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On Dec. 4, 2017, the Supreme Court issued an order allowing President Trump’s Proclamation on Travel Ban to go fully into effect. With certain exceptions, this ban places entry restriction on nationals of eight countries – Chad, Iran, Libya, North Korea, Somalia, Syria, Venezuela, and Yemen. As previously reported, in September a U.S. District Judge in Hawaii blocked the Proclamation from taking effect, except for nationals of North Korea and Venezuela. On Nov. 13, the Ninth Circuit Court of Appeals temporarily put part of the lower court’s ruling on hold, allowing the Proclamation to take effect, but only for those individuals from the impacted countries who do not have bona fide ties to the United States.

Continue Reading Supreme Court Issues Order Allowing Full Implementation of Proclamation

The heavily anticipated new Executive Order (EO), “Protecting the Nation from Foreign Terrorist Entry into the United States,” banning nationals from six countries from entering the United States, was signed by President Donald Trump on March 6, 2017 with an effective date 10 days following on March 16, 2017. This new EO revokes and replaces the previous EO 13769 signed on Jan. 27, 2017. The replacement EO provides additional clarification that stemmed from judicial review. For a summary of EO 13769, and a history of events that transpired, please visit.

Highlights of changes in the new EO include:

  • The six countries under the travel ban are Iran, Libya, Somalia, Sudan, Syria, and Yemen.  Iraq has been lifted from the travel ban.
  • Clarification has been given that lawful permanent residents are not subject to the travel ban, and dual nationals may use another passport (that is not from one of the six countries) to enter the United States.
  • Waivers may be granted to individuals applying for a visa who are subject to the travel ban if: 1) denying entry during this period would cause undue hardship, 2) the entry would not pose a threat to national security, and 3) it would be in the national interest of the United States. Examples were provided of situations where a waiver would be appropriate.
  • Entry under the U.S. Refugee Admission Program will be halted for 120 days from March 16, 2017. Notably, the blanket halt on Syrian refugees has been removed.
  • The Visa Interview Waiver Program is suspended until further guidance from the Department of State.
  • Those who are in the United States will not have their visas revoked.

The new EO provides an explanation for some components of EO 13769 that are now rescinded, amended, or clarified in this Order. A section-by-section analysis is below:

Section 2:  Suspension of Visa Issuance- Iraq Removed

The text of this EO calls for the suspension of issuance of visas to nationals of Iran, Libya, Somalia, Sudan, Syria, or Yemen, except in case-by-case waivers, for 90 days from the effective date of the EO (March 16, 2017), while an ongoing assessment of the countries for terrorist threats is conducted. Notably, Iraq has been removed as one of the original countries subject to the travel ban. The reason cited is that the United States has been closely working with the Iraqi government and because of the military presence in Iraq, and Iraq’s commitment to fight ISIS, removing this country from the travel ban is justified.

In addition, the Secretary of Homeland Security, in consultation with the Secretary of State and the Director of National Intelligence, will conduct a worldwide review to identify additional information, if necessary, from any country to ensure that the individual applying for a visa benefit is not a security threat. Within 20 days of March 16, 2017, a required report will be submitted to the President on the results of the worldwide review. Copies of this report will also be given to the Secretary of State, the Attorney General, and the Director of National Intelligence.

Once the report has been submitted to all parties, the Secretary of State shall request the foreign governments to provide the information needed within 50 days of notification. After the 50 day period has expired, the Secretary of Homeland Security, with the Secretary of State and the Attorney General, will submit to the President a list of countries where certain categories of foreign nationals should be prohibited from visa issuance because they have not provided the information. Additional countries may also be submitted for consideration to be added to the list of countries where restrictions or limitations are deemed necessary to protect the United States. In the same way, countries may be recommended for removal from the list as well.

