If TSA’s criminal-history information is substantially correct but the identified condition is eligible for discretionary relief, a TWIC waiver may allow you to obtain a Transportation Worker Identification Credential.
A waiver does not argue that the disqualifying event never occurred. Instead, it asks the Transportation Security Administration to review the circumstances, your subsequent conduct, and the supporting evidence and determine that you do not presently pose a security threat.
A strong TWIC waiver application should do more than tell TSA you have changed. It should demonstrate rehabilitation, reliability, responsibility, and judgment through credible explanations and independently verifiable records.
The deadline matters. Under 49 C.F.R. § 1515.7, a waiver may be requested during the application process, after pursuing some or all available appeal procedures, or no later than 60 days after service of TSA’s Final Determination of Threat Assessment.
National Security Law Firm represents TWIC applicants nationwide. We have handled TWIC and HME matters since 2016 and have represented applicants in hundreds of TSA credential cases.
For qualifying initial-stage TWIC waiver matters, our flat legal fee is $2,495. We identify and obtain necessary records, develop the evidence, prepare the waiver request, organize the exhibits, submit the package, and manage the matter through the covered TSA stage.
Schedule a free consultation or call (202) 600-4996.
What Does a TWIC Waiver Do?
A TWIC waiver asks TSA to exercise its authority to grant a credential despite an otherwise disqualifying condition.
Under 49 C.F.R. § 1515.7, TSA may grant a waiver when it determines that the applicant does not pose a security threat. In evaluating the request, TSA considers factors relevant to the particular condition, including:
- The circumstances of the disqualifying act or offense
- Restitution made by the applicant
- Federal or state mitigation remedies
- Relevant court records
- Official medical-release documents, when applicable
- Other evidence showing that the applicant does not pose a security threat warranting denial of the TWIC
The governing statute, 46 U.S.C. § 70105, likewise authorizes waiver consideration and directs attention to the circumstances of the disqualifying act, the period that has elapsed, restitution, and other appropriate factors.
A waiver is discretionary. Establishing that an offense is technically waivable gives the applicant an opportunity to request relief; it does not require TSA to approve the request.
Do You Need a TWIC Waiver or an Appeal?
The first question is whether TSA’s adverse determination is correct.
You May Need an Appeal If TSA Is Wrong
A TWIC card appeal may be appropriate when:
- The criminal record belongs to another person.
- The charge was dismissed.
- You were acquitted.
- You were convicted only of a lesser or nondisqualifying offense.
- TSA relied on an incomplete disposition.
- TSA used the wrong conviction or release date.
- The offense does not match the federal category TSA identified.
- A conviction was overturned, vacated, pardoned, or otherwise legally altered.
- An interim offense falls outside both applicable time periods.
An appeal asserts that TSA’s facts or legal conclusion are wrong.
You May Need a Waiver If TSA Is Correct
A waiver may be appropriate when:
- The disqualifying conviction is accurately reported.
- The offense falls within TSA’s waiver authority.
- The applicable interim period has not expired.
- The applicant can present evidence demonstrating rehabilitation and present reliability.
You May Need Both
An applicant may dispute TSA’s classification while requesting a waiver in the alternative.
For example, the applicant may argue that a state conviction does not satisfy the elements of the federal category TSA identified. If TSA rejects that argument, the applicant may alternatively ask TSA to waive the condition based on rehabilitation and present reliability.
Alternative arguments must be framed carefully. An applicant should not inadvertently concede a disputed conviction or legal classification merely by submitting a waiver request.
For a broader discussion of both remedies, visit our TWIC waiver and appeal lawyer page.
Who Is Eligible to Request a TWIC Waiver?
The federal regulations divide disqualifying offenses into permanent and interim categories. However, the word “permanent” does not mean that every offense in that category is nonwaivable.
Under 49 C.F.R. § 1515.7, TSA may consider waiver requests from:
- Applicants with permanent disqualifying offenses listed in 49 C.F.R. § 1572.103(a)(5) through (a)(12)
- Applicants with interim disqualifying offenses listed in § 1572.103(b)
- Certain applicants holding Temporary Protected Status
- Certain applicants subject to TSA’s mental-capacity standard
This page does not reproduce the complete list of offenses. The precise statute of conviction, disposition, dates, and regulatory category must be reviewed before concluding that a person qualifies for a waiver.
