Clearance Crossover:
Moving Your Clearance to a New Contractor Without Losing It
When you resign from a cleared contractor, your access to classified information ends that day. Your eligibility does not. Under Security Executive Agent Directive 7, walking away from an employer is an administrative termination of access,…
July 15, 2026
Security Clearance
When you resign from a cleared contractor, your access to classified information ends that day. Your eligibility does not. Under Security Executive Agent Directive 7, walking away from an employer is an administrative termination of access, not a denial or revocation of your clearance. Practitioners call the move that follows a clearance crossover: your existing eligibility follows you to the next contractor, and the only thing that really changes is which company holds the owning relationship on the government’s behalf.
Key takeaways
- A crossover is not a revocation. Leaving a contractor is an administrative termination of access, not a loss of eligibility (SEAD 7, 2018).
- Reciprocity is fast on paper: a gaining agency must make a national security reciprocity determination within 5 business days (SEAD 7, 2018).
- The gap risk is real. A break in employment that results in loss of eligibility requires a brand-new eligibility determination before any new access (32 CFR 117.10(j)(2)).
- Your investigation has to be current: reciprocity can be refused if your last background investigation is more than 7 years old (SEAD 7).
- About 5.4 million people held national security eligibility as of October 2022, roughly 5 million tied to DoD (GAO, 2025).
What does a clearance crossover actually mean?
A crossover is a contractor-to-contractor move in which your existing eligibility follows you. Access is administratively terminated at the old job and reinstated at the new one once a short list of conditions is met. The clearance was never yours; it belongs to the government and is sponsored by whichever company employs you.
A clearance is not a credential you own and carry between jobs like a driver’s license. The government holds the eligibility; a contractor sponsors it because a specific contract needs someone with access. Under 32 CFR 117.10, a contractor may grant access only when the employee has a valid need-to-know, a favorable government eligibility determination at the appropriate level, and a signed non-disclosure agreement. Pull the sponsor away and the access stops. The eligibility stays where it was.
That is why SEAD 7 draws a hard line around the word terminated. A departure from a sensitive position, a change of need-to-know, or no longer being affiliated with a government contract is an administrative termination. It is not the same event as a suspension or revocation, which is an adverse action against your eligibility itself. One is paperwork. The other is a finding. Because a contractor can sponsor only its own people, there is no in-between status in which you hold the clearance yourself; Section 117.10 bars requesting eligibility for anyone who is not its employee or consultant. The economics of sponsoring a clearance and the difference between contractor and federal employment explain why a new employer has to absorb the cost of picking you up.
How does reciprocity move your clearance to a new contractor?
Reciprocity forces a gaining agency to accept a clearance another agency already granted. Under SEAD 7 the determination is due within five business days, no new SF-86 is required, and the new employer’s FSO re-establishes the owning relationship in DISS.
The rule that makes it possible is 32 CFR 117.10(h): any current eligibility based on an investigation whose scope meets or exceeds the required level of access becomes the basis for a new determination, used without further investigation or adjudication unless the agency learns of significant unadjudicated derogatory information. It is not optional. A contractor is barred from submitting a fresh request if you are already cleared or in process elsewhere. It must use reciprocity and hand the gaining agency your full name, date and place of birth, Social Security number, clearing agency, and type of investigation.
SEAD 7 puts a clock on it. Reciprocity determinations for national security investigations and adjudications are due within five business days of the gaining agency’s security office receiving the file. You do not fill out a new SF-86; the directive says a new questionnaire shall not be requested, and at most you identify what has changed since your last one. The gaining agency confirms your history in Scattered Castles, the Department of Defense adjudication system, or OPM’s Central Verification System.
One wrinkle the directive’s own text carries: it still names the Joint Personnel Adjudication System as the DoD database, alongside a catch-all for successor databases. The DoD system of record is now the Defense Information System for Security, or DISS, where your owning relationship lives today. If the acronyms blur, the differences between Scattered Castles and DISS repay a separate look, and the FSO at your new employer is the person who executes the handoff.