Four reports, each submitted within 30 days of the effective date of the Order (March 16, 2017) to President Trump, are required to document the progress. Continue Reading New Travel Ban Order to Temporarily Halt Entry for Those Seeking New Visas from 6 Muslim-Majority Countries

The Department of State’s (DOS) January Visa Bulletin brings some New Years cheer for China and “All Other Countries” designations indicating that that the EB-3 subcategory for professionals and skilled workers will advance by nine months for China, from June 1, 2010 to March 1, 2011, and seven months for “All Other Countries,” from November 1, 2012 to June 1, 2013.  Unfortunately, the EB-3 category for India continues to wallow in a mire of retrogression advancing only two weeks, from December 1, 2003 to December 15, 2003.

The EB-2 category offers little in the way of good reading with China advancing only a month, from January 1, 2010 to February 1, 2010, and India seeing no change from last month’s Bulletin, staying put at February 15, 2005.  Continue Reading January 2015 Visa Bulletin: Some Good News, But Executive Action Benefits Cannot Come Soon Enough

On November 20, 2014, President Obama released the long-anticipated “Executive Action” on immigration reform. See here, here and here. We will also post additional materials made available. Late last summer, the President had postponed the release of such action until after the mid-term elections. Despite the cries of overreaching and lack of authority by the Republican leadership in the House and the Senate, the President has now released a plan to begin immediately the process of implementing some new policies through published guidance and to begin implementation of other policies through proposed regulatory changes. Some opposed to these actions have vowed to block the implementation through judicial intervention, attempts to defund the programs and potentially through other political means.

We will monitor the status of each change and post updates as they become available.

The following is a brief summary of the Executive proposed actions that will impact business. We have divided them broadly into three categories: 1) Changes done through guidance; 2) Changes that will need regulatory action; and 3) Changes that are still being discussed through a “Presidential Memorandum” process.

Administration Guidance without New Regulation       

  • Expansion of Deferred Action. Provide deferred action with employment authorization and advance parole, to include:
    • Parents of U.S. citizens and Permanent Residents. (Must have lived in the U.S. for 5 years and must have entered by January 1, 2010.)
    • Expansion of current Deferred Action Program to include Individuals who have resided in the U.S. for 5 years or more. There will no longer be an age limit.
  • Parole in Place. Expand PIP eligibility and confirm that Matter of Arrabally & Yerrabelly applies to all who depart and return on advance parole.
  • National interest waivers available for those in positions to create jobs, and those fulfilling shortage occupations.
  • Exemption from the H-1B cap. Interpret the term “affiliated or related nonprofit entity” to an institution of higher education for H-1B cap-exemption purposes under INA §214(g)(5)(A) more flexibly.

Regulatory Changes through the Administration Procedure Act/Federal Register

  • Enable entrepreneurs to be paroled into the U.S. and work if they are researchers, inventors or founders of businesses.
  • Expand availability of optional practical training for graduating F-1s:
    • Make the additional time available for STEM OPT graduates and expand the definition of STEM.
  • Early Adjustment. Enable individuals who are eligible to apply for adjustment of status, but for a non-current priority date, to file for adjustment and receive work authorization and advance parole.
  • Work authorization for spouses of H-1Bs. Finalize pending regulation.
  • Improve the L-1 adjudicative process:
    • Release of guidance on L-1Bs.

Presidential Memorandum on Visa Modernization – Further Discussion

  • Recapturing permanent resident numbers based on numbers allocated by Congress but left unused. When the government is unable to issue the allocated immigrant visa numbers for preference immigrants in a particular fiscal year, despite sufficient demand for such immigrant visa numbers, then the Department of State will ensure those unused immigrant visa numbers are used in subsequent years, in order to better effect Congressional objectives.
  • Derivative spouses and children not counted toward preference quotas.
  • Other important issues related to help revise the visa process for businesses.

