New Good Moral Character Requirements for US Citizenship: Proving You Are an ‘Average Citizen’ Under the New USCIS Policy and the Affirmative Case for Naturalization

By Richard T. Herman, Esq.

The journey to U.S. citizenship, or Naturalization, for a Lawful Permanent Resident** (LPR)** has fundamentally changed. On August 15, 2025, U.S. Citizenship and Immigration Services (USCIS Policy) issued a critical memorandum (PM-602-0188) that redefined how officers evaluate Good Moral Character** (GMC)** for Naturalization Applicants. USCIS issued this policy, and it is currently being implemented across field offices. The days of simply having a clean criminal record and expecting approval are over.

The new guidance requires a Holistic Review—a Totality of the Circumstances approach—that actively measures an applicant’s Positive Contributions to American society. This shift places a much greater burden on the applicant to present an affirmative case demonstrating they are a responsible, contributing member of American society, commensurate with the ethical standards of an “average citizen.” The new approach focuses on thoroughly evaluating an applicant’s good moral character, considering multiple factors beyond just criminal records. This detailed guide breaks down this new standard and provides a clear roadmap for documenting your worthiness for the privilege of citizenship.

Understanding the Shift: From ‘Absence of Misconduct’ to ‘Presence of Virtue’

The core of the USCIS Policy change is the departure from a mechanical, checklist-style review. Now, establishing good moral character requires not just the absence of statutory bars (like certain felonies or crimes), but also the demonstration of positive personal attributes and civic virtue. The new framework demands proof of the presence of civic virtue.

What is the New Good Moral Character (GMC) Standard?

The USCIS Policy memorandum, formally titled “Restoring a Rigorous, Holistic, and Comprehensive Good Moral Character Evaluation Standard for Aliens Applying for Naturalization,” explicitly mandates two things: officers must place greater emphasis on an applicant’s positive attributes and they must scrutinize behaviors that may not be criminal but are “inconsistent with civic responsibility.” It is important to note that this guidance is separate from the official USCIS Policy Manual, and recent policy memos may impact how officers interpret eligibility requirements.

This holistic review means that USCIS evaluates the whole person, not just their legal record, considering overall character, behavior, and compliance with societal norms when determining eligibility for naturalization.

The August 15, 2025, Policy Memorandum (PM-602-0188):

• This Policy Memorandum (PM-602-0188) (USCIS) signals a return to a rigorous, comprehensive assessment that considers the applicant’s complete life history, with particular focus on the applicant’s conduct during the statutory period, which is typically a five year period. It is a fundamental shift in how the Form N-400 is adjudicated.

Defining the “Totality of the Circumstances” Review:

This legal standard requires the adjudicating officer to consider all available favorable and adverse evidence in the applicant’s life story, not just during the statutory period (typically the five years preceding the Form N-400 filing). In this evaluation, favorable factors—such as positive contributions to the community or evidence of rehabilitation—are weighed alongside any adverse evidence. Conditional bars, such as multiple DUI convictions and unlawful voting, apply to offenses committed during this statutory period. Prior conduct, if relevant to the applicant’s present moral character or lack of Rehabilitation, can still be considered.

The New Bar: Character Commensurate with ‘Average Citizens’

The new USCIS Policy defines Good Moral Character as a character “commensurate with the standards of average citizens of the community in which the alien resides,” requiring Naturalization Applicants to demonstrate their alignment with local ethical and societal norms. This phrase introduces significant Subjectivity into the process.

Why the USCIS Shift Creates Uncertainty

The emphasis on an “average citizen’s” behavior introduces ambiguity. USCIS officers now have increased discretion, potentially leading to inconsistent decisions across different field offices. Immigration officials assess each applicant individually, applying the preponderance of evidence standard to determine if the applicant likely meets the criteria. Applicants must proactively shape the narrative, as simply meeting minimum legal requirements is no longer sufficient to overcome this inherent Subjectivity. The burden of proof now clearly rests on the Naturalization Applicant to affirmatively establish their moral worthiness, with a particular focus on showing good moral character through their actions and supporting evidence.

The Essential Categories of ‘Positive Contributions’ for USCIS Review

The USCIS Policy definitively lists the categories of Positive Contributions officers must weigh as affirmative evidence of GMC. In the holistic review process, USCIS officials consider the applicant’s positive contributions alongside any adverse factors, reflecting a more nuanced assessment of moral character. Naturalization Applicants must proactively document these factors.

Category 1: Active Community Involvement and Civic Engagement

This is the most visible way to demonstrate integration and commitment. Being actively engaged in community activities is a key indicator of good moral character, as it shows ongoing positive contributions and involvement in society.