Can a “Permanent” TWIC Offense Be Waived?
Some permanent disqualifying offenses can be waived.
The waiver regulation covers the permanent offenses listed in 49 C.F.R. § 1572.103(a)(5) through (a)(12). Those categories include certain serious offenses involving transportation security incidents, hazardous materials, explosives, murder, threats concerning explosives or lethal devices, qualifying RICO violations, and attempts or conspiracies associated with specified offenses.
A conviction’s placement in TSA’s permanent category means that the seven-year and five-year expiration rules do not automatically remove the disqualification. It does not necessarily mean TSA lacks authority to grant a waiver.
Because these offenses are serious, an effective application usually requires extensive evidence, a candid explanation, and a compelling demonstration of present reliability.
Are All Interim Disqualifying Offenses Waivable?
The interim disqualifying offenses in 49 C.F.R. § 1572.103(b) fall within TSA’s waiver authority.
Interim offenses are time-limited for disqualification purposes. They are disqualifying if either:
- The applicant was convicted or found not guilty by reason of insanity within seven years of the TWIC application; or
- The applicant was incarcerated for the offense and released within five years of the application.
An applicant who remains within either applicable period may request a waiver. If the applicant falls outside both periods, an appeal may be the better remedy because the offense may no longer be disqualifying.
A waiver should not be used to concede an interim disqualification before the conviction and release dates are calculated correctly.
Which Conditions Cannot Be Waived?
The criminal-offense waiver authority in 49 C.F.R. § 1515.7 does not extend to the first four permanent categories listed in § 1572.103(a):
- Espionage or conspiracy to commit espionage
- Sedition or conspiracy to commit sedition
- Treason or conspiracy to commit treason
- A federal crime of terrorism, a comparable state offense, or conspiracy to commit such an offense
The permanent-offense provision also separately addresses attempts to commit the crimes in the first four categories.
Other barriers may require an appeal rather than a waiver or may be governed by a different procedure. An applicant’s eligibility should therefore be determined from the specific TSA notice and underlying records—not from the general title of an offense on a commercial background report.
What Does TSA Consider in a TWIC Waiver Application?
TSA’s central question is whether the applicant presently poses a security threat.
That determination is broader than asking whether the applicant completed a criminal sentence. TSA may examine the offense, the applicant’s conduct since the offense, the reliability of the supporting evidence, and whether the record as a whole demonstrates rehabilitation and responsible judgment.
Relevant considerations may include:
- The nature and seriousness of the offense
- The applicant’s role in the conduct
- The circumstances surrounding the offense
- The applicant’s age and maturity at the time
- Whether violence, weapons, drugs, fraud, or abuse of trust were involved
- The amount of time that has elapsed
- The applicant’s criminal history before and after the offense
- Completion of incarceration, probation, or parole
- Payment of restitution, fines, and other obligations
- Treatment or rehabilitation
- Employment stability
- Professional conduct and safety history
- Education and training
- Community involvement
- Family responsibilities
- Candor and acceptance of responsibility
- Current evidence of reliability
- Evidence contradicting or aggravating the applicant’s account
No single factor guarantees approval. TSA evaluates the complete record.
How Should You Discuss the Disqualifying Offense?
The explanation of the offense is one of the most important and difficult parts of a TWIC waiver.
An effective statement should be:
- Accurate
- Consistent with the official records
- Candid about established conduct
- Specific enough to demonstrate insight
- Focused on responsibility rather than excuses
- Connected to evidence of change
An applicant does not strengthen a waiver by minimizing serious conduct or blaming everyone else. TSA may compare the personal statement with the charging documents, plea agreement, judgment, police records, or other evidence.
At the same time, accepting responsibility does not require admitting conduct that was dismissed, never established, or inaccurately reported. The statement should distinguish between:
- The offense of conviction
- Allegations that were dismissed
- Facts the applicant admits
- Facts the applicant disputes
- Relevant context
- The lessons and changes that followed
A strong explanation ordinarily addresses:
- What happened.
- What responsibility the applicant accepts.