Compliance Concerns with the extension of Deferred Action

Extensions of temporary relief for workers already in the U.S. could make their status more confusing to employers and put business owners in an untenable position with regard to employment eligibility verification compliance. Employers are particularly vulnerable when a current employee comes forward and reveals that s/he has been working for the company under a false identity and asks the employer to provide evidence of his/her employment history in order to take advantage of Executive Relief. An employer faces civil and potentially criminal liability for past hiring of unauthorized workers and also may face discrimination charges for hiring newly documented workers who previously presented fraudulent documents. Additionally, employers who do provide documentation to unauthorized workers may be identified as a target for future government enforcement activity.

Legislation to permanently address many of the items identified in the President’s executive action is still very much needed. We will continue to monitor and bring our readers updates as these initiatives, and reactions to them, unfold.

CEOs from top corporations have joined the chorus of companies pushing for Immigration Reform. In a letter to Congress, these executives outlined several areas that need to be addressed through meaningful Immigration Reform in order for companies to successfully conduct business, including:

Continue Reading Leading Executives Urge Congress to Act Now on Immigration Reform

On Jan. 1, 2026, U.S. Citizenship and Immigration Services (USCIS) issued a new policy memorandum—PM-602-0194: Hold and Review of USCIS Benefit Applications Filed by Aliens From Additional High-Risk Countries—that has had wide-ranging effects on immigration benefit processing. This guidance builds on the expanded travel restrictions under Presidential Proclamation 10998 (PP 10998), Restricting and Limiting the Entry of Foreign Nationals to Protect the Security of the United States, signed on Dec. 16, 2025, and effective Jan. 1, 2026.

PM-602-0194 directs USCIS officers to take three main actions:

  1. Place a holdon all pending benefit applications, subject to certain exceptions and regardless of entry date, for nationals of the countries listed in PP 10998, pending a comprehensive review;
  2. Conduct a comprehensive review of all policies, procedures, and screening and vetting processes for benefits requests for nationals of countries listed in PP 10998; and
  3. Conduct a comprehensive re-review of approved benefit requests for nationals of countries listed in PP 10998 that were approved on or after Jan. 20, 2021.

Now that almost 60 days have passed since the announcement, applicants may be seeing the effects of the policy in delayed applications, and in some cases requests for additional evidence that USCIS might consider in determining whether to exercise favorable discretion.

Who Is Impacted?

The hold and comprehensive review now apply to nationals of all countries listed in PP 10998. This expanded list includes (among others):

  • Afghanistan
  • Angola
  • Antigua and Barbuda
  • Benin
  • Burkina Faso
  • Burma (Myanmar)
  • Chad
  • Côte d’Ivoire
  • Cuba
  • Dominica
  • Equatorial Guinea
  • Eritrea
  • Gabon
  • The Gambia
  • Haiti
  • Iran
  • Laos
  • Libya
  • Malawi
  • Mali
  • Mauritania
  • Niger
  • Nigeria
  • Senegal
  • Sierra Leone
  • Somalia
  • South Sudan
  • Sudan
  • Syria
  • Tanzania
  • Togo
  • Tonga
  • Turkmenistan
  • Venezuela
  • Yemen
  • Zambia
  • Zimbabwe

Individuals with Palestinian Authority–issued or endorsed travel documents are also included. This means the policy applies based on nationality, country of birth, or citizenship acquired through Citizenship-by-Investment (CBI) programs.

Exceptions

PM-602-0194 allows USCIS to continue adjudicating certain categories of benefit requests, including:

