FSOTOOLSIndustrial security / Independent resources
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Holding a clearance · Your reporting duties

What you must report

The reporting rules were written to agencies and companies, and reach you through a briefing once a year. This is the same list written to you: what to report, to whom, when, and why reporting it yourself is the single most useful thing you can do for your own clearance.

Before you travel The full chart for FSOs

How and where to report

To your FSO, not to DCSAThe NISPOM requires your company to make sure you know your “responsibilities for reporting pertinent information to the FSO” (§117.8(a)(2)). The company, not you, files the onward report with DCSA, recorded in DISS as an incident report or, for travel, a foreign travel report. You cannot see those records yourself.
Before, or as soon as possibleSEAD 3’s rule for everything on this page: report “prior to participation in such activities or otherwise as soon as possible following the start of their involvement.” The only day-counts anywhere in the directive are the five business days for travel changes, below. For an arrest, a debt or a new relationship there is no grace period: report when it happens.
In writing, with the detailsSEAD 3’s Appendix A lists the facts each report needs (dates, names, countries, amounts, dispositions). A short written note to your FSO with those facts is better than a hallway mention, because it is what the FSO will type into the system and what adjudicators will read.
If you cannot go through your companyFederal hotlines exist so that contractor employees can report security irregularities “without fear of reprisal” (§117.7(j)). The rule encourages the company channel first; the hotline is the alternative when that channel is the problem.

Your company may set additional or more detailed procedures (SEAD 3, E.7), and your contract or customer may add its own. When a briefing from your FSO says more than this page, the briefing governs.

Before you travel abroad

Unofficial foreign travel, meaning any trip that is not official business, is the one item that needs approval, not just a report.

  1. 1

    Send your itinerary to your FSO before you go, and wait for approval

    SEAD 3 requires covered individuals to “submit an itinerary for unofficial foreign travel” and to “receive approval prior to the foreign travel.” Travel can be disapproved when it “presents an unacceptable risk,” and going anyway can cost the clearance. Puerto Rico, Guam and other U.S. territories are not foreign travel.

  2. 2

    Take the briefing if one is required

    Where the agency requires it, you receive a defensive security and counterintelligence briefing before you leave. For many contractors it is a short document from the FSO.

  3. 3

    Report changes within five business days of coming home

    “All deviations from approved travel itineraries shall be reported within five business days of return.” An unplanned day trip to Canada or Mexico is reported on return, within the same five business days. Unanticipated border crossings into any country not on the approved itinerary are discouraged.

  4. 4

    Emergency travel: tell someone before you leave, report fully after

    If you must leave at once, at minimum tell your supervisor or management chain, and preferably a security representative, before departure, with the specifics. Full reporting follows within five business days of return.

What the report containsBefore: the complete itinerary, dates, mode of transport and carriers, passport data, foreign-national traveling companions and their relationship to you, planned contacts with foreign governments, companies or citizens and why, and an emergency contact. After: unplanned foreign contacts, anything unusual or suspicious, and any foreign legal or customs incident (SEAD 3, Appendix A.1).

Reporting unofficial travel to DoD has been required of DoD-cognizant contractors since August 24, 2022 (32 CFR §117.1(b)(3) and 86 FR 46597). Your FSO files the travel report in DISS before you depart and records the debrief afterward.

Foreign contacts

Two kinds of contact are reportable. Casual public contact is not.

Any contact with a known or suspected foreign intelligence entityReport it at once, whatever form it took. SEAD 3 defines a foreign intelligence entity as a known or suspected foreign state or non-state organization or person that conducts intelligence activities to acquire U.S. information. If an approach seemed off, that is the report.
Continuing association with a foreign nationalReportable when it involves “bonds of affection, personal obligation, or intimate contact,” or when “any contact with a foreign national ... involves the exchange of personal information.” The test is the nature of the relationship, “regardless of how or where the foreign national contact was made or how the relationship is maintained,” so an online friendship counts as much as a neighbor. After the first report, update it only when the nature of the contact significantly changes.

