HUD Updates Citizenship Verification Guidance

By: Darshana Subramaniam, Policy & Legislative Affairs Data Analyst

October 15, 2026 — On September 4, 2026, HUD issued updated citizenship verification guidance titled “Guidance on Continuing to Protect the Meaning and Value of American Citizenship (Executive Order 14418) for Verification Requirements under Section 214 of the Housing and Community Development Act of 1980 and Title IV of the Personal Responsibility and Work Opportunity Reconciliation Act of 1996” (SD-2026-01) to implement the requirements of Executive Order 14418 for HUD-funded programs where citizenship status affects eligibility. The guidance applies prospectively and is limited to benefit eligibility determinations. Under the guidance, HUD-assisted housing providers must verify U.S. citizenship through specified documentation and, in certain cases, obtain additional parental citizenship documentation or attestations.

Under Executive Order 14418, federal agencies are directed not to issue or accept documentation recognizing U.S. citizenship for individuals when neither parent is a U.S. citizen and one of several circumstances applies, including when a parent is classified as an “alien enemy,” is a foreign diplomat or government official with immunity, engaged in birth tourism or related fraudulent activity, or when the child was born in a U.S. territory where citizenship is not granted by federal statute.

Two Paths to Verify Citizenship

The guidance establishes two methods for verifying U.S. citizenship.

Option 1: Category A Documentation

Applicants may demonstrate citizenship by providing at least one Category A Qualifying Beneficiary Document, which establishes both identity and citizenship. Acceptable documents include the following:

• U.S. Passport;
• Form N-550 or N-570 (Certificate of Naturalization);
• Form N-560 or N-561 (Certificate of Citizenship);
• Certain state-issued identification documents meeting citizenship verification standards;
• Tribal membership documentation from federally recognized tribes; and
• Other documents approved by HUD that establish both identity and citizenship.

Option 2: Category B and Category C Documentation, Plus Parent Documentation

Applicants may alternatively establish citizenship through:

• One Category B Qualifying Beneficiary Document (citizenship evidence only);
• One Category C Qualifying Beneficiary Document (identity evidence only);
• At least one Qualifying Parent Document, when applicable; and
• A completed Eligibility Attestation.

Eligibility Attestation Requirements

A key component of the guidance is the Eligibility Attestation, which is separate from the citizenship documentation itself. The attestation is considered sufficient when it confirms one of the following:

• The individual is a U.S. citizen whose citizenship can be confirmed through a Category A document; or
• The individual was born in one of the 50 states, the District of Columbia, Puerto Rico, Guam, the U.S. Virgin Islands, or the Northern Mariana Islands and can provide both a Category B and Category C document.

In addition, the attestation must address parental citizenship by stating that:

• The individual’s mother was a U.S. citizen and that status can be verified through a Qualifying Parent Document; or
• The individual’s father was a U.S. citizen and that status can be verified through a Qualifying Parent Document; or
• Neither parent was a U.S. citizen, but the parent attests that none of the circumstances identified in Section 2(a)-(d) of Executive Order 14418 applies.

Acceptable Documentation

Category B Documents (Citizenship Only)

Examples include:

• U.S. birth certificates for individuals born in the 50 states, District of Columbia, Puerto Rico, Guam, U.S. Virgin Islands, or Northern Mariana Islands;
• Form FS-545 or Form DS-1350 (Certification of Birth Abroad);
• Form FS-240 (Consular Report of Birth Abroad);
• Form I-197 (U.S. Citizen Identification Card); and
• Other HUD-approved citizenship documentation.

Category C Documents (Identity Only)

Examples include:

• Identity documents authorized under Section 274A(b)(1)(D) of the Immigration and Nationality Act; and
• Other forms of identification approved by HUD as reliable evidence of identity.

Qualifying Parent Documents

When parental citizenship must be verified, acceptable documentation includes:

• U.S. Passport;
• Form N-550 or N-570 (Certificate of Naturalization);
• Form N-560 or N-561 (Certificate of Citizenship);
• Certain qualifying state-issued identification documents;
• U.S. birth certificate;
• Tribal membership documentation from a federally recognized tribe; and
• Other HUD-approved citizenship documentation.

If neither parent possesses documentary evidence of U.S. citizenship, the parent may instead attest that none of the circumstances described in Section 2(a)-(d) of Executive Order 14418 applies.

The citizenship verification guidance document can be found here.