  • Individuals with a pending Form I-90, Form N-565, and Form N-600;
  • “Benefit requests that are a priority for law enforcement and where [Immigration and Customs Enforcement] has requested that USCIS take adjudicative action to uphold public safety or national security;”
  • Form I-765, categories(c)(11) for an alien paroled into the United States in the public interest or temporarily for emergency reasons and (c)(14) for an alien granted deferred action only when the request comes from law enforcement because the noncitizen is assisting law enforcement;
  • Initial Form I-765, category (c)(8) for an asylum applicant (with a pending asylum application) who filed for asylum on or after Jan. 4, 1995;
  • Benefit requests for individuals whose entry would serve a United States national interest;
  • Benefit requests for athletes or members of an athletic team, including the coaches, persons performing a necessary support role, and immediate relatives for the purpose of participating in the World Cup, Olympics, or other major sporting event as determined by the secretary of state;
  • Benefit requests, or associated underlying benefits, for any programs that are terminated or discontinued as a result of an executive order, proclamation, Federal Register notice, or directive issued by the president, the secretary of homeland security, or the USCIS director; and
  • Decisions to automatically terminate automatic or ancillary benefit requests related to when an individual is granted legal permanent resident status or becomes a naturalized citizen.

The exceptions to the policy are limited and may not apply to many applicants. Moreover, almost 60 days have passed since this policy was announced and there are no further updates as to when these applications may go back into normal processing. Without any meaningful update from USCIS, applicants from the affected countries may continue to experience significant delays and/or additional USCIS scrutiny in the adjudication of their cases, irrespective of whether the applicant or beneficiary is inside or outside the United States.

The United States has introduced a new immigration pathway aimed at attracting ultra-high-net-worth individuals: the Gold Card Program, created by Executive Order 14351 in September 2025. Because this program arises from executive action rather than an act of Congress, it operates outside the traditional statutory framework that governs the EB-5 immigrant investor program. As a result, it presents both opportunities and legal uncertainties for prospective applicants.

Below is a detailed analysis of the Gold Card program’s structure, requirements, risks, and how it compares to the long-established EB-5 investor visa category.

What the Gold Card Program Is—and Why It Is Different

Unlike EB-5, Congress did not enact the Gold Card. It is an executive initiative, implemented solely through presidential authority. That distinction has significant implications:

  • It may be modified, suspended, or rescinded by a future administration.
  • It does not include statutory grandfathering protections. Investors who begin the process today do not have guaranteed eligibility if the program is later withdrawn or struck down by a court.
  • It relies on existing immigrant categories (EB-1A and EB-2 NIW) for visa issuance, meaning adjudications may still need to satisfy the regulatory standards for extraordinary or exceptional ability in the national interest. For example, EB-1A normally requires the applicant to have “sustained national or international acclaim.” Exceptional ability EB-2 normally requires the applicant to have an advanced degree and meet other criteria, in addition to meeting the requirements for a National Interest Waiver.

In effect, the Gold Card overlays a financial-contribution model onto existing immigrant visa frameworks, creating a hybrid program that blends donation-based residency incentives with employment-based visa adjudications.

Key Features of the Gold Card

Although the Gold Card uses employment-based categories, the distinguishing elements relate to its funding mechanism, processing model, and tax-related incentives.

Donation Model: Applicants must make a non-refundable “gift” to the U.S. government:

  • $1 million per individual applicant, including each family member; or
  • $2 million for corporate-sponsored applicants, plus $1 million per dependent; and
  • $15,000 USCIS processing fee per person.

Unlike EB-5, the funds are not invested, do not carry job-creation obligations, and are not returned under any circumstances.

New Fast-Track Petition: Form I-140G

The program introduces Form I-140G, a petition similar to a premium-track I-140 but tied to visa availability. Petition processing may be completed in weeks, but immigrant visa issuance still depends on priority date movement and the applicant’s country of birth. Applicants born in certain countries may still experience long wait times for the immigrant visa due to existing EB-1 and EB-2 visa backlogs.

No Adjustment of Status

Significantly, Gold Card applicants must process through a U.S. embassy or consulate abroad. The program explicitly bars Adjustment of Status, eliminating the ability to apply from within the United States. It is unclear why.

Platinum Tier

A forthcoming $5 million Platinum contribution offers extended U.S. presence (up to 270 days annually) and preferential tax treatment on foreign-source income. It does not provide permanent residency; rather, it functions as a long-term entry and tax-benefits privilege for globally mobile individuals.

