§ 147.32 Temporary eligibility for access at the top secret and SCI levels and temporary eligibility for “Q” access authorization: For someone who is not the subject of a current, favorable personnel or personnel-security investigation of any kind.

Quick Answer: What This Section Does

§ 147.32 explains when the government may grant temporary eligibility (interim clearance) for:

• Top Secret access
• Sensitive Compartmented Information (SCI)
• “Q” access authorizations

👉 when there is no current, favorable investigation on file

This is the most restrictive and highest-risk interim clearance category.

In practice, this section answers:

“Can I get interim Top Secret clearance with no prior investigation?”

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What This Means in Practice

Most applicants assume:

👉 interim clearance requires an existing investigation

This section allows temporary eligibility even without one—but under strict conditions.

This is not common.

And it is not easy to obtain.

Adjudicators are not asking:

👉 “Has this person been cleared before?”

They are asking:

👉 “Do we have enough immediate information to justify taking a risk?”

That distinction matters.

Because:

👉 this scenario involves the least amount of verified background information

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How This Rule Is Actually Used

Temporary eligibility under this section may be granted only when:

• there is a strong operational need
• initial checks do not reveal disqualifying concerns
• expedited investigation is immediately initiated

However:

👉 this type of interim access is highly scrutinized
👉 and often denied or delayed

This is why many applicants do not receive interim Top Secret clearance, as explained in how interim security clearances work and why higher-risk cases are often denied early.

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Full Text of § 147.32

§ 147.32 Temporary eligibility for access at the top secret and SCI levels and temporary eligibility for “Q” access authorization: For someone who is not the subject of a current, favorable personnel or personnel-security investigation of any kind.

As a minimum, such temporary eligibility requires completion of the Standard Form 86, including any applicable supporting documentation, favorable review of the form by the appropriate adjudicating authority, immediate submission of a request for an expedited Single Scope Background Investigation (SSBI), and completion and favorable review by the appropriate adjudicating authority of relevant criminal history and investigative records of the Federal Bureau of Investigation and of information in the Security/Suitability Investigations Index (SII) and the Defense Clearance and Investigations Index (DCII).

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Why This Matters for Your Case

This section reflects one of the most important principles in clearance law:

👉 the less information the government has, the higher the risk

Two applicants may apply for Top Secret access:

• one has an existing investigation
• one has none

The second applicant faces:

👉 greater scrutiny
👉 greater delay
👉 greater likelihood of denial

This is because interim decisions rely heavily on early signals, as explained in what an interim clearance denial actually means and how it reflects underlying risk concerns.

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Where These Cases Almost Always Go Wrong

This is the most fragile stage of the clearance process.

Problems arise when:

• the SF-86 contains inconsistencies
• financial or criminal issues appear early
• foreign contacts raise questions
• prior history is unclear or incomplete
• initial database checks reveal concerns

From the applicant’s perspective:

👉 “They haven’t even investigated me yet”

From the system’s perspective:

👉 “We don’t have enough information to justify access”

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How This Section Connects to the Investigation

This provision immediately triggers:

👉 a full Single Scope Background Investigation (SSBI)

This is the most intensive investigation type, as explained in what a Top Secret SSBI background investigation includes and how it differs from other clearance levels.

During this process:

• new issues may be discovered
• the investigation may expand
• interim access may be revoked

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How This Section Fits Into the Clearance Process

This rule applies at the earliest and most uncertain stage of the security clearance process from application through adjudication.

It directly affects:

• access to Top Secret roles
• hiring timelines for sensitive positions
• entry into high-security programs

These early decisions often predict outcomes under the security clearance adjudication process and how risk is evaluated at the highest levels.

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How This Section Interacts With Other Rules

This section is closely related to:

• §147.30 (Secret-level interim access)
• §147.31 (Top Secret interim with a prior investigation)
• Standard B (SSBI investigation requirements)

Together, these determine:

👉 how much information is required before access is granted
👉 how risk is evaluated at different stages

Return to the full statute list in the Security Clearance Statutes and Regulations resource page, or explore how these rules are applied in practice in the Security Clearance Lawyers Resource Center.

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Why Insight Into the System Matters

Security clearance decisions are not made in a vacuum.

They are made by:

• adjudicators
• administrative judges
• agency decision-makers
• reviewers who rely on the written record

Understanding how these individuals evaluate risk, credibility, and mitigation is not theoretical—it is structural.

At National Security Law Firm, our security clearance lawyers include attorneys who have worked:

• as administrative judges and adjudicators responsible for deciding clearance cases
• inside federal agencies evaluating whether individuals should be approved or denied
• within military legal systems handling sensitive national security matters
• in roles directly applying the adjudicative guidelines to real-world cases

Our cases are not handled by a single attorney working in isolation.

They are reviewed through our internal Attorney Review Board, where multiple experienced attorneys analyze the record, test arguments, and refine strategy before submission.

This mirrors how the government evaluates cases—through layered review and institutional scrutiny.

Clients often come to us after receiving advice that focuses only on:

• legal arguments
• explanations of past conduct

But security clearance cases are not decided that way.

They are decided based on:

👉 how the record will be read, reused, and defended by decision-makers

That is the difference between a response that explains—and a record that supports approval.

You can read what clients say about their experience working with our team in our 4.9-star Google reviews, which reflect both outcomes and the level of strategic guidance we provide throughout the process.

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Speak With a Security Clearance Lawyer Before High-Risk Interim Decisions Are Made

The most important question is not:

👉 “Can I get interim Top Secret clearance?”

It is:

👉 “What does my record show before the government even investigates me fully?”

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The Record Controls the Case.