Security clearance levels, explained

A security clearance is a decision that a person is eligible for access to classified information at one of 3 levels. The levels come from Executive Order 13526, signed December 29, 2009, which recognizes Top Secret, Secret, and Confidential and nothing else. The decision comes from a process laid out in Executive Order 12968 and a series of Security Executive Agent Directives, carried out for most of the government by the Defense Counterintelligence and Security Agency (DCSA). The word "clearance" barely appears in those documents, which speak of "eligibility for access" and "national security eligibility" instead. This post explains the levels, what sensitive compartmented information and special access programs add to them, the investigation tiers, the adjudicative guidelines, interim eligibility, reciprocity, and the shift from periodic reinvestigation to continuous vetting, and ends with what "clearable" means when a contractor uses the word.

The 3 levels under EO 13526

Section 1.2 of Executive Order 13526 defines the levels by the damage unauthorized disclosure could reasonably be expected to cause: "exceptionally grave damage" for Top Secret, "serious damage" for Secret, and "damage" for Confidential. Except where a statute provides otherwise, "no other terms shall be used" to identify U.S. classified information, and if there is significant doubt about the level, the information is classified at the lower one.

Having a clearance at a level is not the same as being allowed to see a given document. Section 4.1 of the order requires 3 things before anyone gets access: a favorable eligibility determination by an agency head or designee, a signed nondisclosure agreement, and a need-to-know, which Section 6.1 defines as a determination that the person requires the information to perform or assist in a lawful and authorized governmental function. Executive Order 12968, Access to Classified Information, signed August 2, 1995, says the same in Section 1.2 and adds in Section 2.2 that the level of access approved must be limited to, and relate directly to, the level of classified information the person needs. A Secret clearance is a ceiling, not a key.

Top Secret vs SCI, and what a SAP adds

The most common confusion is treating sensitive compartmented information (SCI) as a fourth level. The National Institute of Standards and Technology glossary defines SCI as classified national intelligence concerning or derived from intelligence sources, methods, or analytical processes that must be protected within formal access control systems established by the Director of National Intelligence. SCI is a kind of information, not a fourth level, and access to it is a separate decision on top of the clearance.

That decision is governed by Intelligence Community Directive (ICD) 704, effective October 1, 2008. The Director of National Intelligence sets the eligibility standards and delegates to the heads of Intelligence Community elements the authority to grant access. The threshold criteria are short: the person must be a U.S. citizen; must be stable, trustworthy, reliable, discreet, of excellent character and sound judgment, and unquestionably loyal to the United States; and must have no immediate family or close associates subject to duress by a foreign power. Exceptions to the citizenship requirement are reserved to the Director of National Intelligence or a designee. The directive names the Scattered Castles repository as the authoritative source for SCI access verifications, and it says continuous personnel security and counterintelligence evaluation is required of everyone granted SCI access.

A special access program (SAP) adds a second kind of control. Section 4.3 of Executive Order 13526 lets only a few officials create one, and only when a statute requires it or on a finding that the vulnerability of, or threat to, the information is exceptional and that normal eligibility criteria are not sufficient. For Department of Defense SAPs, DoD Manual 5205.07, effective January 17, 2025, says a SAP protecting information up to Secret requires a final Secret eligibility based on a Tier 3 or equivalent investigation, and a SAP protecting Top Secret information requires a final Top Secret eligibility based on a Tier 5 or equivalent investigation. Nominees must be enrolled in continuous vetting, and the SAP nomination process checks a final clearance, demonstrated need-to-know, and access eligibility. Neither SCI nor SAP access raises the classification level. Both narrow who gets in.

Who runs the system

Executive Order 12968 established a uniform personnel security program for the executive branch. Under Security Executive Agent Directive (SEAD) 1, effective March 13, 2012, the Director of National Intelligence serves as the Security Executive Agent, responsible for uniform policies governing investigations and adjudications for eligibility for access to classified information and for sensitive positions. The directive assigns that office the common investigative, reinvestigation, and adjudicative standards, the standardized questionnaires, and the role of final arbiter of reciprocity disputes. The National Counterintelligence and Security Center's policy page lists 9 SEADs issued under that authority, from authorities and polygraph through reporting, adjudication, social media, continuous evaluation, reciprocity, temporary eligibility, and whistleblower protection.