Navigating Requirements and Process

Although the Gold Card avoids the rigorous EB-5 job-creation framework, it still requires detailed documentation.  The current process appears as follows:

  1. Source and Path of Funds: Applicants must prove lawful origin of the gifted amount, consistent with employment-based immigrant standards. It appears the source and path of funds requirements is similar to EB-5 standards.
  2. Filing of Form I-140G with the donation documentation and fees.
  3. USCIS Adjudication under EB-1A or EB-2/NIW standards.
  4. Consular Processing and visa issuance once the priority date is current.

The reliance on EB-1 and EB-2 legal standards introduces a substantive evaluation that some high-net-worth individuals may not expect; the financial contribution does not necessarily override statutory eligibility requirements.  Further clarification on this point is required from USCIS.

Comparison to the EB-5 Immigrant Investor Program

Created by Congress in 1990, EB-5 remains the only statutory investment-based pathway to a U.S. green card. It requires:

  • $800,000 investment in a Targeted Employment Area (TEA) or $1,050,000 outside a TEA.
  • Creation of 10 full-time U.S. jobs.
  • Capital at risk throughout the investment period.
  • Eligibility for Adjustment of Status and concurrent filing inside the United States.
  • Access to grandfathering protections for those who apply before Sept. 30, 2026, under the Reform and Integrity Act.

EB-5’s core advantages are family coverage, permanence, and legal stability. Its disadvantages are longer timelines and the need to satisfy job-creation and project-risk requirements.

Side-by-Side Analysis

AspectGold Card (EO 14351)EB-5 Investor Visa (Statute)
AuthorityExecutive order; vulnerable to legal challenge and repeal; no grandfatheringCongressional statute; RIA provides statutory grandfathering through Sept. 30, 2026
Cost$1M per family member; $2M if company-sponsored; $5M Platinum tier; $15k per person filing fee$800k–$1.05M investment covers entire family
Family CoverageEach family member pays full gift and feeOne investment covers spouse and children under 21
RefundabilityNoneInvestment generally returnable after project exit or if petition is denied
RequirementsNo job creation or business risk; gift treated as government donationMust create 10 full-time jobs; capital must remain at risk
TimelinePetition may be processed within weeks; visa issuance tied to EB-1/EB-2 backlogsFour to six years typical for permanent residency
Green Card OutcomePermanent residency unless program is repealedTwo-year conditional residency, then permanent upon I-829 approval
Preference CategoryEB-1A or EB-2/NIWEB-5
Process(1) Register on trumpcard.gov, (2) File I-140G, and (3) Consular process only(1) File I-526E, (2) AOS or consular, and (3) File I-829 after two years

Sample Cost Comparison: Family of Six

The contrast in total cost is stark:

Gold Card

  • Donation: $1,000,000 × 6 = $6,000,000
  • USCIS fees: $15,000 × 6 = $90,000
  • Total: $6,090,000

EB-5

  • Investment: $800,000 (TEA)
  • USCIS fees: $3,675
  • Total: $803,675

For large families, the Gold Card’s per-person model makes it more expensive than EB-5.

Practical Considerations for Investors

While the Gold Card potentially offers speed and eliminates job-creation risk, the program presents legal and strategic uncertainties:

  • Regulatory durability is weak compared to EB-5’s statutory foundation.
  • Visa availability remains tied to EB-1 and EB-2 demand, meaning individuals from high-demand countries may still face backlogs.
  • The high per-person cost may outweigh benefits for families.

EB-5, despite its longer timeframe and job-creation obligations, aims to provide stability, family efficiency, and an established statutory framework—elements some investors value when making long-term relocation plans.

The Gold Card represents an untested pathway for those seeking rapid U.S. residency through financial contribution. EB-5 remains the more established, predictable option for investors prioritizing statutory protection, family coverage, and long-term stability. The optimal route depends on the applicant’s priorities: speed and simplicity versus durability and cost efficiency.