- What the applicant learned.
- What changed after the offense.
- How those changes are documented.
- Why the conduct is unlikely to recur.
- Why TSA can rely on the applicant today.
What Evidence Should a TWIC Waiver Include?
The correct evidence depends on the offense and the applicant’s history. A comprehensive waiver may include several categories of documentation.
Court and Criminal-Case Records
TSA should be given enough official information to understand the actual offense and disposition.
Relevant documents may include:
- Charging documents
- Indictment or information
- Plea agreement
- Plea transcript
- Judgment of conviction
- Sentencing order
- Sentencing transcript
- Docket sheet
- Probation or parole records
- Proof of release from incarceration
- Restitution records
- Expungement, pardon, vacatur, or mitigation orders
- Records showing completion of the sentence
Not every document belongs in every case. Police reports, for example, may contain disputed allegations or information that was never established. Before including them, the applicant should understand whether they help, harm, or complicate the presentation.
Proof of Sentence Completion
Evidence that the applicant completed all court-ordered obligations may include:
- A probation-discharge order
- A parole-completion letter
- Corrections records
- Proof of release from custody
- Receipts or court records showing payment of fines
- Restitution-payment records
- Community-service records
- Proof of completed court-ordered programming
Completion of the sentence is important, but it is normally the beginning of a rehabilitation argument—not the entire argument.
Restitution
TSA’s waiver regulation expressly identifies restitution as a relevant factor.
If restitution was ordered, the application should document:
- The amount ordered
- The amount paid
- The payment history
- Whether the obligation has been satisfied
- Any court-approved payment arrangement
- The reason for any outstanding balance
- Evidence of continuing compliance
Ignoring unpaid restitution can create the impression that the applicant has not accepted responsibility. If the balance remains outstanding, the submission should address it accurately and provide evidence of current compliance.
Treatment and Rehabilitation
When the offense involved substance use, mental health, anger, trauma, or another treatable condition, relevant records may include:
- Substance-use treatment records
- Counseling records
- Mental-health treatment
- Anger-management completion
- Recovery-program participation
- Drug-testing records
- Letters from treatment providers
- Relapse-prevention planning
- Reentry-program completion
- Peer-support or mentoring activities
Sensitive medical or treatment records should be selected carefully. The goal is to document relevant rehabilitation without disclosing unnecessary private information.
Employment and Professional Reliability
A stable work history can provide concrete evidence of present responsibility.
Useful records may include:
- Employment-verification letters
- Supervisor recommendations
- Performance evaluations
- Promotions
- Attendance records
- Safety awards
- Professional licenses
- Trade certifications
- Specialized maritime training
- A conditional job offer requiring a TWIC
- Evidence of trusted workplace responsibilities
- Proof of long-term employment in regulated environments
An employer letter is strongest when it provides specific examples of the applicant’s reliability, honesty, judgment, and performance.
Education and Training
Relevant education and training may include:
- Degrees
- Diplomas
- Trade-school records
- Apprenticeship completion
- Occupational certificates
- Safety training
- Maritime credentials
- Leadership training
- Continuing education
- Rehabilitation or decision-making programs
The submission should explain how the training reflects rehabilitation or present reliability rather than attaching certificates without context.
Character References
Character letters should come from people who know the applicant well enough to provide specific, credible observations.
Potential references include:
- Employers
- Supervisors
- Coworkers
- Union representatives
- Probation or parole officers
- Counselors or treatment providers
- Religious or community leaders
- Coaches or mentors
- Longtime friends
- Family members
A useful character letter should explain:
- How the writer knows the applicant
- How long the relationship has existed
- Whether the writer knows about the offense
- What changes the writer has personally observed
- Specific examples of responsibility or trustworthiness
- Why the writer believes the applicant can be trusted with a TWIC
Ten generic letters using identical language may be less persuasive than three detailed and independent letters.
Community, Volunteer, and Family Responsibilities
Community and personal evidence may include:
- Volunteer records
- Charitable involvement
- Mentoring
- Coaching
- Religious or civic participation
- Caregiving responsibilities
- Evidence of stable family life
- Support provided to children or relatives
- Community awards or recognition
These activities should not be presented as though good deeds erase the offense. They should help demonstrate the person’s sustained conduct and responsibilities since the disqualifying event.