ODNI’s own illustration: one lunch with a friend’s foreign business partners is not continuing contact and would not normally be reported, and you need not ask people’s citizenship at a conference unless the contact becomes close and continuing. A foreign national who shares your home is a different matter: a roommate for more than 30 days is reportable at Top Secret, and a cohabitant, someone you live with and share bonds of affection or obligation with, is reportable at Top Secret whatever their citizenship. Official-duty contacts are handled under your company’s or customer’s rules, not this one.

What to includeName, citizenship, occupation, the nature of the relationship (business or personal), how long and how often you are in contact, and its current status (SEAD 3, Appendix A.3). For a suspected intelligence approach: who, when, what they wanted, anything unusual, and whether more contact is likely (Appendix A.2).

Foreign citizenship, passports, money and property

SEAD 3 is tiered. Everyone with eligibility reports the first two; Top Secret adds the rest.

ActivitySecret or ConfidentialTop Secret
Applying for or receiving foreign citizenshipReportReport
Applying for, holding or using a foreign passport or identity card for travelReportReport
Direct involvement in a foreign businessNot a SEAD 3 item at this levelReport
A foreign bank accountNot a SEAD 3 item at this levelReport
Owning foreign propertyNot a SEAD 3 item at this levelReport
Voting in a foreign electionNot a SEAD 3 item at this levelReport
Adopting a child who is not a U.S. citizenNot a SEAD 3 item at this levelReport

SEAD 3, sections G.1 and H.1. “Not a SEAD 3 item” does not mean irrelevant: foreign financial interests are weighed under Guideline B and foreign preference under Guideline C at any level, and your company’s procedures may ask you to report them anyway. When in doubt, tell your FSO.

Events in your own life

The personal events SEAD 3 names, for everyone and then for Top Secret, plus the two DCSA added for industry.

Someone tries to get protected information from youAttempted elicitation, exploitation, blackmail, coercion or enticement to obtain classified or legally protected information, by any means. All levels.
A journalist seeks protected informationMedia contacts, other than for official purposes, where the media seeks classified or legally protected information, whether or not anything was disclosed. Media contact that is part of your job need not be reported. All levels.
You are arrestedAny arrest, with dates, locations, charges or circumstances, and disposition. All levels. Report it before a record check does.
Bankruptcy, or a debt more than 120 days lateEither one, at all levels. At Top Secret also garnishment and “any unusual infusion of assets of $10,000 or greater such as an inheritance, winnings, or similar financial gain.”
Alcohol- or drug-related treatmentTreatment, with the reason, provider and dates. All levels. Seeking treatment is not itself disqualifying; SEAD 4 tells adjudicators to credit a person who “sought assistance and followed professional guidance.”
Marriage, a cohabitant, a foreign roommateAt Top Secret: marriage, a cohabitant, and any foreign national who shares your residence for more than 30 days (see foreign contacts).
Foreign-state cryptocurrency (industry)DCSA’s ISL 2021-02 adds, for DoD-cognizant contractors, ownership of cryptocurrency backed, hosted or managed by a foreign state, or a wallet hosted by a foreign exchange, with exceptions for holdings you did not know had a foreign nexus or hold through a diversified fund. The exact criteria are on the industry reporting page.
Specified mental-health events (industry)The same ISL lists defined events only: a court or administrative finding of incompetence, an order to consult a professional, hospitalization for a mental-health condition, a qualified professional’s diagnosis of one of seven named disorders, and a condition you believe substantially affects your judgment, reliability or trustworthiness. Counseling for ordinary life events is not on the list. See the exact criteria.
Not on the list, still reportableSEAD 3 names alcohol and drug treatment, not your own drug use, and has no general mental-health item. That does not make drug use safe to keep quiet about: your company must report any adverse information about a cleared employee, defined in the NISPOM as anything that “adversely reflects on the integrity or character of a cleared employee” or suggests their ability to safeguard classified information may be impaired, and drug involvement is Guideline H. If something in your life would worry an adjudicator, the question is not whether it is on this list but whether you want them to hear it from you.

