Key Highlights
Changes in U.S. citizenship exams have returned to the news, and this time, they could contain more than just tougher trivia questions. The Department of Homeland Security is considering a new rule that would establish new "education requirements" for those seeking U.S. citizenship. The proposal would also allow third-party, non-governmental organizations to administer the naturalization test, which is currently only done by USCIS officers.
This is no quick off-the-cuff thought tossed off by a junior staffer. It's on DHS's official regulatory agenda, which is the list of proposed rules agencies use to indicate they are considering a rule before publishing it. And it arrives at a time when the citizenship process has become noticeably more difficult for hundreds of thousands of applicants.
What DHS is Really Proposing?
The DHS filing states the rule would establish "a framework and a standard" for applicants to satisfy the citizenship education requirement. If you're applying for a job under Federal law, they are now asking applicants to demonstrate some basic skills in reading, writing, and speaking English, as well as knowledge of United States history and government. But DHS points out that current regulations "do not provide specifics on how aliens should meet the educational requirements."
That's the difference that the department wants to bridge. There are two significant changes:
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New education standards. A clear standard for acceptable civics and English preparation (rather than the current vague guidance).
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Third-party test administration. The filing does not clarify who these third parties would be or how they would be supervised, but USCIS claims the move would provide the agency with "additional flexibility" in conducting exams.
The goal is expressed using the familiar language of DHS: "Proper assimilation" of new citizens and "a unified American identity and attachment to the Constitution, laws, and founding principles of the United States. A NOPR is likely to be published in December and will provide an opportunity for public comment before any rule is finalized.
Why This Isn't Coming Out of Nowhere?
This plan is a continuation of an approach set by Trump during his first term. In his last year in office, his administration had implemented a more difficult and lengthy civics exam. It was abandoned by President Biden's team in 2021, reverting to the same basic requirement of the previous version.
Almost the same version was reinstated in September 2025 and was effective for all F-400s filed on or after October 20, 2025.
The current test is already one of the largest changes in the history of naturalization. Here's how it compares to the version it replaced:
|
Feature |
Pre-October 2025 Test |
2025 Test (Current) |
|
Question pool |
100 questions |
128 questions |
|
Questions asked at interview |
10 |
20 |
|
Correct answers needed to pass |
6 |
12 |
|
Question style |
Mostly short, one-word answers |
More "how" and "why" questions |
|
Early stop rule |
Stops after 6 correct |
Stops after 12 correct or 9 wrong |
|
Applies to |
N-400 filed before Oct 20, 2025 |
N-400 filed on/after Oct 20, 2025 |
Applicants who filed before that October date still take the older exam. Everyone else studies from the larger, more difficult question bank. And now, with DHS eyeing a second round of rulemaking, that October update may turn out to be just the opening move rather than the final word.
A Quick Timeline of the Overhaul
Following the sequence of events helps explain why immigration attorneys are watching closely:
|
Date |
Event |
|
2020 |
Trump's first term introduces a harder, 20-question civics test |
|
2021 |
Biden administration rolls back the 2020 test, restores the simpler version |
|
September 17, 2025 |
USCIS announces the return of the harder 2025 civics test |
|
October 20, 2025 |
New 128-question test takes effect for all new N-400 filings |
|
January 5, 2026 |
USCIS confirms all applications filed since October 20, 2025, fall under the new rules |
|
August 2026 |
DHS regulatory agenda reveals plans for education standards and third-party testing |
|
December 2026 (expected) |
DHS to publish formal notice of proposed rulemaking |
What This Could Mean for Applicants?
No one outside of DHS has an exact idea of what the new education standard will look like. There is no specific detail on what constitutes ‘sufficient' preparation, or how a test administered by a third party would be marked, monitored, and challenged in the event of a failure.
Some immigration attorneys don't like the ambiguity and point to fairness and consistency concerns raised by outsourcing part of the legal eligibility process. Nonetheless, some useful lessons can be drawn from the experience so far:
Nothing changes immediately. This is not a final rule, but rather a regulatory agenda item. First, there needs to be a public comment period.
The existing law of 128 questions and 20 out of 12 requires that all those filing now adhere to it.
The broad reshaping of the good moral character reviews has also extended to new areas, such as social media activity, Selective Service registration, and tax compliance.
Persons aged 65 and older who are U.S. LPRs are still eligible for the 10-question version.
The crux of the entire proposal is this single line: "DHS said current regulations do not provide specifics on how aliens should meet the educational requirements".
Conclusion
The changes to the U.S. citizenship exam are back on the table, and this time the issue is not only how many questions will be on the test but also who will administer it. While the proposal hasn't yet been published as a rule, it's no surprise that it's part of this administration's theme of stricter standards, fewer ambiguities, and a drive for what administration officials refer to as "full assimilation.
If anyone has an N-400 pending, they should continue studying the current 128-question civics test because that is the one that is binding now. But it will be interesting to watch December closely, as it's when the actual details of this new chapter should emerge.