• Volunteer Service and Charitable Activities: Documenting Selfless Action
• What Counts: Consistent, sustained involvement (e.g., weekly shifts at a food bank, coordinating a neighborhood clean-up, coaching a youth sports team). One-time donations or brief participation will likely be viewed as insufficient.
• Example Documentation: Official letters from non-profit organizations on letterhead, signed by a supervisor, detailing the nature and duration of the service; volunteer hour logs (annual totals); awards or certificates of recognition.
• Civic Participation and Religious Contributions: Showing Leadership
• What Counts: Active participation in democratic institutions or significant roles within a religious or cultural organization (e.g., serving on a local school committee, organizing community outreach at a place of worship).
• Example Documentation: Proof of holding a formal position (e.g., meeting minutes, official role description); official letters from religious leaders attesting to the applicant’s character and service.
• Neighborhood and Local Contributions:
• What Counts: Consistent efforts to maintain one’s residence and contribute positively to the immediate area.
• Example Documentation: Affidavits from neighbors or landlords attesting to positive community reputation and adherence to neighborhood rules; records of attending local town hall meetings or police-community forums.

Category 2: Demonstrated Family Caregiving and Responsibility

Fulfilling familial duties and upholding family responsibilities is deemed a fundamental Positive Contribution to the nation’s social fabric, as it demonstrates good moral character through commitment to caregiving and family commitments.

• Caregiving for Dependents (Children and Elderly Parents): Documenting Stability
• What Counts: Providing primary emotional, physical, and/or financial support to a dependent, especially U.S. citizens or LPRs.
• Example Documentation: Birth certificates of U.S. citizen children; medical records or notarized affidavits proving full-time caregiving responsibilities for an elderly or disabled relative; evidence of financial contributions, such as joint bank accounts or money transfer receipts.
• Strong Family Ties and Lawful Residency History:
• What Counts: The number and strength of ties to the U.S. (e.g., U.S. citizen spouse, children, siblings) and a long, uninterrupted history of Lawful Permanent Resident (LPR) status.

Category 3: Financial Responsibility and Economic Stability

Financial probity is central to the concept of Good Moral Character.

• Stable and Lawful Employment History: Proof of Economic Contribution
  • What Counts: Consistent, long-term employment that contributes to the U.S. economy, especially in critical or in-demand sectors.
  • Example Documentation: Comprehensive W-2s or 1099s for the statutory period; employment verification letters from current and former employers on company letterhead; a professional resume detailing the length of service and achievements.
• Compliance with Tax Obligations and Financial Health: The Non-Negotiable Factor
  • What Counts: Filing and paying all federal, state, and local taxes fully and on time. Any outstanding debt or failure to file is a significant negative factor.
  • Example Documentation: Official IRS Tax Transcripts for the entire statutory period; documentation proving repayment plans for any past tax issues or debts; proof of financial independence.

Category 4: Educational Attainment and Professional Growth

Commitment to self-improvement and integration is viewed favorably.

• Degrees, Certifications, and Continuing Education:
  • What Counts: Any formal education or professional development completed while residing in the U.S.
  • Example Documentation: Diplomas, transcripts, professional license copies, and certificates of completion for vocational training or ESL/civics courses.
• Demonstration of Language Proficiency and American Values:
  • What Counts: Going beyond the minimum required for the interview (e.g., taking advanced English classes, demonstrating a deep knowledge of American history or current events).

Addressing Negative Factors with Evidence of Genuine Rehabilitation

The Holistic Review provides an opportunity for Naturalization Applicants with past issues—even conditional bars, such as fraud or other disqualifying conduct—to submit counterbalancing evidence. USCIS officers are now explicitly directed to consider Rehabilitation.

The Four Pillars of Rehabilitation Evidence

The New Scrutiny: What is Beyond the Criminal Record?

The USCIS Policy directs greater scrutiny toward behavior categorized as “technically lawful” but detrimental to GMC.

• Habitual Reckless Driving and Repeated Traffic Violations: A pattern of traffic offenses, even if minor, may indicate a disrespect for law and order. A review of driving records (MVR) is now more critical than ever.
• Social Misconduct: This vague category covers actions like documented patterns of harassment, aggressive solicitation, or repeated violations of apartment/neighborhood rules, as determined by local standards.
• Unlawful Voting/False Claims to Citizenship: This remains a major area of scrutiny. Any registration to vote or actual voting before achieving citizenship can trigger a permanent or conditional bar, making accurate disclosure mandatory.
• Marijuana-Related Offenses: Despite state-level legalization in some areas, marijuana-related offenses remain a conditional bar to good moral character under the new policy.

Navigating the High Uncertainty of the Holistic Review

The introduction of intense Subjectivity into the Holistic Review is the primary source of high uncertainty for Naturalization Applicants. The broader review expected from the updated policy may result in more subjective denials.

