Updated 09/19/2026

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USCIS updated its denaturalization referral guidance on September 14, 2026. The legal grounds for revoking naturalization have not changed, but screening, referral priorities and review of past immigration histories have expanded.

USCIS Has Not Created New Legal Grounds for Denaturalization

On September 14, 2026, USCIS issued Policy Alert PA-2026-13, Revocation of Naturalization Referrals, updating Volume 12, Part L of the USCIS Policy Manual. The guidance became effective immediately.

The update does not fundamentally change the legal circumstances under which naturalization may be revoked.

The significant change concerns how USCIS identifies, reviews and refers potential denaturalization cases.

A New Immigration Filing May Trigger Review of the Citizen’s Prior History

The updated guidance provides that, for a pending or future-filed petition or application associated with a U.S. citizen, USCIS may determine whether that person lawfully obtained citizenship.

For example, a naturalized U.S. citizen who files an I-130 petition for a parent or spouse may again bring his or her prior immigration and naturalization history before USCIS.

This does not mean that every naturalized citizen who files an immigration petition will undergo a full denaturalization investigation. It does mean, however, that a new filing may create another opportunity for USCIS to identify serious issues in an older immigration record.

Which Cases Are Prioritized?

USCIS identifies priority areas including national security cases, war crimes and human-rights violations, gang and cartel activity, undisclosed pre-naturalization felonies, human trafficking and violent offenses, certain financial fraud, false identities, false claims to U.S. citizenship, unlawful pre-naturalization voting and marriage fraud.

These categories primarily identify enforcement and referral priorities; they do not themselves create new statutory grounds for revoking citizenship.

Can USCIS Revoke Citizenship on Its Own?

No.

USCIS may investigate and refer a case, but civil denaturalization generally requires an action in federal district court and the government must satisfy a demanding evidentiary standard.

A USCIS review, database flag or inconsistency in an old application therefore does not automatically result in loss of citizenship.

Who Should Consider Reviewing Their Immigration History?

Naturalized citizens may wish to obtain legal review before filing a new immigration petition if their history involves significant issues such as:

• Questions about whether the original green card was lawfully obtained;
• Prior marriage-fraud allegations;
• Multiple identities or materially inconsistent biographical information;
• Pre-naturalization criminal conduct that may not have been fully disclosed;
• False claims to U.S. citizenship or voting issues;
• Material inconsistencies among visa applications, asylum filings, adjustment applications and the N-400; or
• Potential material misrepresentations in earlier immigration proceedings.

Green card holders preparing to file Form N-400 should consider the same analysis where their immigration histories are complex.

Bottom line: The legal grounds for denaturalization have not materially changed, but USCIS has significantly strengthened the framework for identifying, screening and referring potential cases.