On Dec. 2, 2025, USCIS issued a policy memorandum PM-602-0192 directing officers to place an adjudicative hold on

  1. all pending asylum applications (Form I-589), regardless of nationality, and;
  2. most pending immigration benefit requests – such as green cards, adjustment of status, travel documents, naturalization, etc. – filed by nationals of 19 countries designated as “high risk,” regardless of the entry date.

For nationals from above-mentioned 19 “high-risk” countries, the memorandum also mandates a comprehensive re-review of certain previously approved or pending cases if the applicant entered the United States on or after Jan. 20, 2021. This may include re-interviews, additional vetting, identity verification, or further security-based screenings.

The 19 “high risk” countries include: Afghanistan, Burma, Chad, Republic of Congo, Equatorial Guinea, Eritrea, Haiti, Iran, Libya, Somalia, Sudan, Yemen, Burundi, Cuba, Laos, Sierra Leone, Togo, Turkmenistan, and Venezuela.

This policy is grounded in Presidential Proclamation 10949 (June 4, 2025), Restricting the Entry of Foreign Nationals To Protect the United States From Foreign Terrorists and Other National Security and Public Safety Threats, as known as the “travel ban,” and Executive Order 14161 (Jan. 20, 2025), Protecting the United States from Foreign Terrorist and Other National Security and Public Safety Threats, both of which emphasize enhanced national security review of foreign nationals from certain jurisdictions.

Why the Administration Implemented this Policy

The Memorandum cites two recent incidents involving foreign nationals accused of planning and attempting terrorist activity after entering the United States. USCIS notes that gaps in prior screening measures necessitate a broad reassessment of individuals from certain regions.

Impact on Affected Applicants

USCIS acknowledges that the hold and re-review requirements will slow adjudications, even significantly, but asserts that the delay is justified given the national security rationale. Applicants who have pending immigration benefits request may expect delays. The Memorandum also allows USCIS to require interviews for applicants who ordinarily would not need one. Though this policy does not automatically deny applications, adjudications will not resume until USCIS completes its review and issues implementing guidance. Applicants should also be aware that identity-related issues will receive heightened scrutiny. Inability to establish identity or inconsistent documentation may independently trigger ineligibility under the Immigration and Nationality Act (INA).

Practical Considerations for Affected Applicants

Nationals of the 19 “high-risk” countries may wish to:

  • Prepare for extended adjudication timelines;
  • Expect possible requests for re-interviews or additional evidence;
  • Ensure identity documents are complete and consistent; and
  • Consult counsel before international travel, especially where advance parole or re-entry permits are on hold.

Asylum applicants of any nationality should:

  • Monitor for updated operational guidance, which USCIS states will be issues within 90 days; and
  • Acknowledge that no asylum applications will move forward until USCIS lifts the hold.

Takeaways

This Memorandum represents the broadest national-security-based pause on immigration benefits since the “travel ban era.” USCIS states that the hold will remain in effect until lifted by a superseding directive from the USCIS director. It also emphasizes that this policy does not create individual rights or enforceable benefits. Given the scope of the pause, the enhanced security vetting it requires, and its overlap with prior travel ban, this policy may influence adjudications for a considerable period. USCIS has committed to issuing additional operational guidance within 90 days, which will determine how these reviews are implemented in practice and how quickly any movement on pending cases may resume.

This week USCIS announced that in a continued effort to upgrade the Systematic Alien Verification for Entitlements (SAVE) program, states may now use SAVE to verify the U.S. citizenship status of those voting in federal elections.

States may now use SAVE to verify voters’ citizenship status using the last four digits of the voter’s Social Security number, as opposed to the previously required nine digits. USCIS spokesman Matthew Tragesser commented, “By allowing states to efficiently verify voter eligibility, we are reinforcing the principle that America’s elections are reserved exclusively for American citizens. We encourage all federal, state, and local agencies to use the SAVE program.”

