies that create unnecessary delays can have a real impact on families and communities.
We are closely monitoring updates from USCIS and any legal developments related to these reports. We hope this policy will be retracted, and we will continue to keep our clients and community informed as more information becomes available.
If you have questions about your citizenship case or are thinking about applying for naturalization, our team is here to help.