A Secret-level case closed in 109 days end to end in the fourth quarter of FY2025, against a government target of 40. Top Secret ran 220 days against 75. If you are holding an unfilled cleared seat and an uncleared candidate, that gap is not something you can paperwork your way out of. The front half of the chain is different. Sponsorship, the facility clearance, the justification of need and the package your FSO submits are all yours, and that is where avoidable delay collects.

What has to be true before you can sponsor anyone?

Your company needs a favorable entity eligibility determination, commonly called the facility clearance, before any employee touches classified material. You cannot apply for one yourself. A government contracting activity or an already-cleared contractor has to sponsor you, and that sponsor files the request in NISS.

The regulation is blunt. Under 32 CFR 117.9(a)(4), “neither the contractor nor its employees will be permitted access to classified information until the CSA has made an entity eligibility determination.” Paragraph (c)(10) closes the workaround: a contractor cannot apply for its own. A sponsor may act at any point where access is needed to participate, including the solicitation phase. You need not wait for award.

Per the NISS external user guide, the request is filed by a Sponsor GCA or Sponsor Industry user, and submitting it creates your facility profile automatically. If you are the prime and all classified work sits with your subs, 117.9(a)(5) still requires your own determination at the same level or higher. The company determination also runs on a separate track from your KMP clearances under 117.9(e)(2): neither waits on the other, but nobody gets access until both land. Whether your company qualifies is covered in Can a Company Sponsor a Security Clearance?, the wider duties in NISPOM in 2026.

How long does the facility clearance take, and where do packages die?

DCSA’s published roadmap starts a clock at day one, puts your FCL package into NISS on days 10 to 20, schedules DCSA’s review at day 20, and sets a day-45 deadline for key management personnel applications and fingerprints. Treat those as process targets, not a service level.

They come from a June 2022 DCSA Facility Clearance Branch briefing, and one step is stale: the slide has KMPs submitting “e-QIPs,” untrue since October 2023. The briefing also corrects a routine misreading: a facility clearance is not a clearance for a location or building. It is granted on the ownership, authority and control of your key management personnel.

Package contents split on award status. Pre-award, DCSA wants the solicitation number with release and close dates, written GCA authorization verifying pre-award access is required, the classification level, and a copy of the pre-award DD-254. Post-award, it wants the DD-254, the statement or performance work statement, and written GCA authorization for anything beyond NISPOM. The DD-254 is not discretionary: FAR 4.403(c)(1) requires DoD components and nondefense agencies with DoD industrial security agreements to use it. If nobody at your company can read one, start with How to Read a DD-254.

Now the number that should change your behavior. Revising its sponsorship procedures effective March 1, 2023, DCSA published its own baseline: sponsorship packages cycled 1.93 times each with a 53% rejection rate, and initial or upgrade FCL packages cycled 2.5 times with a 70% rejection rate. Its goal was 1.1 cycles and 15%. No newer rate has been published, so read those as a 2023 baseline, not today’s odds. The enforcement mechanism is what people miss. Return a package twice for the same unfixed defect and DCSA rejects the request outright; the sponsor starts over.

DCSA’s list of top rejection reasons is dominated by two failures. One is the DD-254: incorrect or incomplete information on it, or a sponsorship request that contradicts it. The other is justification, meaning no access required, no obvious bona fide need, or a solicitation that does not actually require pre-award access. Both are unforced. Both are fixed by having your FSO and contracts lead read the request and the DD-254 side by side before upload. If you have not appointed an FSO, that is the prior step.

Approval is not the end. Four things still have to finish: KMP clearances adjudicated and reflected in the system of record, DCSA’s internal vetting assessment, mitigation of any foreign ownership, control or influence, and an orientation meeting with a DCSA industrial security representative. No published average exists for total FCL issuance time. The milestones are predictable; the tail is not, because it turns on FOCI complexity and how fast your officers clear. Per DCSA’s March 2026 Voice of Industry, digital signatures are now accepted on the DD Form 441 and SF 328, removing the witness requirement.

