Quick Answer: What This Section Does
§ 147.31 explains when the government may grant temporary eligibility (interim clearance) for:
- Top Secret access
- Sensitive Compartmented Information (SCI) pathways
- “Q” access authorizations
👉 This applies when a person has a favorable investigation—but not one that fully meets Top Secret standards
In practice, this section answers:
“Can I get interim Top Secret clearance before my full investigation is complete?”
What This Means in Practice
Most applicants assume:
👉 Top Secret access requires a fully completed investigation before any access is granted
That is not always true.
This section allows temporary eligibility when:
- a prior or partial investigation exists
- initial review is favorable
- the agency has a justified need for access
However:
👉 the investigation does not yet meet full Top Secret standards
Adjudicators are not asking:
👉 “Is this person fully cleared for Top Secret?”
They are asking:
👉 “Is there enough information to allow temporary access while we complete the full investigation?”
That distinction matters.
How Interim Top Secret Decisions Are Actually Made
Temporary Top Secret eligibility is based on:
- the existing investigative record
- the absence of immediate risk indicators
- early adjudicative review
But unlike Secret-level interim clearances:
👉 the threshold is higher
👉 the tolerance for risk is lower
This is why many applicants do not receive interim Top Secret access, as explained in how interim security clearances work and why higher-level requests are more likely to be delayed or denied.
Full Text of § 147.31
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, and expedited submission of a request for a Single Scope Background Investigation (SSBI).
Why This Matters for Your Case
This section reflects a critical principle:
👉 Top Secret interim access is based on incomplete—but favorable—information
Two applicants may have similar records:
- one receives interim access
- one does not
Because:
👉 one record raises early questions
This is why early-stage issues matter so much, as explained in what an interim clearance denial actually means and how it signals deeper concerns in your case.
Where Interim Top Secret Cases Go Wrong
Most issues arise when:
- the existing investigation contains gaps
- disclosures raise unresolved concerns
- prior conduct requires deeper review
- financial, criminal, or foreign issues are present
- inconsistencies exist across records
From the applicant’s perspective:
👉 “They haven’t even finished the investigation yet”
From the system’s perspective:
👉 “There is already enough information to delay access”
How This Section Connects to the Investigation
This provision triggers:
👉 a full Single Scope Background Investigation (SSBI)
That investigation is significantly more detailed, as explained in what a Top Secret SSBI background investigation actually involves and how it differs from lower-level clearances.
During this process:
- additional issues may be identified
- the investigation may expand
- temporary access may be revoked
How This Section Fits Into the Clearance Process
This rule operates at the early stage of the security clearance process from application through adjudication.
It directly affects:
- access to Top Secret roles
- assignment to sensitive programs
- early career movement into higher clearance levels
Those early decisions often predict outcomes under the security clearance adjudication process and how risk is evaluated at higher levels.
How This Section Interacts With Other Rules
This section works alongside:
- §147.30 (Secret-level interim access)
- §147.32 (Top Secret access without a prior investigation)
- investigation standards (Standard B – SSBI)
Together, these determine:
👉 whether Top Secret access can be granted early
👉 how risk is evaluated before full adjudication
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.
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.
Security Clearance Denied or Revoked
If your security clearance has been denied, suspended, or revoked, it is critical to act early.
You can better understand your options by reviewing what happens after a security clearance denial and how appeals, reinstatement, and reapplication are evaluated.
Speak With a Security Clearance Lawyer Before Interim Decisions Limit Your Case
The most important question is not:
👉 “Will I get interim Top Secret clearance?”
It is:
👉 “What does my record show before the full investigation is complete?”
The Record Controls the Case.
SECURITY CLEARANCE DENIED OR REVOKED
If you are appealing a security clearance determination, it is imperative that you obtain experienced legal representation. Doing so will provide you with the best opportunity to obtain or maintain your clearance.
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