Mitigating Factors
Mitigating factors are conditions or circumstances that can offset security concerns identified during the clearance adjudication process. Under the whole-person concept, adjudicators consider not just the concerning conduct but also factors that may reduce or eliminate the security risk.
Quick Facts
| Purpose | Offset or reduce security concerns |
| Standard | Defined in SEAD 4 adjudicative guidelines |
| Application | Case-by-case, whole-person evaluation |
| Burden | Applicant provides evidence of mitigation |
How Mitigation Works
The adjudicative guidelines list both disqualifying conditions and mitigating conditions for each concern area[1]:
- Disqualifying condition identified - Something in your background raises concern
- Mitigating conditions reviewed - Adjudicator looks for offsetting factors
- Whole-person analysis - All factors weighed together
- Decision made - Concerns may be fully mitigated, partially mitigated, or not mitigated
Common Mitigating Factors
Time Passage
For many concerns, the passage of time without recurrence can be mitigating[3]:
- Drug use that occurred years ago
- Financial problems that have since been resolved
- Criminal conduct from youth
- Foreign contacts that have ended
No specific time period guarantees mitigation - context matters.
Changed Circumstances
Demonstrating that the concerning situation has changed:
- Completion of drug treatment program
- Stable employment and income
- Marriage or other stabilizing life changes
- Relocation away from negative influences
Rehabilitation Evidence
Concrete evidence of positive change[2]:
- Counseling or treatment completion
- Support group participation
- Positive references attesting to change
- Track record of responsible behavior
- Professional evaluations
Isolated Incident
If concerning conduct was a single occurrence:
- Not part of a pattern
- Out of character
- Unlikely to recur
- Circumstances were unique
Coercion or Pressure
If conduct occurred under duress:
- Threat of harm
- Coercion by others
- Unusual pressure
- Lack of genuine voluntariness
Examples by Concern Area
Financial Issues:
- Debt was caused by circumstances beyond control (medical, job loss)
- Good-faith efforts to resolve debts
- Financial counseling completed
- Current financial stability demonstrated
Drug Use:
- Experimental use in distant past
- No use since specific date
- Treatment successfully completed
- Changed environment and associations
Foreign Contacts:
- Contacts are casual and infrequent
- No ongoing obligation to foreign nationals
- Promptly reported all contacts
- Contacts don't create vulnerability
Criminal Conduct:
- Offense was minor
- Significant time has passed
- Evidence of rehabilitation
- Successful completion of sentence/probation
Providing Mitigation Evidence
When responding to concerns, document mitigation through[2]:
- Records - Treatment completion certificates, financial statements
- Letters - From employers, counselors, character references
- Timeline - Clear dates showing passage of time
- Context - Explanation of circumstances
- Changes - Evidence of behavioral changes
What Doesn't Mitigate
Some factors generally don't serve as mitigation:
- Claiming everyone does it
- Blaming others without accepting responsibility
- Promising it won't happen again without evidence
- Technical arguments about the rules
- Expressing how important the clearance is to you
Related
- Adjudication
- Background Investigation
- PSAB (Personnel Security Appeals Board)
- Suspension / Revocation
References
- ^ SEAD 4: National Security Adjudicative Guidelines. Office of the Director of National Intelligence. Accessed 2026-01-08.
- ^ Adjudications. Defense Counterintelligence and Security Agency. Accessed 2026-01-10.
- ^ Security Clearance Process: Answers to Frequently Asked Questions. Congressional Research Service. Accessed 2026-01-10.