DHS Just Proposed a 75% N-400 Fee Hike and the End of Fee Waivers: The Naturalization Repricing Playbook Immigration Firms Need Before August 24, 2026
DHS published a proposed rule on June 23, 2026 raising the Form N-400 filing fee from $760 to $1,330 and eliminating the $380 reduced fee and all fee waivers except for military applicants. Comments close August 24, 2026. Here is how immigration firms should reprice flat fees, restructure trust-funded government fee advances, and rewrite client cost disclosures before the rule lands.
Published: 2026-07-12T13:05:37.637Z · Category: Immigration · 7 min read
📜 What DHS Actually Proposed
The proposed rule, Naturalization Application Fee Adjustments, was published in the Federal Register on June 23, 2026. DHS frames it as a "full-cost, beneficiary-pays" model — the theory being that an applicant should carry the full processing cost of their own citizenship application, including the expanded background checks, interviews, and vetting now required under recent executive orders.
The mechanics that matter to your firm:
N-400 paper fee: $760 → $1,330
A 75% increase on the single highest-volume naturalization form in the country.
N-400 online fee: $710 → $1,280
The online discount survives, but it shrinks to a rounding error against the new base.
Reduced fee eliminated
The $380 reduced-fee tier for lower-income applicants disappears entirely.
Fee waivers eliminated
Waivers end for N-400 and N-336. Only current and former military remain exempt.
⚠️ Why This Breaks Your Fee Agreements — Not Just Your Clients' Budgets
Most immigration firms quote naturalization as a flat legal fee plus government filing fees, with the filing fee advanced by the client into trust and disbursed on filing. That structure is fine — until the government fee moves 75% in a single rulemaking.
Three failure modes show up immediately:
1️⃣ Stale retainer language
If your engagement letter says "the current USCIS filing fee of $760," you now have a client-facing document that is wrong the moment the rule finalizes. If it says "the applicable USCIS filing fee at the time of filing," you are fine — but only if your intake process actually collects the higher amount before you file.
2️⃣ Underfunded trust balances
The client who funded $760 into your IOLTA in March for a case you plan to file in October is now $570 short. Multiply that across a naturalization book of 80 pending cases and you are carrying a $45,600 funding gap that nobody has flagged, because trust ledgers don't automatically know a federal fee schedule changed.
3️⃣ The waiver population falls off a cliff
Firms that run meaningful pro bono or reduced-fee naturalization volume have been relying on the fee waiver and the $380 reduced fee to make those matters viable. Both disappear. Every one of those cases needs an economic re-decision — file now under current rules, restructure the fee, or decline.
🛠️ The 6-Step Repricing Playbook
Step 1: Pull every open and pipeline N-400 matter with its trust balance
You need one list: matter, client, planned filing date, filing fee funded to date, filing fee required under the proposed schedule, and the delta. This is a report, not a spreadsheet project — if it takes your firm a week to produce, that is itself the finding.
3️⃣ Step 2: Segment by filing window
Cases you can reasonably file before the rule takes effect are one bucket. Cases that will land after are another. The first bucket may justify an accelerated document-collection push; the second needs a funding call.
Step 3: Rewrite the fee agreement's cost clause
Move to a "fee-as-then-in-effect" formulation with an explicit client obligation to fund any increase before filing. Add a plain-English notice that USCIS fees are changing in 2026 and that waivers are being eliminated. Clients forgive fee increases; they do not forgive surprises.
Step 4: Reissue trust replenishment requests as a batch
Do not do this case-by-case over three months. Batch it, template it, and track it as a single campaign with a completion percentage.
Step 5: Re-underwrite your reduced-fee and pro bono book
With waivers gone, decide deliberately how much subsidized naturalization work the firm can absorb, and book it as such. A pro bono matter that quietly consumes $1,330 of unrecovered hard cost is a budget line, not a rounding error.
Step 6: Comment before August 24
If the waiver elimination materially affects your client base, the comment docket is open. AILA and multiple nonprofit filers are organizing responses; a firm-level comment costs an hour and is part of the record.
⚙️ How CaseQube and LawAccounting Absorb a Fee Shock
A naturalization fee increase touches four systems at once: intake quoting, matter records, trust ledgers, and disbursement accounting. In firms running separate practice management and accounting tools, that means four reconciliations. In a unified platform, it means one.
Matter-level trust ledgers
Every N-400 matter carries its own IOLTA ledger. Filing-fee shortfalls surface as a balance, not a memory.
Compliance & funding alerts
Trust balance below the required disbursement triggers an alert before anyone tries to file.
Hard-cost disbursement tracking
Government fees are booked as advanced client costs against the matter — recoverable, auditable, never revenue.
Pipeline reporting
One report: every naturalization matter, funded vs. required, sorted by planned filing date.
Dynamic intake quoting
Intake questionnaires pull the current fee schedule, so quotes are never stale.
Full audit trail
Who changed the fee, when, and what the client was told — reconstructable years later.
- DHS's June 23, 2026 proposed rule would raise the N-400 fee from $760 to $1,330 and eliminate the $380 reduced fee and all non-military fee waivers. Comments close August 24, 2026.
- The real exposure for firms is not the fee itself — it is the funding gap on every pending matter that was trust-funded at the old amount.
- Fee agreements should reference the fee "then in effect," with an explicit client obligation to fund increases before filing.
- Government filing fees are advanced client costs. They belong in the trust ledger and the hard-cost subledger, never in revenue.
- Firms that store the fee schedule as data — not as text baked into templates — reprice in an afternoon instead of a quarter.
Reprice Your Naturalization Book in an Afternoon
See how CaseQube and LawAccounting keep matter-level trust ledgers, government fee advances, and client cost disclosures in one system — so a federal fee change is a report, not a fire drill.
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