Summary: On November 4, 2026, U.S. Citizenship and Immigration Services (USCIS) issued policy memorandum PM-602-0201, new guidance on how officers evaluate “good moral character” in naturalization (citizenship) cases. The memo focuses on support of dependents, public benefits, and the financial-support promises made by sponsors and supporters.
What happened
To become a U.S. citizen, an applicant must show good moral character during the required statutory period. The new USCIS memo, titled “Good Moral Character Determination: Failure to Support Dependents, Public Benefits, and Sponsorship through Affidavit or Declaration of Support,” directs officers adjudicating Form N-400 to review whether an applicant has:
- willfully failed or refused to support his or her dependents;
- committed, been convicted of, or admitted to fraud or deception in seeking, receiving, or using public benefits;
- failed to meet obligations on an Affidavit of Support (Forms I-864, I-864EZ, or I-864A) during the period it is enforceable;
- failed to meet obligations on a Declaration of Financial Support (Form I-134 or I-134A) while those obligations were in effect; or
- received means-tested public benefits “due to a reason that is identified by average citizens of the community as intentionally avoiding self-sufficiency.”
The memo says that, depending on the circumstances, a dependent’s receipt of means-tested public benefits may be evidence that the applicant failed to support that dependent. It also gives an example of conduct an officer may view negatively: stopping work or significantly reducing work hours in order to stay within benefit eligibility limits, rather than for a legitimate personal or medical reason.
Who is affected
The guidance applies to people applying for naturalization. It may be especially relevant to applicants who have child-support or other dependent-support obligations, applicants who have received public benefits, and applicants who have signed an Affidavit of Support or a Declaration of Financial Support for a relative or other person (for example, as a sponsor in a family-based green card case or as a supporter in a parole program).
What it means
The memo itself repeats several important limits. It states that lawful receipt of public benefits “is neither a bar to naturalization nor always considered as a negative factor,” and that officers must conduct an individualized, case-by-case review of the totality of the circumstances, including the reason benefits were used, the applicant’s efforts toward self-sufficiency, and evidence of rehabilitation and positive contributions. It says any adverse finding must be tied to specific conduct, “rather than poverty, disability, or lawful benefit receipt.” It also notes that in communities where many residents receive means-tested benefits, an applicant’s benefit receipt may not reflect negatively on character.
Several details are still unknown. USCIS says it will draft new Policy Manual content and officer guidance, and will revise Form N-400 to collect more information about public benefit use and support of dependents. It has not yet published that updated guidance or the revised form, and the memo does not state which pending applications the new approach will apply to. Advocacy groups could challenge the policy in court, which could affect how or when it is applied. Applicants with questions about how their own history may be viewed should get individual legal advice. Learn more about our immigration assistance services.
Source: USCIS – Policy Memorandum PM-602-0201, Good Moral Character Determination: Failure to Support Dependents, Public Benefits, and Sponsorship through Affidavit or Declaration of Support (published November 4, 2026)
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This article is a news summary for general information only and is not legal advice. Reading it does not create an attorney-client relationship. Immigration law changes often and every case is different; only a legal consultation with Attorney James Betzold can determine how this news applies to you.