Federal or State Mitigation Remedies
TSA may consider federal or state mitigation remedies. Depending on the case, these may include:
- A pardon
- Expungement
- Set-aside
- Vacatur
- Certificate of rehabilitation
- Restoration of civil rights
- Judicial findings concerning rehabilitation
- Completion of a diversionary disposition
- Other formal relief affecting the conviction or its consequences
The legal effect of these remedies varies. The complete order and governing law should be reviewed before asserting that the remedy eliminates or mitigates TSA’s concern.
How Do You Organize a TWIC Waiver Application?
A persuasive application should make it easy for the decision-maker to understand the case and locate the supporting evidence.
A waiver package may contain:
- A formal request for a waiver
- An executive summary
- A procedural and factual history
- An explanation of waiver eligibility
- A discussion of the offense
- An analysis of TSA’s waiver factors
- Evidence of rehabilitation and present reliability
- The applicant’s personal statement
- A table or index of exhibits
- Clearly labeled supporting documents
- A specific request that TSA grant the waiver
The exact structure should be tailored to the record. A complicated case involving multiple convictions, inconsistent records, or a serious permanent offense generally requires a more detailed submission than a single old interim offense.
Why We Do Not Recommend Generic TWIC Waiver Templates
A generic sample TWIC waiver letter may appear convenient, but it can encourage applicants to submit an incomplete or ineffective administrative record.
Templates frequently fail because they:
- Use the same arguments for every offense.
- Do not address TSA’s actual concern.
- Omit relevant court records.
- Ignore restitution.
- Rely on unsupported claims of rehabilitation.
- Include generic character letters.
- Minimize the offense.
- Create inconsistencies with the official record.
- Fail to distinguish an appeal from a waiver.
- Overlook aggravating evidence.
- Do not preserve the record for later review.
The greatest danger is not merely that TSA might deny the waiver. Under 49 C.F.R. § 1515.11, an Administrative Law Judge reviewing a waiver denial generally may consider only the evidence and information previously presented to TSA in the waiver request.
An applicant ordinarily cannot repair an incomplete waiver by adding new evidence during ALJ review. If new evidence exists, the regulation directs the applicant toward a new waiver request, and the pending ALJ review will be dismissed.
For that reason, we do not provide a generic downloadable waiver letter. The initial submission should be treated as the administrative record on which later review may depend.
When Can You Submit a TWIC Waiver?
Under 49 C.F.R. § 1515.7, a waiver may be requested:
- During the TWIC application process;
- After receiving TSA’s Initial Determination;
- While pursuing an appropriate appeal;
- After completing some or all of the appeal procedure; or
- No later than 60 days after service of the Final Determination of Threat Assessment.
An applicant does not always need to wait for a Final Determination before requesting a waiver.
The correct timing depends on whether the applicant disputes the disqualification, needs TSA’s releasable materials, requires additional court records, or intends to combine an appeal with an alternative waiver request.
Can You Request More Time?
TSA may grant an extension for good cause under 49 C.F.R. § 1515.7(e).
A request made before the deadline should:
- Be submitted in writing
- Identify the deadline
- Explain why additional time is necessary
- Describe the records or evidence being pursued
- Explain the efforts already made
- Request a specific additional period
- Be received within a reasonable time before the deadline
The regulation also permits a request after a deadline has expired if the applicant explains why the failure to file on time was excusable. TSA has discretion to grant or deny the extension.
Difficulty obtaining archived records, delayed agency responses, hospitalization, delayed service, or another documented circumstance may support good cause depending on the facts. Do not assume an extension will be granted.
What Happens If TSA Requests Additional Information?
TSA may determine that it needs more information or documentation before deciding the waiver.
A request for information should be reviewed carefully. Determine:
- Exactly what TSA requested
- The response deadline
- Whether the requested record exists
- Which agency or person possesses it
- Whether the request reveals a weakness or inconsistency
- Whether additional explanation is necessary
- Whether the response affects another argument
The applicant should answer the request directly and completely. If a record cannot be obtained, the response should document the efforts made and provide the best available alternative evidence.