On paper the crossover is quick; in practice the data systems lag. When the Government Accountability Office studied how vetting determinations move between agencies, 28 of the 31 it surveyed said their IT systems at times lacked the complete information needed to make a reciprocity determination. About 5.4 million people held national security eligibility as of October 2022, roughly 5 million tied to the Department of Defense.
When can a gaining agency refuse reciprocity?
Reciprocity is mandatory but not unconditional. A gaining agency can decline it if your last background investigation is over seven years old, if new derogatory information has surfaced, if your prior adjudication carried a documented exception, or if your eligibility was only temporary or interim rather than final.
The exception that catches movers most often is investigation age. If your most recent background investigation is more than seven years old, the gaining agency need not accept it and must immediately initiate a reinvestigation. New adverse information, an adjudication carrying a documented exception, and a Bond Amendment disqualifier for SCI or special access programs also break reciprocity.
Interim status is the quiet trap. Reciprocity does not flow from an eligibility granted on a temporary, interim, limited, or one-time basis. If your current access is a temporary determination under SEAD 8, capped at one year unless your agency extends it, the new employer cannot ride it and must wait for the final determination. Anyone moving on an interim security clearance should treat that as a hard blocker. The level and scope of your investigation matter too, because reciprocity only works when the prior investigation meets or exceeds what the new access requires.
Contrast all of this with an actual adverse action. If your eligibility has been denied or revoked, reciprocity is off the table, and absent mitigation you should expect to remain ineligible for national security duty for a minimum of one year from the date of the denial or revocation. A crossover is not that.
What is the gap risk, and how does a Loss of Jurisdiction happen?
The real danger in a crossover is the gap between owning employers. If your access lapses and no new sponsor picks you up while something is pending, DISS can show a Loss of Jurisdiction. A break in employment that actually costs you eligibility forces a brand-new determination.
Here is the mechanism the reassuring version leaves out. Section 117.10(j) treats a break in employment differently from a break in access. Leave and return while remaining eligible with a current investigation, and a contractor can reinstate your access on agency guidance. But the same section states flatly that a contractor may not grant access to someone whose break in employment already resulted in a loss of eligibility, without a new eligibility determination by the agency. That is the trapdoor. The moment a gap becomes a loss, you are starting over.
Loss of Jurisdiction, or LOJ, is the DISS status that appears when the owning relationship ends and no new sponsor establishes cognizance while an issue is pending. The government temporarily has no one responsible for adjudicating you. LOJ is not a revocation and it is not a denial; it is a paused state that resolves when a new employer re-establishes the owning relationship in DISS. Its regulatory backbone is that same subsection on breaks in employment. Two deeper reads earn their place here: what a security clearance Loss of Jurisdiction is, and how to keep a Loss of Jurisdiction from sinking your cleared career.
A clean move avoids all of this because of continuous vetting. Under Trusted Workforce 2.0, continuous vetting replaced periodic reinvestigations with ongoing automated record checks of public and government data, and an alert prompts a closer look. Your eligibility is a live record, not a periodic checkpoint. While that record stays current and a sponsor holds the owning relationship, the crossover rides reciprocity.
Crossover vs. Loss of Jurisdiction vs. revocation
The three states get conflated constantly, yet the path forward from each is different.
| Aspect | Crossover (administrative termination) | Loss of Jurisdiction | Denial or revocation |
|---|---|---|---|
| What triggers it | Employer change; access ends at the old job | No sponsor holds the owning relationship while an issue is pending | Adverse adjudicative finding against eligibility |
| Effect on eligibility | Intact | Paused, not decided | Lost |
| Access to classified | Reinstated at the new job on reciprocity | Suspended until a sponsor re-establishes cognizance | Denied immediately, regardless of location |
| Path forward | New FSO takes the owning relationship in DISS | New employer re-establishes the owning relationship | Appeal or reapply; minimum one year absent mitigation |
What should you ask a new employer before you resign?
