On November 4, 2026, U.S. Citizenship and Immigration Services (USCIS) issued a new policy memorandum explaining how it will evaluate “good moral character” in naturalization cases. The memo focuses on four types of conduct: willfully failing to support children or other dependents; obtaining public benefits through fraud; a sponsor’s failure to meet the obligations of a Form I-864 Affidavit of Support; and deliberately not working, or working less, to stay eligible for benefits. The memo does not make lawful receipt of public benefits a bar to citizenship, but it does mean that benefit use and family support will become a focus of review at the naturalization interview. Green card holders planning to apply for citizenship, especially those who signed an Affidavit of Support for a parent or spouse, whose family members have received benefits, or who have child support obligations, should review the relevant records in advance and make sure they can explain them clearly and truthfully.
What Is the Good Moral Character Review, and What Has Changed?
Naturalization applicants must show good moral character during a statutory period, which is generally the five years before filing, or three years for applicants married to U.S. citizens. In the past, most people associated character issues with criminal records, tax problems, or false statements. In August 2025, USCIS had already directed officers to take a holistic view of good moral character rather than looking only at whether the applicant had broken the law.
The new memo builds on that approach and expressly extends the review to family financial responsibilities and public benefits. It states that even without an arrest or conviction, officers may find that an applicant lacks good moral character if the conduct falls below the moral standards of average citizens in the community. In some circumstances, conduct outside the statutory period may also be considered.
Timeline: Where Things Stand and What Comes Next
The memo was issued on November 4, 2026, and already serves as guidance for officers deciding naturalization applications. According to the memo, USCIS will take two further steps: add detailed adjudication standards to the USCIS Policy Manual, and revise Form N-400, the naturalization application, to ask additional questions about public benefit use and support of dependents. Once the new guidance is published, officers will question applicants and examine these issues at the interview.
As a result, applicants should expect the N-400 and the naturalization interview to ask more directly about benefits and family support, and should be ready with explanations and supporting documents.
Who Is Affected? A Look by Situation
If you signed an I-864 Affidavit of Support for a parent or spouse, pay particular attention. The I-864 is a legally binding commitment: once the sponsored relative becomes a green card holder, the sponsor must keep that person’s income at no less than 125% of the federal poverty guidelines. The obligation generally continues until the sponsored relative becomes a citizen, has worked in the U.S. for a certain period, or another terminating event occurs. Household members who co-signed Form I-864A carry the same responsibility. The new memo states that a sponsor’s failure to meet this obligation, particularly if the sponsored relative received means-tested public benefits during that time, may count against the sponsor in the sponsor’s own naturalization case. Those who signed a Form I-134 Declaration of Financial Support do not have the same legal obligation, but willfully failing to honor that commitment may also be viewed as a negative factor.
If you immigrated through a sponsor and have received public benefits, such as SNAP (food stamps), Medicaid, or Supplemental Security Income (SSI), the key question is whether you received them lawfully and reported truthfully. The memo makes clear that lawful receipt of public benefits does not by itself bar naturalization, and poverty or disability alone cannot be the basis for finding a lack of good moral character. The following, however, may be treated as fraud or misconduct: misstating income or household size when applying for benefits, continuing to receive benefits after becoming ineligible, failing to report changes in circumstances (for example, not disclosing extended travel abroad that affects SSI eligibility), and failing to tell the benefits agency about a sponsor’s support obligation when required.
If you reduced your work to stay eligible for benefits, this may also come up. The memo gives the example of an applicant who quits a job or significantly cuts hours to keep qualifying for food or housing assistance, rather than for a legitimate personal or medical reason. After an individualized review, an officer may find that this conduct falls short of the community’s expectation of self-sufficiency. The memo also stresses that this determination must be made case by case, weighing the reason for benefit use, efforts toward self-sufficiency, and positive contributions, and may never serve as an automatic basis for denial. In communities where most residents receive benefits, or where local law provides additional benefits, receiving them may be consistent with community standards.
If you have child support obligations, for example after a divorce, willfully failing to pay, paying a clearly insufficient amount, or abandoning a minor child may on its own prevent a finding of good moral character unless you can show extenuating circumstances. Even without a court order, parents have a duty to support their minor children. The memo also notes that a dependent’s receipt of means-tested benefits may, in some cases, be treated as evidence that the applicant failed to provide support. Support obligations owed abroad may also be reviewed.
How Can You Prepare Before Applying for Citizenship?
First, review the benefit records for yourself and your family members during the statutory period, confirm that each benefit was received in compliance with eligibility rules and reported accurately, and request records from the benefits agency if needed. Second, if you signed an I-864 or I-864A, gather evidence showing you met your support obligation, such as transfers to the sponsored relative, proof of living together, or records of paying living expenses. Third, if you have child support obligations, prepare the court order and payment records; if you ever fell behind, it is best to catch up before filing and keep proof. Fourth, if you reduced your work because of illness, caring for family, or similar reasons, keep medical records or other documentation. If you are unsure whether part of your history could raise an issue, consider having an attorney review it before you file the N-400, since a denied naturalization application stays in your immigration file.
Conclusion
The memo does not change the basic principle that lawfully receiving public benefits does not prevent naturalization. It does, however, make benefit use, Affidavits of Support, and family support a formal part of the good moral character review, and officers will ask more detailed questions. Every family’s income, benefits, and sponsorship situation is different. Organizing your records and preparing your explanations in advance will help you approach the interview with confidence.
The LYD Law immigration team can help naturalization applicants review their public benefits, Affidavit of Support, and child support records during the statutory period, assess potential good moral character risks, and prepare explanations and supporting documents before filing the N-400 and attending the interview. If you are planning to apply for citizenship, or have signed an Affidavit of Support for a family member, we welcome you to contact us to develop a preparation plan based on your circumstances.