The work is done mostly by DCSA. The agency's personnel vetting page describes 4 functions: initiation, when a customer agency submits a security questionnaire; background investigations, of which DCSA conducts more than 2 million a year as the primary investigative service provider for the federal government; adjudications, where DCSA makes determinations for roughly 95 percent of the federal population, including the Military Departments, the National Industrial Security Program, and the DoD Fourth Estate; and continuous vetting, with approximately 4 million people enrolled.

The investigation tiers: Tier 3 and Tier 5

Job postings say "Tier 5 investigation" or "T3." The tiers come from the Federal Investigative Standards, and a one-page Department of the Interior summary of them lays out the current and future models side by side.

The National Industrial Security Program rule describes the same split without numbers. 32 CFR 117.10 says the standards set under Executive Order 13467 designate one investigative tier for positions designated moderate risk or non-critical sensitive, allowing access at the L, Confidential, and Secret levels, and another for positions designated high risk, critical sensitive, or special sensitive, allowing access at the Q, Top Secret, and SCI levels.

The Interior summary also shows where this is going. Under Trusted Workforce 2.0 the 5 tiers become 3, low, moderate, and high, with Tier 3 mapping to the moderate tier and Tier 5 to the high tier. Performance.gov describes Trusted Workforce 2.0 as the reform of a vetting framework whose core concepts were developed decades ago, and DCSA's continuous vetting page dates the start of implementation to 2018. Postings still use the old numbers.

The SF-86, e-QIP, and NBIS eApp

Both tiers start with the same form. Standard Form 86, Questionnaire for National Security Positions, revised November 2016, is the Office of Personnel Management form used by the government in conducting "background investigations, reinvestigations, and continuous evaluations" of people being considered for, or retained in, national security positions. The sections run from name and citizenship through every residence, school, and job over the covered period, people who know the applicant well, relatives, foreign contacts, foreign activities and travel, psychological health, police record, drug and alcohol use, and finances.

The form is submitted electronically. DCSA's 2022 industry guidance still calls the submission "an updated SF-86 (e-QIP and releases)," using the name of the older system, but DCSA's pages now point applicants and security officers to the National Background Investigation Services (NBIS). DCSA calls NBIS the federal government's information technology system for the end-to-end personnel vetting process, from application through investigation, adjudication, and continuous vetting. Applicants fill out their form in NBIS eApp; security managers, special security officers, and facility security officers process and track cases in NBIS Agency.

Adjudication: SEAD 4 and the 13 guidelines

Once the investigation closes, an adjudicator decides. SEAD 4, National Security Adjudicative Guidelines, effective June 8, 2017, establishes "the single, common adjudicative criteria" for every covered individual, a term that expressly includes contractors, subcontractors, licensees, grantees, experts, and consultants as well as government employees. The 13 guidelines are:

• A, allegiance to the United States
• B, foreign influence
• C, foreign preference
• D, sexual behavior
• E, personal conduct
• F, financial considerations
• G, alcohol consumption
• H, drug involvement and substance misuse
• I, psychological conditions
• J, criminal conduct
• K, handling protected information
• L, outside activities
• M, use of information technology

The directive calls the method the whole-person concept: a careful weighing of a number of variables of an individual's life, past and present, favorable and unfavorable, to make an affirmative determination that the person is an acceptable security risk. Eligibility is granted only when the evaluation shows it is clearly consistent with the interests of the United States, and "any doubt shall be resolved in favor of the national security." A single criterion can be enough for an unfavorable decision. Every determination is recorded in Scattered Castles, the Department of Defense's adjudication system, or the Office of Personnel Management's Central Verification System so other agencies can rely on it. Appendix B extends the Bond Amendment to all covered individuals: no eligibility for an unlawful user of a controlled substance or an addict, and no SCI, SAP, or Restricted Data access for a person convicted, sentenced to more than a year, and incarcerated for at least a year, dishonorably discharged, or found mentally incompetent, absent a meritorious waiver.

Interim clearances

An interim clearance is the government's own phrase for temporary eligibility. SEAD 8, Temporary Eligibility, effective May 18, 2020, lets security personnel authorized by the agency head approve temporary access before the investigation and adjudication are complete, in exceptional circumstances when official functions must be performed, including mission readiness. For Confidential, Secret, and L access the requirements are a favorable review of the completed SF-86, citizenship verification, initiation of an expedited investigation, and a favorable FBI fingerprint check. Top Secret and Q add an FBI name check and a National Crime Information Center check. Temporary access is limited to the categories of information needed, is valid only with the granting agency, may be terminated at any time if disqualifying information arrives, and may not exceed 1 year without approval and a recorded justification. Temporary access to SAP information requires approval of the program's establishing authority or designated program manager.