About other cleared people

SEAD 3 section F.3 asks every covered individual to alert the security office to these, when seen in another cleared person.

  • An unwillingness to comply with rules and regulations or to cooperate with security requirements.
  • Unexplained affluence or excessive indebtedness.
  • Alcohol abuse.
  • Illegal use or misuse of drugs or drug activity.
  • Apparent or suspected mental-health issues where there is reason to believe they may affect the person’s ability to protect classified or legally protected information.
  • Criminal conduct.
  • Misuse of U.S. Government property or information systems.
  • Any activity that raises doubts as to whether another covered individual’s continued eligibility is clearly consistent with the interests of national security.

This is the part people find hardest. Two things make it fairer than it sounds. First, you report what you saw to your FSO; you do not judge it. The company may not file reports “based on rumor or innuendo” (§117.8(c)(1)), and the company, not you, decides whether what you described meets the threshold. Second, the report goes to adjudicators who weigh it under published guidelines; it is not a verdict. ODNI’s example for a co-worker’s DUI: “The incident should be reported to the security office.” If you suspect espionage, sabotage or terrorism, the company reports that to the FBI (§117.8(b)); tell your FSO immediately.

Why reporting first matters

It is written into the adjudication standard, not just into the advice.

Adjudicators are told to ask whether you reported itWhen information of security concern arises about someone who already holds eligibility, SEAD 4 directs the adjudicator to consider whether the individual “voluntarily reported the information,” “was truthful and complete in responding to questions,” “sought assistance and followed professional guidance,” has resolved or is likely to resolve the concern, and “has demonstrated positive changes in behavior” (Appendix A, ¶2(f)). Continuous vetting will often surface the same event; what it cannot supply is your account of it.
Not reporting is its own concernSEAD 3 says failure to comply with reporting requirements “may result in administrative action that includes, but is not limited to, revocation of national security eligibility.” SEAD 4 makes “failure to report or fully disclose, when required” a disqualifying condition in its own right for foreign contacts (Guideline B), foreign passports (Guideline C) and outside activities (Guideline L), and concealing relevant facts from a security official is Guideline E. The mitigating condition for that is “prompt, good-faith efforts to correct the omission ... before being confronted with the facts.”
A report is not a findingA required report is not an adverse determination. ODNI’s employee FAQ says a self-report “could require further investigation and adjudication until the issue is resolved,” following the same process used for information found during a background investigation, with due-process rights and the opportunity to appeal. Most reports end with the adjudicator closing the item. What happens when one does not is on when something comes up.

What your company adds

Its own written proceduresYour company must have procedures for how you learn these duties, how it receives and manages reports, and how you report concerns about others. Ask your FSO for them; they may add items or set lead times this page does not.
Status changes you should mentionThe company must report a cleared employee’s change of name, change of citizenship, death and termination of employment (§117.8(c)(3)). Tell your FSO about a name change or a new citizenship even though SEAD 3 does not list them for you.
Stepping away from classified workIf you no longer want to be processed or no longer want access, the company reports that and the reason (§117.8(c)(5)). Refusing to sign the SF 312 nondisclosure agreement is also reported (§117.8(c)(6)).
Leaving does not close the fileIf adverse information about you reaches the company, “the termination of employment of an employee does not negate the requirement to submit this report” (§117.8(c)(1)(i)). Resigning does not make a report go away; it only removes your account from it.

Training: you receive an initial briefing before access and refresher training at least every 12 months (§117.12(k)); the insider-threat awareness training covers reporting requirements too (§117.12(g)). The duty applies for the whole time you hold eligibility, including while your access is administratively suspended because your current work does not need it.

Sources

Checked against SEAD 3, SEAD 4, the ODNI employee FAQ and 32 CFR Part 117 (eCFR text current as of October 29, 2026); ISL 2021-02 as carried on this site’s industry reporting page, reviewed September 23, 2026. An independent guide for cleared employees, not legal advice. Your company’s procedures and your FSO’s instructions govern where they say more.