On 9/14/2026, U.S. Citizenship and Immigration Services (USCIS) released Policy Alert PA-2026-13, which will change the USCIS Policy Manual regarding referrals that can lead to denaturalization. These changes are in Volume 12 Part L of the Policy Manual. The policy went into effect as soon as it was published. USCIS allowed for public comment through 9/25/2026 but has since extended that to 10/14/2026.
The grounds for denaturalization have not changed. USCIS only changed how it will find cases, review them, and prioritize referrals.
When USCIS looks at your Citizenship
There are many ways that a naturalized citizen’s file can be audited. Typically, someone will file a form that requires citizenship, such as an I-130 to petition for your spouse or parent, or even an N-600 for your child. They will then check if you became a citizen properly. Another reason for an audit could be that they flagged your case for fraud detection, or DHS or another agency requested a review (i.e., the State Department).
Grounds for Revocation
We will discuss two main grounds for revocation. This includes situations where an individual unlawfully secures citizenship because they didn’t fulfill a necessary naturalization condition. Such as lawfully being a permanent resident. Residing/physically present for the required amount of time or having good moral character. You don’t need to have intent to commit fraud. The other ground is if you concealed a material fact or willfully misrepresented. This could be a false declaration or statement on your N-400, during your interview, or in your documentation.
There are two additional grounds. One is becoming a member of certain organizations within 5 years of naturalization. Another is becoming a U.S. citizen through military service and being dishonorably discharged before serving 5 years honorably.
Burden of Proof
USCIS cannot revoke citizenship independently; only a federal court has this authority. In civil cases, the Department of Justice must provide clear, convincing, and unambiguous evidence and is not subject to a statute of limitations. In criminal cases, the standard is beyond a reasonable doubt, and action must be taken within ten years.
Which cases get Priority
The document outlines priority categories for referral. These include national security concerns such as terrorism and espionage, serious threats to public safety, human rights violations, associations with gangs or cartels, and cases flagged by Interpol. Priority is also given to cases involving undisclosed felonies, human trafficking, sex offenses, violent crimes, certain financial fraud, government corruption, false identities, false claims of U.S. citizenship, unlawful voting before naturalization, and marriage fraud.
Most referrals will be sent to ICE. If they decline the case or it is past the statute of limitations for a crime. Then USCIS can refer them to the department of justice to file a civil action with the office of immigration litigation.
What happens after Denaturalization
When someone is denaturalized, they are considered not naturalized from the date of naturalization. They will have to give up their naturalization. And go back to their previous immigration status. Other people can be affected as well. USCIS can reopen any petition the person filed for family members to see if they qualify. There may be a case where your spouse or child can be denaturalized as well based on what your naturalization was canceled for.
What you should do Now
For most naturalized citizens, this update will not affect daily life. However, if you plan to sponsor a family member or submit an application based on your citizenship, review your naturalization record carefully. Address any prior arrests, previous marriages, gaps in residence, or inconsistencies in earlier applications before submitting new forms.
If you have questions about your history, our lawyers can review your file and help you determine your next steps.
As always, ILBSG actively monitors ongoing U.S. immigration news. If you have questions about any U.S. immigration related issue, contact us. Working with an experienced attorney ensures you get the right advice based on the most recent laws. In an ever-evolving immigration policy landscape, it’s particularly critical you get the right advice.