Who decides the employee actually needs a clearance?

You do. Not the candidate, not the government. Under 32 CFR 117.10(a)(1)(i) the contractor must determine that access is essential to performing tasks or services under a classified contract. Paragraph (a)(7) adds a limit worth knowing: you may not submit for non-employees, nor for a subcontractor’s people.

The timing rule is the one hiring managers learn too late. You may request an investigation before the start date, but only with a written commitment for employment that the candidate has accepted in writing. That commitment must state employment will begin within 45 days of eligibility being granted. The offer letter is a gating document in the clearance timeline, not an HR formality, which is why contingent-offer sequencing matters as much as the terms.

What does your FSO actually submit to DCSA?

The chain DCSA documents for industry is short. The FSO initiates the case in NBIS, the subject completes the eApp form and submits it to the FSO, and the FSO reviews it and submits it to PSMO-I. What changed is where the form lives and what that receiving office is called.

e-QIP is finished. Industrial Security Letter 2024-02, issued May 20, 2024, told cleared contractors that as of October 1, 2023 the NBIS Electronic Application became the successor system for the SF-86. Ignore sources claiming an October 2024 decommissioning. The receiving office was renamed too: per DCSA’s March 2026 Voice of Industry, the office formerly called VRO reverted to its pre-merger name PSMO-I, while the adjudication shop formerly called CAS is now Trust Decisions.

The form itself is unchanged and enormous. The SF-86, Questionnaire for National Security Positions, runs 136 pages. eApp reorganized it from 34 sections into 10 groupings, but a candidate reconstructing a decade of addresses and verifiers still faces real hours. One detail prevents the most common stall: eApp mail arrives from [email protected], and DCSA advises confirming your firewall will not block it. A blocked notification is a case that sits.

Your FSO’s review is mandatory and narrow. 32 CFR 117.10(d) requires the SF-86 to be reviewed by the FSO or a specifically designated employee, and the following paragraphs limit that review to adequacy and completeness. Two submissions ride alongside: citizenship evidence must reach the FSO as originals or certified copies rather than scans, and fingerprints are separate, with 117.10(e) directing digital collection where possible.

How long does the investigation take once it is submitted?

Which investigation you are buying is set by the position, not the person. The FY2025-Q4 figures below are the government’s own, published by the Performance Accountability Council, whose report notes that end-to-end data runs a quarter behind because it is collected manually.

Keep the two vocabularies straight. 32 CFR 117.10(b)(1) never numbers the tiers it sets: it describes one investigative tier for moderate risk, non-critical sensitive positions allowing L, Confidential and Secret access, and another for high risk, critical sensitive and special sensitive positions allowing Q, Top Secret and SCI. Tier 3 and Tier 5 are DCSA billing names, and Federal Investigations Notice 24-01 prices the Tier 5 DoD customers must order in FY2026, adjudication bundled, at $6,240. That is a sticker price nowhere near your real exposure; the full model sits in what sponsoring a clearance actually costs.

Where the time goes is not where most people assume. The Trusted Workforce 2.0 quarterly progress report calls current timeliness “unacceptably higher than mandated performance targets” and says that while adjudications are significantly behind, investigation remains the greatest factor. On a Top Secret case, 168 of the 220 days are investigation.

When is sponsoring the wrong move?

When the seat has to bill soon. Sponsoring an uncleared candidate is the slowest path to a filled position that exists, and the regulation itself explains why hiring someone already cleared beats it.

Under 32 CFR 117.10(h), an existing eligibility built on an investigation whose scope meets or exceeds the new access requirement carries over: the prior investigation “will be used without further investigation or adjudication” unless significant unadjudicated derogatory information surfaces. Reciprocity is not a courtesy. It is a requirement, and it skips the 68 or 168 days of investigation entirely. If your program manager needs a body on contract this quarter, hire cleared and put sponsorship on the seats that can wait. Moving an existing clearance is covered in clearance crossover, the bulk version in re-badging after a recompete.

