Citizenship and Naturalization

Federal Rulemaking is one of the most direct ways that the public can participate and shape policies and practices of executive agencies. Federal regulations govern the executive agencies charged with enforcing the United States’ immigration laws and granting immigration benefits to eligible applicants. However, the process of Federal Rulemaking is often misunderstood and public participation in the process is under-utilized. This practice advisory provides an overview of the federal regulatory and rulemaking process as well as the authorities that govern this process as well as a guide to commenting on proposed rules and practical tips for navigating the resources available to the public.
This alert describes recent changes to the naturalization disability waiver. On October 19, 2022, USCIS announced major revisions to the Form N-648, which is used by naturalization applicants who seek a waiver of the English and/or civics requirement based on a disability or impairment that causes the applicant to be unable to learn or demonstrate knowledge of English and/or civics. USCIS also published major changes to the accompanying USCIS Policy Manual guidance.

Citizenship and Naturalization

Citizenship and Naturalization

 

There are many advantages to becoming a U.S. citizen—including helping family members immigrate to the United States, traveling with a U.S. passport, and voting in U.S. elections. Millions of lawful permanent residents are eligible to naturalize but need support to take the important step of becoming a U.S. citizen.

The Immigrant Legal Resource Center (ILRC) provides critical support to organizations helping immigrants navigate the naturalization process. We provide trainings and technical assistance, publish the top practitioner’s guide, Naturalization and U.S. Citizenship: The Essential Legal Guide, engage in federal and local advocacy. Through the national New Americans Campaign, we also develop and disseminate best practices in providing access to naturalization services.

Latest Resources

Public Comments / Sign-on Letters
Resources
Publication Date
10/13/2026
On October 12, 2026, the Immigrant Legal Resource Center (ILRC) submitted a comment opposing a new Department of Homeland Security (DHS) interim final rule that would make electronic filing mandatory for immigration benefit applications, along with a proposed form requiring applicants to request a waiver from that requirement.
Practice Advisory
Resources
Publication Date
10/07/2026
This practice advisory analyzes the recent changes in the U.S. Citizenship and Immigration Services Policy Manual regarding the implementation of neighborhood investigations in naturalization adjudications. The advisory includes practical tips and considerations that practitioners should use when advising clients on applying for naturalization under this new policy.
Practice Advisory
Resources
Publication Date
10/07/2026
USCIS recently announced that naturalization applicants may receive neighborhood visits to ask neighbors and/or co-workers questions about the applicant’s work, family status, social activities, travel, criminal history, and more. USCIS also acknowledged that it has discretion to waive these neighborhood visits. New USCIS guidance invites applicants to affirmatively submit two-character reference letters as consideration to waive the neighborhood visit. These letters are not required for naturalization eligibility. ILRC has created the following template letter to help applicants who choose to submit letters.
Resources
Resources
Publication Date
09/30/2026
On August, 24, 2026, the ILRC submitted a comment opposing a proposed rule entitled Naturalization Application Fee Adjustments. The rule seeks to raise the application fee for Form N-400 by 75-80% as well as eliminates the fee waiver and fee reduction for naturalization applications. ILRC opposes this rule given that it will create a substantial barrier for low-income naturalization applicants who could be permanently priced out of citizenship.
Resources
Resources
Publication Date
09/14/2026
This practice advisory reviews recent changes and current practice in filing FOIA requests with DHS and with the different offices within DHS. Since January 22, 2026, all have transitioned exclusively to online filing. The only exception is for persons who lack internet access, such as incarcerated requestors, who may still file on paper, by mail.
Practice Advisory
Resources
Publication Date
05/28/2026
This explainer provides information and context for the Department of Homeland Security’s proposed rule seeking to change Form AR-11, Change of Address. DHS proposes to add questions seeking information about a person’s employment or current schooling and whether they have received any means-tested benefit. The proposed form change is over-broad and will result in confusion for applicants who are required to update the government about their address changes. This rule is proposed and is NOT in effect yet.
Public Comments / Sign-on Letters
Resources
Publication Date
02/09/2026
ILRC submitted this comment to DHS opposing recent changes to FOIA rules effective January 22, 2026 that restrict public access. DHS published a final rule in violation of the Administrative Procedures Act by unlawfully bypassing public notice and comment. The rule eliminates paper filing of FOIA requests and allows DHS in its discretion to administratively close requests that it deems to insufficiently describe the records sought.
Practice Advisory
Resources
Publication Date
01/12/2026
On December 22, 2025, DHS published a final rule impacting processing of FOIA requests by all DHS components. The rule is effective January 22, 2026. Despite the major changes made by the rule, no period of public comment was provided. The rule eliminates paper filing of FOIA requests with DHS as of January 22, 2026. FOIAs to DHS must be filed online after that date. The rule also states that DHS can, in its discretion, administratively close or make “requests for clarification” where it deems the request to be an inadequate description of the records sought.

New Americans Campaign

A project of the ILRC, the New Americans Campaign is a nonpartisan, groundbreaking national network of legal-service providers, faith-based organizations, businesses, foundations and community leaders that is paving a better road to citizenship.

A Guide for Immigration Advocates

Asylum
Citizenship and Naturalization
Crimes
Family-Based
Removal Defense
Temporary Protected Status
U Visa/T Visa/VAWA

A Guide for Immigration Advocates is a practical and essential tool for beginning immigration attorneys, immigration law firms employing paralegals, DOJ accredited representatives, and nonprofit community-based organizations. The Guide is unique...

The Effects of Absences on Naturalization

Citizenship and Naturalization

Level: IntermediateThis webinar will examine the different ways that absences from the United States can affect naturalization eligibility. Using examples, the presenters will walk through the continuous residence and physical presence requirements...