How Geographic Context Impacts the ‘Average Citizen’ Standard (GEO)

The standard of an “average citizen” is not uniform. The same behavior may be viewed differently based on local norms, a key GEO factor:

This variation means every Form N-400 application must be locally sensitized, emphasizing contributions that resonate with the values of the applicant’s specific community.

The Threat of Deeper Background Investigations

The new policy hints at more rigorous vetting. USCIS officers are empowered to go beyond standard databases. Applicants should expect more thorough background reviews that go beyond criminal record checks.

• The new guidance empowers USCIS officers to conduct deeper investigations, which may include interviewing neighbors, employers, and co-workers to verify an applicant’s community reputation and adherence to social norms, requiring the applicant’s entire life story to be verifiable. Applicants must ensure their public life is consistent with their documented narrative.

FAQ: Essential Questions for the New GMC Standard

Q: Can a single speeding ticket disqualify my naturalization application?

A: A single speeding ticket is unlikely to be a bar to GMC. However, a pattern of reckless or habitual traffic infractions (e.g., five or more tickets in the statutory period) could be interpreted under the Holistic Review as a lack of respect for law and order, potentially leading to a denial. Proactive disclosure and a strong record of Positive Contributions are essential to counter this.

Q: If I have a past conviction, is Rehabilitation guaranteed to overcome it?

A: No. While Rehabilitation is now an explicit factor, it must be genuine and sustained. It cannot overcome a permanent statutory bar (e.g., murder, aggravated felony). For conditional bars (e.g., multiple DUIs), documented evidence of genuine, verifiable reform (like completion of treatment and a long period of sobriety) is mandatory but not a guarantee.

Q: What is the single most effective piece of evidence I can submit?

A: There is no single “most effective” document, as GMC requires a Holistic Review. However, IRS Transcripts showing consistent tax compliance and specific, detailed affidavits from respected community leaders or long-term employers are generally the strongest pillars of evidence, as they confirm both Financial Responsibility and Community Involvement.

Q: Does USCIS consider online or social media activity?

A: Although not explicitly detailed in the PM-602-0188, USCIS has the right to conduct comprehensive Background Reviews. Any public-facing behavior that contradicts an applicant’s claim of Good Moral Character or commitment to the U.S. Constitution (e.g., promoting violence, advocating for terrorism, or public displays of habitual intoxication) may be subject to scrutiny and could weigh negatively under the Totality of the Circumstances.

Q: Does failure to pay off all debt (e.g., credit cards, medical bills) disqualify me?

A: Ordinary debt that is being managed is unlikely to disqualify you. However, willful failure to meet financial obligations, particularly court-ordered debts like child support or unpaid taxes, is a significant negative factor and can be a bar to GMC. The key is to demonstrate a pattern of Financial Responsibility and good-faith efforts to repay.

Conclusion: Citizenship as a Privilege Demanding Affirmative Character

The August 15, 2025, USCIS Policy is a definitive statement: U.S. citizenship is not just a right earned by waiting, but a privilege granted based on demonstrated merit. Naturalization Applicants must move beyond merely avoiding legal trouble and instead proactively compile a compelling narrative of Positive Contributions. Under the new guidance, USCIS will place greater emphasis on positive factors, including community involvement and educational attainment. The Holistic Review demands diligence, transparency, and a strategic legal approach to manage the new era of Subjectivity and heightened scrutiny. Success under this new standard requires presenting a well-documented life story that affirms the applicant’s ethical commitment to American society.

Key Takeaways for Naturalization Applicants in the New Era

1. Documentation is Power: Treat every Positive Contribution as a required piece of evidence. Proactively collect letters, transcripts, and financial records.
2. Proactivity is Essential: Do not wait for a Request for Evidence (RFE). Submit your “Full Story” upfront with your Form N-400.
3. Address the Negative Head-On: If past issues exist, the only path forward is to demonstrate genuine and sustained Rehabilitation.

Author Bio/Profile

Richard T. Herman, Esq., is a nationally recognized immigration lawyer and advocate for immigrants, known for his commitment to ethical and holistic representation. He is the founding attorney of the Herman Legal Group (Law Firm for Immigrants), a renowned immigration law firm dedicated to helping individuals and businesses navigate the complex landscape of U.S. immigration law. Richard is the co-author of the critically acclaimed book, Immigrant, Inc.: Why Immigrant Entrepreneurs Are Driving The New Economy, which explores the positive impact of immigrants on the American economy and society.

To learn more about Richard T. Herman and the Herman Legal Group’s approach to Naturalization applications under the new USCIS Policy, please visit the Herman Legal Group website page or view Richard’s detailed bio page.

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