The Defense Counterintelligence and Security Agency (DCSA) has confirmed that as of August 1, 2025, only the February 2024 versions of Standard Forms (SF) 85, 85P, 85P-S, and 86 will be accepted for background investigations. Earlier versions are no longer valid.This transition reflects DCSA's continuing efforts to modernize the National Background Investigation Services (NBIS) and Electronic Application (eApp) system, with the goal of ensuring a more consistent and efficient process for national security vetting.
Submission and Processing Guidance
Missed Deadline: Cases submitted on outdated forms after August 1 have been or will be rejected and must be re-initiated using the updated February 2024 versions.
Returned Cases: If an investigation has been returned for corrections, it must now be resubmitted using the updated forms—unless it was cleared for review prior to the cutoff date.
Fingerprint Records: New fingerprints are not required unless the existing set is more than 120 days old.
What Changed in the February 2024 VersionsThe underlying questions themselves remain unchanged. However, DCSA has removed outdated language related to consumer credit file security freezes:
Deleted references to lifting credit report freezes in the Investigative Process instructions.
Removed similar language from the Fair Credit Reporting Disclosure and Authorization section.
The SF 85P-S is not affected by these content changes but also carries the new February 2024 version date.
Action Steps for Cleared Industry
Use Updated Forms Only: Make sure all new and ongoing cases utilize the February 2024 versions.
Resubmit If Needed: Re-initiate any cases that were rejected for using outdated forms.
Check Fingerprints: Submit new prints only if existing ones are older than 120 days.
Update Procedures: Remove outdated forms from circulation and confirm that staff have been trained on the new versions.
Why This MattersEven though the substantive content of the forms has not changed, using outdated versions can significantly delay investigations and jeopardize clearance timelines. For contractors and agencies that depend on timely vetting, compliance with the February 2024 versions is critical to avoiding unnecessary disruption.
We counsel defense contractors, cleared professionals, and security managers on navigating clearance application requirements, NBIS transition issues, and compliance risks. For tailored legal guidance on background investigation procedures, and to learn more about our National Security practice, contact our team at (212) 668-0200 or info@mdrxlaw.com.