For industry, 32 CFR 117.10 repeats the rule, noting that temporary eligibility was "previously called interim," and adds that non-U.S. citizens are not eligible for it and that Restricted Data, communications security, and NATO information require a final Secret eligibility. DCSA's interim clearances page says every applicant submitted by a cleared contractor is routinely considered for an interim eligibility, that the decision is made concurrently with the initiation of the investigation after a review of the SF-86 and other files, and that it generally stays in effect until the investigation is complete and a final eligibility is considered.

Reciprocity under SEAD 7

A clearance granted by one agency is supposed to be good at another. SEAD 7, effective November 9, 2018, defines reciprocity as acceptance of an existing background investigation, acceptance of an eligibility adjudication, and acceptance of an active eligibility determination. Agencies must check Scattered Castles, the DoD system, or the Central Verification System for prior records, accept investigations that meet the requirements, and accept adjudications at the same or higher level. When the requirements are met, no new SF-86 may be requested, the old one may not be re-adjudicated, and no new checks may be started. The decision is due within 5 business days.

The exceptions are specific: new adjudicatively relevant information; a most recent investigation more than 7 years old, which an agency may still accept while starting a reinvestigation; an adjudication recorded with an exception under SEAD 4; a Bond Amendment disqualifier when SCI, SAP, or Restricted Data access is needed; agency-specific requirements the Security Executive Agent has approved; a temporary, limited, or one-time grant; and a current denial, revocation, or suspension. For contractors, 32 CFR 117.10 forbids submitting a request to one cognizant security agency for an employee known to be cleared or in process with another and requires reciprocity under SEAD 7 instead.

Continuous vetting replaces periodic reinvestigation

Executive Order 12968, Section 3.4, requires periodic reinvestigations conducted with the same priority and care as initial investigations. SEAD 6, Continuous Evaluation, effective January 12, 2018, added automated records checks of commercial databases, government databases, and other lawfully available information at any time during the period of eligibility, with the Director of the National Counterintelligence and Security Center setting the data sources and periodicity. At the time, the directive described continuous evaluation as supplementing, but not replacing, scheduled periodic reinvestigations.

The program has since become the replacement. DCSA's industry guidance of August 8, 2022, issued by its Vetting Risk Operations after a June 27, 2022 Office of the Under Secretary of Defense memorandum, states 3 points: periodic reinvestigations "will not be conducted" for the National Industrial Security Program contractor population, an updated SF-86 and releases must be submitted every 5 years regardless of level, and anyone enrolled in continuous vetting is compliant. DCSA's continuous vetting page describes the checks: automated record checks pull data from criminal, terrorism, and financial databases and public records at any time during eligibility; when an alert arrives, DCSA assesses whether it is valid, and investigators and adjudicators then gather facts and make determinations, in some cases suspending or revoking a clearance. The agency calls NBIS the backbone of Trusted Workforce 2.0. The regulation for industry reads the same way: 32 CFR 117.10 says contractor employees will follow cognizant security agency guidance to complete "reinvestigation and continuous evaluation or continuous vetting requirements," and DoD Manual 5205.07 makes enrollment in continuous vetting a condition of SAP access. SEAD 6 also sets the limits: no unfavorable action may be taken solely on uncorroborated information, and anyone denied or revoked keeps the review rights in Part 5 of Executive Order 12968, which include a written explanation, a chance to reply, and an appeal to a panel.

What cleared people must report

Eligibility carries obligations. SEAD 3, effective June 12, 2017, requires every covered individual to report unofficial foreign travel in advance and get approval, to report continuing association with known foreign nationals that involves bonds of affection, personal obligation, or intimate contact, and any contact with a foreign national that involves the exchange of personal information, and to alert security to concerning behavior by other cleared people. People with Secret or Confidential access also report applications for foreign citizenship or passports, attempted elicitation, arrests, bankruptcy or debts more than 120 days delinquent, and alcohol or drug treatment. People with Top Secret access add foreign business, bank accounts, and property, voting in a foreign election, foreign national roommates of more than 30 days, cohabitants, marriage, and any unusual infusion of assets of 10,000 dollars or more. Failure to report can end in revocation.

