The Trump administration is tightening the rules for immigrants applying for U.S. citizenship. A new policy from U.S. Citizenship and Immigration Services (USCIS) expands how officers decide if an applicant has “good moral character,” a longstanding requirement in the naturalization process.

The updated policy directs officers to take a “holistic” view of applicants. That means considering both positive contributions and behaviors that may not be illegal but could still qualify as falling short of “the standards of average citizens of the community.”

USCIS shifts to a “holistic” review

The USCIS memo, issued Friday, tells officers they must go beyond looking for serious crimes or statutory disqualifications. The review should now include “a holistic assessment of an alien’s behavior, adherence to societal norms, and positive contributions that affirmatively demonstrate good moral character.”

Applicants can highlight factors like community involvement, caregiving responsibilities, educational achievements, legal employment history, length of residence in the U.S., and paying taxes.

“U.S. citizenship is the gold standard of citizenship. It should only be offered to the world’s best of the best,” USCIS spokesman Matthew J. Tragesser told news outlets. “Today, USCIS is adding a new element to the naturalization process that ensures America’s newest citizens not only embrace America’s culture, history, and language but also demonstrate Good Moral Character.”

What counts against “good moral character”

The updated guidance also allows officers to consider behaviors beyond violent crimes and felonies. Officers are instructed to consider repeat DUI convictions, drug use, or “reckless or habitual traffic infractions.”

The memo even points to “harassment or aggressive solicitation” as grounds for questioning an applicant’s character, even if technically lawful. Officers now have explicit authority to weigh all “relevant evidence, both adverse and favorable, before granting or denying naturalization,” the memo states.

Rehabilitation can tip the scales

The policy leaves space for applicants to prove rehabilitation. This could mean paying overdue taxes or child support, following probation requirements, or providing testimony from community members. The memo says USCIS officers must look at whether applicants have rectified past wrongdoing and demonstrated change.

Critics say the definition is being stretched

Some immigration experts warn that the new rules expand subjectivity. Doug Rand, a former senior USCIS official under the Biden administration, told CBS News: “They’re trying to increase the grounds for denial of U.S. citizenship by kind of torturing the definition of good moral character to encompass extremely harmless behavior.”

TIME also reported on concerns that the administration is injecting political bias into immigration. Stanford’s student newspaper recently sued, alleging that non-citizens who express pro-Palestinian views face targeting, which critics say undermines free speech.

Good moral character test impacts hundreds of thousands

The “good moral character” requirement applies to green card holders who want to naturalize, typically after living in the U.S. for three or five years. Applicants also need to pass English and civics exams.

According to USCIS data, between 600,000 and 1 million immigrants have naturalized each year since 2015. Around 25 million people in the U.S. are naturalized citizens, representing over half of all foreign-born residents in 2023.

But critics point out the new rules could also play into denaturalization. TIME reported that a Justice Department memo instructed attorneys to “prioritize and maximally pursue” denaturalization cases when eligibility conditions, including good moral character, were violated.