Do not ignore a TSA request merely because the original package was extensive. A failure to respond can prevent TSA from resolving the concern in the applicant’s favor.
How Long Does TSA Have to Decide a TWIC Waiver?
Under 49 C.F.R. § 1515.7(d), TSA ordinarily sends a written decision granting or denying the waiver within 60 days after service of the waiver request.
However, the regulation permits TSA to use a longer period for good cause. Actual processing time can therefore exceed 60 days.
Timing may also be affected by:
- Requests for additional information
- Missing court records
- Inconsistent evidence
- Multiple criminal cases
- The seriousness or complexity of the offense
- TSA’s workload
- The need for additional agency review
No attorney can guarantee when TSA will issue a decision.
What Happens If TSA Grants the Waiver?
If TSA grants the waiver, it determines that the applicant does not pose a security threat warranting denial based on the waived condition.
For a mariner applying for a TWIC, TSA sends a Determination of No Security Threat to the Coast Guard as provided in the regulation. The applicant must still satisfy any remaining enrollment, identity, immigration, credential-issuance, Coast Guard, facility-access, or employment requirements.
A waiver does not:
- Erase or expunge the conviction
- Amend the criminal-history record
- Guarantee employment
- Override an independent Coast Guard licensing problem
- Prevent TSA from considering later adverse information
- Eliminate the need for future TWIC renewals or recurrent vetting
The waiver resolves the covered TSA disqualification for purposes of the credentialing determination.
What Happens If TSA Denies the Waiver?
A waiver denial is not necessarily the end of the administrative process.
Under 49 C.F.R. § 1515.11, an applicant generally has 30 calendar days from the date of service of TSA’s waiver-denial decision to request review by a TSA Administrative Law Judge.
The request for review must clearly identify the issues and include:
- The original waiver request
- All materials submitted to TSA
- TSA’s waiver-denial decision
The applicant may request an in-person hearing, but a hearing is not automatic. The ALJ considers whether the credibility of the evidence and TSA’s compliance with the governing regulations warrant a hearing.
ALJ review is a separate, advanced stage and is not included in NSLF’s $2,495 initial-stage fee unless expressly included in a written engagement agreement.
The Administrative Record Is Generally Closed During ALJ Review
This is one of the most important features of the TWIC waiver process.
Under 49 C.F.R. § 1515.11, the ALJ generally may consider only the evidence and information presented to TSA in the original waiver request.
The applicant may not ordinarily add new evidence to repair an incomplete waiver package during that review. If the applicant has new evidence, the regulation requires a new waiver request, and the pending ALJ proceeding will be dismissed.
That means the initial waiver should include the strongest reasonably available:
- Court records
- Sentence-completion evidence
- Restitution records
- Treatment evidence
- Employment history
- Training records
- Character references
- Personal explanation
- Rehabilitation evidence
- Legal and factual arguments
Waiting to “save” evidence for an appeal can undermine the case.
What Happens After the ALJ Decides?
The ALJ issues a written decision after the record closes. Either party may seek review by the TSA Final Decision Maker within 30 calendar days after service of the ALJ’s decision.
Review by the TSA Final Decision Maker is limited to whether the ALJ’s decision is supported by substantial evidence in the record. The TSA Final Decision Maker’s decision constitutes a final agency order.
A person may seek judicial review of a final order denying a waiver under 49 U.S.C. § 46110.
ALJ proceedings, hearings, Final Decision Maker review, and federal-court litigation require separate legal analysis, engagement terms, and fees.
Do You Need a Lawyer to Submit a TWIC Waiver?
No. Federal law does not require an attorney to submit a TWIC waiver application.
Some applicants can prepare a credible request themselves, particularly when the offense is straightforward, the record is complete, and the applicant has strong, well-organized rehabilitation evidence.
An attorney may be especially valuable when:
- Your job depends on obtaining or keeping the TWIC.
- The offense is classified as permanently disqualifying but waivable.
- You have multiple convictions.
- The conviction involved violence, weapons, drugs, fraud, or serious harm.
- The court records are old or incomplete.
- TSA’s information is partly correct and partly disputed.
- You may need both an appeal and a waiver.
- Restitution or sentence obligations remain unresolved.