Before you give notice, get four answers from the gaining FSO. Will they take the owning relationship in DISS with no gap? Is your last investigation under seven years old? Is your current eligibility final rather than interim? And can a signed offer start pre-employment processing early?
You have the most room to protect yourself before you resign, not after. Ask the gaining company’s FSO these four questions, and get the answers in writing.
- Will you take the owning relationship in DISS immediately, with no gap? The biggest risk is a lapse between owning employers. You want the new FSO to establish cognizance the day your old access ends, so no window opens for a Loss of Jurisdiction.
- Is my most recent background investigation under seven years old? If it is older, the gaining agency can refuse reciprocity and order a reinvestigation before you are usable on the contract.
- Is my current eligibility final, not interim? Reciprocity does not carry a temporary or interim determination. If you are still on interim status, plan the timing around your final determination.
- Is there a signed offer so pre-employment processing can start early? With a written commitment stating employment will begin within 45 days of your eligibility being granted, the new contractor can begin the paperwork before your first day under 32 CFR 117.10(f)(2).
Each of these maps to a rule, not a preference. The responsibilities of an FSO in a cleared facility are defined tightly enough that a good one answers all four without hesitation. If they hedge, that is information too.
Will a crossover reopen my finances?
A routine crossover does not restart your investigation, so it does not trigger a fresh look at your debt on its own. Guideline F has no dollar threshold. Adjudicators weigh judgment and good-faith resolution, not a specific number, and continuous vetting already watches the records that matter.
The fear that keeps people from moving is that switching employers will surface old debt and cost them the clearance. It usually does not. Reciprocity uses your existing investigation, and continuous vetting already monitors the financial records that count, so a clean move opens no new inquiry by itself. If a concern does surface, know what the rule says. Guideline F of the national security adjudicative guidelines contains no dollar threshold: no amount of debt automatically disqualifies you, and none automatically clears you. What matters is whether financial behavior shows poor judgment or unreliability. The mitigating conditions are concrete: debt from circumstances largely beyond your control, such as job loss, a medical emergency, divorce, or identity theft, where you acted responsibly, plus a good-faith effort to repay or resolve what you owe. If your finances worry you going into a move, the fuller picture of protecting a clearance over financial concerns is the place to start.
Frequently Asked Questions
Can I hold my own clearance between jobs if I have no employer?
No. A clearance is sponsored, not self-held. 32 CFR 117.10 bars a contractor from requesting eligibility for anyone who is not its employee or consultant, and there is no personal status in which you keep it on your own. If a break in employment costs you eligibility, a new agency determination is required before any new access.
Does a crossover require a new SF-86?
No. Under SEAD 7, a new SF-86 shall not be requested when you move on reciprocity. The gaining agency may ask you to identify what has changed since your last questionnaire, but it works from your existing investigation.
Is a Loss of Jurisdiction the same as losing my clearance?
No. A Loss of Jurisdiction is a paused state in DISS that appears when no sponsor holds the owning relationship. Your eligibility is not decided against you; it is waiting for a new employer to re-establish cognizance. A revocation, by contrast, is an adverse finding, and access is denied immediately regardless of your location.
How current does my investigation have to be?
Reciprocity can be refused if your most recent background investigation is more than seven years old, at which point the gaining agency must initiate a reinvestigation. Continuous vetting under Trusted Workforce 2.0 keeps your record current in the meantime, which is what lets most crossovers clear without a new investigation.
Can my new employer start the paperwork before my start date?
Yes. With a written offer stating employment will begin within 45 days of your eligibility being granted, the contractor can submit pre-employment processing before your first day under 32 CFR 117.10(f)(2).
Treat a crossover the way DISS treats it: as a handoff, not a restart. Before you sign the resignation letter, get the gaining FSO to confirm in writing that they will take the owning relationship the day your old access ends. In the Trusted Workforce 2.0 system now in force, continuous vetting has replaced the old periodic reinvestigation, and your eligibility record moves faster than any HR timeline. Make sure it is moving toward a sponsor and not into a gap, and the strongest move in a cleared career stays what it should be: a step up, never a reset.