What "clearable" means for a contractor

Contractors write "must be clearable" in job postings. The regulation uses the word only once, in 117.10(k), where a limited access authorization for a non-U.S. citizen depends on no cleared or clearable U.S. citizen being readily available, and never defines it. Under 32 CFR 117.10 the cognizant security agency, not the company, determines eligibility, and only after the contractor has determined that access is essential to performing a classified contract. A contractor may then give an employee access at or below the level of its own facility clearance once the employee has a need-to-know, a favorable government eligibility determination, and a signed nondisclosure agreement. Requests are limited to the minimum number of people and "will not be used to establish a cache of cleared employees," may not be submitted for people who are not the company's employees or consultants, and may not be submitted for subcontractor staff. Every applicant who claims U.S. citizenship must show original or certified documents. 32 CFR 117.3 defines cleared employees to include people being processed for eligibility, not only those who hold it.

So "clearable" is a prediction: that the person is a U.S. citizen whose record, judged against the 13 SEAD 4 guidelines, would produce a favorable determination once a contract justifies sponsoring them. The prediction has a timeline attached. Even with an interim grant on the SF-86 review and fingerprint check, final eligibility waits on a Tier 3 or Tier 5 investigation, and a system that assumes cleared users on day one has made an assumption about the schedule as well as the people.

What to check

• Which level and which access the work requires, since Secret, Top Secret, SCI, and SAP are 4 different determinations with different sponsors.
• Whether a candidate's existing eligibility is recorded in Scattered Castles, the DoD system, or the Central Verification System, and whether any SEAD 7 exception applies, such as an investigation more than 7 years old or an adjudication with an exception.
• Whether an interim eligibility is enough for the task, given that Restricted Data, communications security, and NATO information need a final Secret.
• Whether the staff are enrolled in continuous vetting, which SAP access and current DoD guidance require.
• For a contractor, whether a classified contract already justifies each sponsorship, since requests may not build a cache of cleared employees.
• Whether the SEAD 3 reporting obligations have been briefed, especially foreign travel and foreign contacts.

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Questions people ask

What are the security clearance levels?

There are 3. Executive Order 13526, Section 1.2, defines Top Secret as information whose unauthorized disclosure could reasonably be expected to cause exceptionally grave damage to the national security, Secret as serious damage, and Confidential as damage. The order says that except where a statute provides otherwise, no other terms shall be used to identify U.S. classified information. A person's eligibility is granted at one of those levels, and under Executive Order 12968 the level of access is limited to the level the person needs.

What is the difference between Top Secret and SCI?

Top Secret is a classification level. Sensitive compartmented information is a category of information, defined in the NIST glossary as classified national intelligence concerning or derived from intelligence sources, methods, or analytical processes that must be protected within formal access control systems established by the Director of National Intelligence. SCI is not a fourth level. 32 CFR 117.10 puts SCI access in the same investigative tier as Top Secret, the tier agencies call Tier 5, and Intelligence Community Directive 704 adds a separate SCI eligibility determination that requires U.S. citizenship.

What is a Tier 5 investigation?

Tier 5 is the background investigation for the highest tier of national security positions. A Department of the Interior summary of the Federal Investigative Standards lists Tier 5 as covering critical sensitive and special sensitive positions, Top Secret, sensitive compartmented information, and Q access. 32 CFR 117.10 describes the same tier without the number: positions designated high risk, critical sensitive, or special sensitive with access at the Q, Top Secret, and SCI levels. It runs on the Standard Form 86.

What is a Tier 3 investigation?

Tier 3 is the investigation for Secret and Confidential eligibility. The Department of the Interior summary lists it as covering non-critical sensitive positions, Secret and Confidential access, and Department of Energy L access. 32 CFR 117.10 describes that tier as positions designated moderate risk or non-critical sensitive with access at the L, Confidential, and Secret levels. Under Trusted Workforce 2.0 the same summary shows the 5 tiers collapsing into low, moderate, and high tiers, with Tier 3 becoming the moderate tier.

What is SEAD 4?

Security Executive Agent Directive 4, National Security Adjudicative Guidelines, effective June 8, 2017, establishes the single, common adjudicative criteria for everyone who needs eligibility for access to classified information or to hold a sensitive position. The 13 guidelines, A through M, run from allegiance to the United States through foreign influence, financial considerations, drug involvement, and use of information technology. Adjudicators apply the whole-person concept, and any doubt is resolved in favor of the national security. It also applies the Bond Amendment restrictions.

What is an interim clearance?

An interim clearance is temporary eligibility granted before the investigation is finished. SEAD 8, Temporary Eligibility, effective May 18, 2020, requires for Secret and Confidential a favorable review of the completed SF-86, citizenship verification, an expedited investigation under way, and a favorable FBI fingerprint check; Top Secret adds an FBI name check and a National Crime Information Center check. Temporary access may not exceed 1 year without approval and is valid only with the granting agency. DCSA says every contractor applicant is routinely considered for one.

