Expanded Canadian citizenship law may complicate U.S. security clearances

By AI, Created 6:00 PM UTC, May 20, 2026, /AGP/ – Canada’s expanded citizenship-by-descent law could create new disclosure and compliance issues for U.S. security clearance holders, especially those who may gain dual citizenship automatically. A national security attorney says the bigger risk is failing to report foreign citizenship or related activity, not dual citizenship itself.

Why it matters: - Canada’s expanded citizenship law could unexpectedly sweep in millions of people in the United States. - U.S. security clearance holders may now face added disclosure, reporting and documentation issues if they are affected. - The main concern is not automatic dual citizenship alone, but whether cleared personnel correctly report it and avoid conduct that raises foreign preference or personal conduct issues.

What happened: - Canada’s Bill C-3, An Act to Amend the Citizenship Act, took effect on Dec. 15, 2025. - The law significantly broadened citizenship by descent. - The change may extend Canadian citizenship to millions of individuals in the United States without any application or affirmative action. - National security attorney Mathew Tully, founding partner at Tully Rinckey PLLC, warned the law could create security clearance complications for U.S. personnel.

The details: - Dual citizenship alone is not disqualifying for security clearance eligibility. - Clearance cases involving dual citizenship typically fall under Guideline C: Foreign Preference. - Guideline C examines whether a person may be inclined to act in another country’s interests over the United States during a conflict. - Tully said cases involving Canada present a low baseline national security concern because Canada is a close ally. - Adjudicators still focus on trustworthiness, reliability and transparency. - The biggest risk for clearance holders is failing to report foreign citizenship under federal requirements, including SEAD-3 reporting obligations. - Failure to disclose foreign citizenship or related activities can escalate a Guideline C issue into Guideline E: Personal Conduct. - Guideline E can apply when someone knowingly withholds information, gives incomplete disclosures or acts inconsistently with reporting obligations during the clearance process. - Bill C-3 may affect people who did not apply for citizenship and did not take affirmative steps to obtain it. - Some individuals may not know they acquired foreign citizenship until they seek formal confirmation. - That distinction matters when adjudicators assess intent and compliance.

Between the lines: - The issue is less about nationality on paper and more about candor. - In clearance adjudications, undisclosed foreign ties can be more damaging than the underlying foreign citizenship itself. - Automatic citizenship by descent creates a gray area for people who may not realize their status changed.

What’s next: - Affected clearance holders may need to review whether they now hold Canadian citizenship and whether disclosure is required. - Tully recommended using a U.S. passport for international travel, reporting all foreign travel including travel to Canada, disclosing any change in citizenship status or related applications, and avoiding exercise of foreign citizenship rights where possible. - Individuals with questions about specific clearance obligations should consult a qualified national security attorney. - For more information, Scott Brewster was listed as the contact at (202) 375-2251 or sbrewster@tullylegal.com. - Tully Rinckey PLLC also listed social links for LinkedIn, Instagram, Facebook and YouTube.

The bottom line: - Expanded Canadian citizenship rules may not threaten a U.S. clearance by themselves, but they can trigger reporting mistakes that do.