In response to Executive Order 14248, “Preserving and Protecting the Integrity of American Elections,” this SAVE upgrade aims to allow registered users to create a SAVE case without needing a Department of Homeland Security (DHS) identifier or complete Social Security number. If a voter cannot be identified using their Social Security number, the user agency is prompted to resubmit the search using a DHS-issued identification number or direct the voter to the Social Security Administration to update their record. 

SAVE’s voting initiatives, combined with SAVE’s status verifications for new benefit requests, have together resulted in more than 205 million status verifications in 2025 compared to the 25 million verification queries for all of 2024.

To date, 26 states already have, or are in the process of establishing, a memorandum of agreement for voter verification with SAVE. SAVE is an online service administered by U.S. Citizenship and Immigration Services (USCIS) that provides immigration status and U.S. citizenship information to federal, state, local, territorial, and tribal agencies. SAVE enables registered user agencies to make decisions for applicants seeking benefits and licenses. Approximately 1,200 agencies nationwide use SAVE to support their benefit eligibility and licensing determinations. This includes agencies such as those that provide health care benefits, social security benefits, education grants and assistance, state driver’s licenses and ID cards, and occupational and professional licenses.

On Sept. 18, 2025, U.S. Citizenship and Immigration Services (USCIS) published a Federal Register notice announcing the implementation of the 2025 Naturalization Civics Test. This updated version reintroduces the 2020 test format, with modifications, and is designed to assess applicants’ understanding of U.S. history and government.

The new test will apply only to naturalization applications filed on or after Oct. 20, 2025. Applications submitted before that date will continue to be assessed under the 2008 test format, which remains in use during the transition period.

In its notice, USCIS outlines the purpose and legislative foundation of the civics test, emphasizing that U.S. citizenship is the most meaningful immigration benefit the country offers. It confers vital rights and responsibilities, including voting, serving on juries, and defending the Constitution.

The 2025 version expands the question bank to 128 items, increasing the number of questions asked during interviews from 10 to 20, with a passing score of 12 correct answers. Approximately 75% of the questions are derived from the 2008 test, with some carried over verbatim. The remaining 25% are new, while certain questions from the 2008 version have been removed.

In accordance with Section 312(b)(3) of the Immigration and Nationality Act, USCIS continues to offer special consideration for applicants aged 65 or older who have been lawful permanent residents for at least 20 years. These individuals may take a simplified version of the test, consisting of 10 questions selected from a designated pool of 20, with a passing score of 6 correct answers.

The reimplementation of the 2020 test reflects a broader policy shift, aligned with Executive Order 14161, which President Donald Trump issued on Jan. 20, 2025. The directive instructed the secretary of homeland security to evaluate immigration programs for their effectiveness in promoting assimilation, civic preparedness, and attachment to American principles.

Historically, the 2020 test was in effect from Dec. 1, 2020, to April 30, 2021, before being replaced by the 2008 version on Feb. 22, 2021. The 2025 test marks a return to the 2020 format, with procedural and content updates.

A key modification in the 2025 test is its administration protocol. Unlike the 2020 version, where officers asked all 20 questions regardless of outcome, the 2025 version allows officers to stop once the applicant answers 12 correctly (pass) or 9 incorrectly (fail). This change streamlines the interview process while maintaining the test’s rigor. The test remains oral, with no multiple-choice options.

Some applicants will not be subject to the new test until at least three months after the notice, as it applies only to applications filed on or after Oct. 20, 2025. USCIS has released updated study materials and encourages applicants to verify which version of the test applies based on their filing date.

In its announcement, USCIS described the 2025 Naturalization Civics Test as the first in a multi-step overhaul of American citizenship standards, signaling that additional updates may follow in the coming months.

At this time, no changes have been made to the English language components of the naturalization test, which include reading, writing, speaking, and comprehension.