When Canada passed Bill C-3 to amend the rules governing citizenship by descent, they probably weren’t concerned with the ensuing panic from American security clearance holders who suddenly became dual citizens on December 15, 2025 (including me).
The anxiety is understandable. Reporting requirements are strict. Plenty of cleared individuals working today remember when standard policy required people across agencies to surrender their foreign passport. Small wonder that a case of sudden-onset “Canadian-ness” would trigger flop sweat and panicked Googling: Is my security clearance eligibility in danger?
The answer depends entirely on the larger context: Canada’s as well as yours.
Impact of foreign citizenship on security clearances in 2026
When assessing the risk of dual citizenship, adjudicators consult the 13 Adjudicative Guidelines (SEAD-4). Each category of security concern comes with disqualifying factors and mitigating factors. Dual citizenship in and of itself is not a security concern (SEAD-4 ¶ 6), but additional disqualifying factors may make it one.
Two guidelines directly concern foreign involvement:
Guideline B: Foreign Influence: How much leverage could a foreign country hold over you, and how likely are they to use it?
Guideline C: Foreign Preference: How likely are you to choose another country over the United States, and how likely is that choice to come up?
Dual citizenship falls under Guideline C: Foreign Preference, but it can be tied up with Guideline B: Foreign Influence — especially if the country is hostile to the U.S. The reality for dual citizens is that your individual character is not the sole object of scrutiny. The foreign country’s character is also relevant.
Canadian Americans are fortunate on this front. As Canada itself poses minimal national security risk, Canadian citizenship is also less likely to pose a national security risk. However, Canadian–U.S. dual citizenship — even for C-3 Canadians — can still raise a red flag in the wrong circumstances.
Can Canadian dual citizenship cause security clearance issues?
Security may not be overly worried about Canada, but they are concerned with what your foreign involvement says about you as a person and your attitude toward U.S. national security. Canada being trustworthy hardly matters if the Canadian citizen is not.
When assessing the eligibility of Canadian dual citizens, adjudicators weigh the following:
How you obtained your citizenship
There is a substantial difference between Canadian citizenship acquired through parentage versus Canadian citizenship acquired through application.
If you newly qualified as a Canadian citizen by virtue of Bill C-3, then you did not apply for Canadian citizenship. Canada’s change to criteria for determining citizenship by descent triggered an automatic change in your citizenship. Your citizenship may be new, but it is still acquired through parentage. That difference matters to Security.
Reasons for applying
Your reasons for applying for citizenship are highly relevant. Heritage is one thing. If you declare your ambition to leave the U.S. for a “better life” in Canada, the closeness of our relationship to Canada may not help your case.
Note that applying for recognition of Canadian citizenship is entirely distinct from applying for Canadian citizenship. If you became a Canadian citizen under Bill C-3, you need not apply for citizenship. Applying for Canadian citizenship involves, among other things, taking the Oath of Citizenship and swearing allegiance to the king of England and his successors (yes, truly). Claiming proof of citizenship obtained through descent comes with no such requirement; the significance of this difference couldn’t be overstated.
If you are now a Canadian citizen under Bill C-3, your reasons for applying for proof of citizenship or a passport may still be of security interest. Be prepared to explain your intentions.
Failure to report
The Adjudicative Guidelines are very clear: dual citizenship in and of itself is not disqualifying unless there is either (A) a conflict with American national security interests, or (B) the individual tries to hide it. (SEAD-4 ¶ 9). Canada itself is not a security concern. If the Canadian in question makes efforts to conceal their foreign ties, then that is a concern.
Guideline E, Personal Conduct involves concealing information relevant to your national security eligibility, both during and after application. Security clearance holders have strict requirements under SEAD-3 to report certain activities or status changes. Failure to do so may trigger security clearance revocation.
Note that concealment requires knowledge. You cannot conceal facts you are unaware of. The only way to know for certain whether you are now a Canadian citizen under Bill C-3 is filing with the Canadian government for a Canadian certificate of citizenship, which can take many months. If you automatically became (or may have become) a Canadian citizen, you are unlikely to be penalized for misrepresenting your citizenship, or the citizenship of your spouse or cohabitant, during the security investigation process.
How to protect your security clearance as a U.S.–Canada dual citizen
Your behavior as a dual citizen matters, no matter the country of citizenship.
Mind reporting requirements
All clearance holders have reporting requirements (found in SEAD-3). Dual citizens should be particularly mindful of the following:
- Always use your U.S. passport to travel in and out of the U.S.
- Timely report any and all foreign travel, including Canada.
- Disclose any changes to your citizenship status, including application for proof of citizenship or passport.
Curb your Canadian involvement
Top Secret and Q clearance holders have further reporting requirements, like foreign investments, business involvement, adoption, et cetera. (SEAD-3 H.1). However, it may benefit dual citizens of any clearance level to observe the following:
- Limit your exercise of foreign citizenship (e.g., voting in a foreign election, serving in a foreign military or other governmental position).
- Limit your foreign investments (e.g., owning property abroad, foreign business investments, foreign bank accounts).
- Be prepared to explain any foreign activity.
Be proactive with mitigation
Showing a clear preference for the United States can mitigate Guideline C concerns. You may demonstrate your investment in U.S. interests by demonstrating an investment in your American life: your relationships, property, career, finances and community.
Know where to seek clarification
Eligibility for access to classified information is not a right. It is a privilege. Due process in security clearance adjudications exists, but it takes a form strikingly different from other employment matters. The burden of proof is on you to demonstrate that you are not a security risk. Any doubt is resolved in favor of national security.
Your facility security officer (FSO) and fellow cleared coworkers are obligated to report any of your activities that may present potential security risk, as you are theirs (SEAD-3 F.3). Your security officer’s duty is understandably to protect security, not your career. A private national security attorney can field your questions, confidentially, without risking review, suspension or revocation of your clearance.
There is no predictable security clearance adjudication formula. Every piece of information, whether derogatory or mitigating, is considered holistically. Context is key. What contributed to the success in one dual citizenship case might not help in another. One material change in fact may change the outcome.
If you have dual citizenship under Bill C-3 and are considering applying for recognition of citizenship, a passport or other benefits of citizenship, it is highly advisable to speak with a security clearance attorney. They can address the questions you may not be comfortable bringing to your security office.
Mathew B. Tully is a founding partner of Tully Rinckey PLLC, where he concentrates his legal practice on representing federal government employees and military personnel in employment and national security matters.
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