- The official records contain aggravating allegations.
- You need to determine what evidence belongs in the package.
- The matter may later require ALJ review.
Hiring counsel does not guarantee TSA approval. It provides legal analysis, record development, strategic evidence selection, professional drafting, and management of a process that may directly affect the applicant’s livelihood.
What Does NSLF Do for a TWIC Waiver?
For qualifying TWIC waiver matters, National Security Law Firm generally:
- Reviews every page of the TSA notice
- Determines whether a waiver is legally available
- Identifies whether an appeal should also be pursued
- Calculates applicable deadlines
- Identifies and obtains necessary court records
- Reviews the charging documents, judgment, sentence, and criminal history
- Identifies aggravating and mitigating information
- Develops a personalized evidence plan
- Assists with treatment, employment, training, and restitution evidence
- Guides the applicant’s selection of character references
- Helps develop and edit the personal statement
- Prepares the legal and factual waiver request
- Organizes and labels the exhibits
- Submits the completed application to TSA
- Tracks the matter through the covered initial stage
- Responds to ordinary TSA requests within the agreed scope
We do not simply provide a form letter and instruct the client to assemble the case alone. Our team manages the records and submission process so the client can remain focused on work and family responsibilities.
National Experience With TWIC Waivers
National Security Law Firm has handled TWIC and HME matters since 2016 and has represented applicants in hundreds of TSA credential cases.
Our publicly reported matters include:
- A TWIC waiver granted for a client convicted of possessing a controlled dangerous substance for sale
- A TWIC waiver application prepared for a client with a conspiracy-to-distribute conviction
- A successful TSA credential matter resulting in TWIC approval
- A TWIC denial overturned for a client facing weapons-related charges
Past results do not guarantee a similar outcome. Every waiver depends on the offense, underlying records, rehabilitation evidence, procedural history, and TSA’s evaluation.
How Much Does TWIC Waiver Representation Cost?
National Security Law Firm charges a flat legal fee of $2,495 for qualifying initial-stage TWIC waiver or appeal representation.
The covered service generally includes:
- Attorney review of the TSA notice
- Waiver-eligibility analysis
- Appeal-versus-waiver analysis
- Procurement of ordinary court records
- Review of the conviction and sentence
- Development of the evidence plan
- Assistance with supporting letters
- Development and editing of the personal statement
- Preparation of the waiver request
- Organization of exhibits
- Submission to TSA
- Tracking through the covered initial administrative stage
- Ordinary TSA follow-up within the agreed scope
The precise scope is governed by the signed engagement agreement.
Unless expressly included, the fee does not cover:
- Unusual third-party expenses
- A separate criminal-record correction proceeding
- Expungement or post-conviction litigation
- A new application based on later evidence
- Administrative Law Judge review
- An administrative hearing
- TSA Final Decision Maker review
- Federal-court litigation
- An unrelated Coast Guard, licensing, employment, or facility-access matter
For additional information, review our guide to TWIC card costs, TSA fees, and lawyer fees.
Financing and the Written Refund Guarantee
Eligible clients may use Pay Later by Affirm to divide the legal fee into monthly payments. Available financing terms are determined by the financing provider.
National Security Law Firm also offers a written refund guarantee in qualifying accepted TWIC waiver matters.
The refund guarantee is not a promise that TSA will grant the waiver, issue a Determination of No Security Threat, or provide a TWIC. TSA controls the government’s decision, and no attorney can ethically guarantee a particular result.
When the guarantee applies, the signed engagement agreement identifies the covered result and the circumstances under which National Security Law Firm will refund the covered $2,495 legal fee if that result is not achieved.
The guarantee:
- Applies only when expressly included in the signed engagement agreement
- Covers only the legal fee identified in that agreement
- Is subject to stated terms, exclusions, and client responsibilities
- Does not control or guarantee TSA’s decision
- Does not necessarily cover third-party expenses or advanced proceedings
We do not accept every matter for guaranteed representation. We review the TSA notice, offense, records, procedural stage, deadlines, and available evidence before deciding whether to accept a case and whether the written refund guarantee will apply.
Frequently Asked Questions About TWIC Waivers
Does TSA grant TWIC waivers?