We sell job postings to cleared employers, so the honest version includes where a posting is the weaker instrument. On a recompete, the cleared people you need already sit on the contract and you get them through incumbent capture, not a req. On a genuinely scarce profile, a niche language plus an accreditation plus a polygraph, no job board will surface an already-cleared candidate, because that person may not exist in the open market. That is where sponsorship is not the slow option but the only one.

A middle path exists, with a narrower scope than most employers assume. 32 CFR 117.10(l) allows temporary eligibility, what the industry still calls interim, capped at one year absent CSA approval and unavailable to non-U.S. citizens. A temporary Secret does not open everything at that level: Restricted Data, COMSEC and NATO material each require a final Secret determination. What it authorizes, and what un-bills a seat afterward, is in time-to-billing on a cleared hire and how an interim works.

What happens between the determination and the first classified task?

One more document, and it can undo the entire chain. An employee determined eligible must execute a nondisclosure agreement before being granted any access, signed and dated in the presence of a witness, with both signatures bearing the same date.

32 CFR 117.10(g) states the consequence of refusal: the contractor denies access and reports it to the CSA. Mismatched dates on the NDA are a routine, preventable finding. Then the 45-day rule reasserts itself, because eligibility granted to someone who does not start inside that window is a problem you created at offer stage. One 2026 change matters for people already in seats: since March 5, 2026, reinvestigations and continuous vetting enrollments take the “5 year update” option on the NBIS order form rather than “Reinvestigation.”

The direction of travel is finally favorable. In the first quarter of FY2026, DCSA’s case inventory fell to roughly 117,000, a 56% decline since January 2025, and that showed up in processing: the fastest 90% of Secret investigations dropped 9.3 days, or 14%, and Top Secret dropped 50 days, or 32%. If that holds through FY2027, a Top Secret seat becomes a different planning assumption than the one your staffing model uses today. Until then, plan against the FY2025-Q4 actuals, and file the sponsorship request the week the solicitation drops rather than the week after award.

Frequently Asked Questions

Can a company sponsor a clearance before it has won the contract?

Yes. 32 CFR 117.9(c)(10) permits a GCA or a currently cleared contractor to sponsor an entity at any point where access is needed to participate, including the solicitation phase. A pre-award package needs the solicitation number with its release and close dates, written GCA authorization, the classification level, and a pre-award DD-254.

What replaced e-QIP for submitting the SF-86?

NBIS eApp. DCSA’s Industrial Security Letter 2024-02, issued May 20, 2024, states that eApp became the successor system to e-QIP as of October 1, 2023. eApp reorganized the SF-86 from 34 sections into 10 groupings. The form is still 136 pages, and notifications arrive from [email protected], a domain worth allowlisting first.

Where does the DD-254 live now that NCCS is gone?

In NISS Increment II. DCSA’s March 2026 Voice of Industry newsletter confirms the NI2 go-live occurred on January 30, 2026, that the legacy NCCS application was disabled the same day, and that the DD-254 workflow migrated to the new environment.

How long does it take to sponsor an employee for a Secret clearance?

In FY2025-Q4 a moderate-risk case averaged 4 days to initiate, 68 to investigate and 37 to adjudicate, for 109 days end to end across 105,438 cases. That assumes your facility clearance already exists. If not, add the FCL process on the front, which the roadmap tracks through day 45 and which then turns on FOCI mitigation and KMP timing.

Can the FSO read what the candidate discloses on the SF-86?

The FSO or another specifically designated employee must review the SF-86 under 32 CFR 117.10(d), but only for adequacy and completeness. The regulation bars using anything disclosed in it for any other purpose within the company. Citizenship evidence is handled separately and must be an original or certified copy, not a scan.