What is continuous vetting?

Continuous vetting is the ongoing review of a cleared person's background during the whole period of eligibility. DCSA describes automated record checks that pull data from criminal, terrorism, and financial databases and public records at any time, with investigators and adjudicators following up on valid alerts. SEAD 6, Continuous Evaluation, effective January 12, 2018, set the policy for those automated checks across the executive branch. DCSA reports roughly 4 million people enrolled.

Does a security clearance transfer between agencies?

Usually yes, through reciprocity. SEAD 7, effective November 9, 2018, requires agencies to accept an existing background investigation and a national security eligibility adjudication at the same or higher level, to decide within 5 business days, and not to ask for a new SF-86 when the requirements are met. The exceptions include new adjudicatively relevant information, an investigation more than 7 years old, an adjudication recorded with an exception, an interim or one-time grant, and a current denial, revocation, or suspension.

What does clearable mean for a contractor employee?

Clearable is mostly a hiring term. 32 CFR 117.10 uses it once, for a non-U.S. citizen's limited access, without defining it. Under that section, the cognizant security agency decides eligibility, the contractor must first determine that access is essential to a classified contract, and requests may not be used to build a cache of cleared employees. An applicant claiming U.S. citizenship must prove it with original or certified documents. In practice, clearable means the company believes the person could meet the SEAD 4 guidelines once sponsored.

What do cleared people have to report?

SEAD 3, effective June 12, 2017, requires everyone with access or a sensitive position to report unofficial foreign travel in advance, close and continuing ties with foreign nationals, any foreign contact involving exchange of personal information, and concerning behavior by other cleared people. Those with Secret or Confidential access also report foreign citizenship or passport applications, arrests, bankruptcy or debts over 120 days delinquent, and alcohol or drug treatment. Top Secret adds foreign business, bank accounts, property, voting, cohabitants, marriage, and unusual asset infusions of 10,000 dollars or more.

Sources

1. 1Executive Order 13526, Classified National Security Information · National Archives and Records Administration
2. 2Executive Order 12968, Access to Classified Information · Government Publishing Office, Federal Register
3. 3Security Executive Agent Directive 1, Security Executive Agent Authorities and Responsibilities · Office of the Director of National Intelligence
4. 4Security Executive Agent Directive 3, Reporting Requirements for Personnel with Access to Classified Information or Who Hold a Sensitive Position · Office of the Director of National Intelligence
5. 5Security Executive Agent Directive 4, National Security Adjudicative Guidelines · Office of the Director of National Intelligence
6. 6Security Executive Agent Directive 6, Continuous Evaluation · Office of the Director of National Intelligence
7. 7Security Executive Agent Directive 7, Reciprocity of Background Investigations and National Security Adjudications · Office of the Director of National Intelligence
8. 8Security Executive Agent Directive 8, Temporary Eligibility · Office of the Director of National Intelligence
9. 9Security Executive Agent policy page (list of directives) · National Counterintelligence and Security Center
10. 10Intelligence Community Directive 704, Personnel Security Standards and Procedures Governing Eligibility for Access to Sensitive Compartmented Information · Office of the Director of National Intelligence
11. 1132 CFR 117.10, Determination of eligibility for access to classified information for contractor employees · Electronic Code of Federal Regulations
12. 1232 CFR 117.3, Acronyms and definitions · Electronic Code of Federal Regulations
13. 13Standard Form 86, Questionnaire for National Security Positions · Office of Personnel Management
14. 14The Federal Personnel Vetting Investigative Standards: Then and Now · Department of the Interior, Interior Business Center
15. 15Trusted Workforce 2.0 · Performance.gov
16. 16Personnel Vetting · Defense Counterintelligence and Security Agency
17. 17Continuous Vetting · Defense Counterintelligence and Security Agency
18. 18Interim Clearances · Defense Counterintelligence and Security Agency
19. 19National Background Investigation Services (NBIS) · Defense Counterintelligence and Security Agency
20. 20Industry Trusted Workforce Guidance (Vetting Risk Operations, August 8, 2022) · Defense Counterintelligence and Security Agency
21. 21DoD Manual 5205.07, Special Access Program Security Manual · Department of Defense
22. 22Sensitive compartmented information (glossary entry) · National Institute of Standards and Technology

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