Yes. TSA has authority to grant waivers when the condition is waivable and TSA determines that the applicant does not pose a security threat. Approval is discretionary and depends on the individual record.
Can a permanent disqualifying offense be waived?
Some can. The permanent offenses listed in 49 C.F.R. § 1572.103(a)(5) through (a)(12) fall within the waiver regulation. The first four permanent categories do not.
Can an interim offense be waived?
Yes. The interim offenses listed in § 1572.103(b) fall within TSA’s waiver authority.
Do I have to admit everything in the police report?
No. A waiver should be candid about established conduct, but the applicant does not have to adopt every disputed allegation in a police report. The statement should distinguish the conviction, admitted conduct, dismissed allegations, and disputed information accurately.
Is completing probation enough to obtain a waiver?
Usually not by itself. Sentence completion is important, but TSA may also consider the circumstances of the offense, restitution, time elapsed, subsequent conduct, treatment, employment, references, and other evidence of present reliability.
How many character letters should I submit?
There is no required number. Quality matters more than quantity. Several detailed letters from credible people with firsthand knowledge are generally more useful than numerous generic letters.
Should I submit a police report?
It depends. A police report may provide context, but it may also contain hearsay, disputed allegations, or information never established in court. It should be reviewed before inclusion.
Can I submit a waiver before TSA issues a Final Determination?
Yes. The regulation permits a waiver request during the application process. An applicant may also pursue some or all of the appeal process first.
How long does TSA take to decide?
The regulation ordinarily provides 60 days after service of the waiver request, but TSA may use a longer period for good cause. Actual processing times vary.
Can I appeal a TWIC waiver denial?
You may request ALJ review under 49 C.F.R. § 1515.11, generally within 30 calendar days after service of the waiver-denial decision.
Can I add new evidence during ALJ review?
Generally, no. The ALJ ordinarily may consider only evidence previously presented to TSA. New evidence normally requires a new waiver request, which results in dismissal of the pending ALJ review.
Does the refund guarantee mean TSA approval is guaranteed?
No. It is a contractual refund commitment applicable only to qualifying accepted cases under the written engagement agreement. It does not promise or control TSA’s decision.
Schedule a Free Consultation About Your TWIC Waiver
A TWIC waiver may be your opportunity to demonstrate that a past offense does not define your present reliability. But a persuasive waiver requires more than a generic apology or collection of certificates.
The application should explain the offense credibly, document sentence completion and restitution, establish rehabilitation, demonstrate professional and personal stability, and create a complete administrative record in case later review becomes necessary.
National Security Law Firm has handled TWIC and HME matters since 2016 and has represented applicants in hundreds of TSA credential cases. For qualifying initial-stage matters, our flat legal fee is $2,495. We obtain ordinary court records, develop the evidence, prepare the waiver, organize the exhibits, and manage the covered TSA process.
Financing may be available, and qualifying accepted cases may include a written refund guarantee subject to the precise terms of the engagement agreement.
Schedule a free consultation or call (202) 600-4996.
Official TWIC Waiver Resources
- TSA: Transportation Worker Identification Credential
- 46 U.S.C. § 70105—Transportation Security Cards and Waivers
- 49 C.F.R. Part 1515—TSA Appeal and Waiver Procedures
- 49 C.F.R. § 1515.5—Appeal of an Initial Determination
- 49 C.F.R. § 1515.7—Waiver Procedures
- 49 C.F.R. § 1515.11—Administrative Law Judge and TSA Final Decision Maker Review
- 49 C.F.R. Part 1572—Credentialing and Security Threat Assessments
- 49 C.F.R. § 1572.103—Disqualifying Criminal Offenses
- 49 C.F.R. § 1572.105—Immigration-Status Standards
- 49 C.F.R. § 1572.109—Mental-Capacity Standards
Author: Katherine O’Brien, Esq., Founder, National Security Law Firm
Attorney Reviewed: August 26, 2026
This page provides general information and is not legal advice. Viewing this page or contacting the firm does not create an attorney-client relationship. Past results do not guarantee future outcomes. Any fee, scope of representation, financing arrangement, or refund guarantee is governed exclusively by a signed written engagement agreement.