What Is a Public Trust Clearance? Tiers and Reciprocity
Public Trust is a suitability or fitness decision for sensitive unclassified work. Tier 2 vs Tier 4, the SF 85P, who starts it, and how reciprocity works.
A Public Trust clearance is a suitability or fitness determination, not a security clearance. It is an agency's decision that you are fit to work in a moderate- or high-risk position with sensitive but unclassified duties, usually based on an SF 85P and a Tier 2 or Tier 4 investigation. It grants no access to classified information.
This is general, factual information for people working in or entering cleared and Public Trust roles. It is not legal, security, career or financial advice. Position risk and sensitivity are designated by the agency, suitability and fitness are decided by the government and its adjudicators, and your hiring organization's security office manages the request. For your own case, your FSO or security office and the official sources at the end are the authority.
Is Public Trust a security clearance?
No. "Public Trust clearance" is recruiter and job-posting shorthand for something the regulations call a position of public trust. Under 5 CFR 731.106, an agency head must designate every covered position, including positions where the work is done by a contractor employee, at a high, moderate or low risk level, based on its "potential for adverse impact to the efficiency or integrity of the service." A position at the high or moderate risk level "is designated as a 'public trust' position." The regulation's examples include policy making, major program responsibility, public safety and health, law enforcement, fiduciary duties, and "access to or control of financial records."
Vetting for one of those positions ends in a suitability determination or a fitness determination. Under 5 CFR 731.101, suitability covers the competitive service, career SES, and excepted-service positions whose incumbents can be noncompetitively converted to the competitive service. Fitness covers other excepted-service employees, contractor employees and nonappropriated fund employees.
5 CFR 731.202 lists ten factors: misconduct or negligence in employment; criminal conduct; a material, intentional false statement, deception or fraud in examination or appointment; dishonest conduct; failure to meet financial or generally applicable civil legal obligations, such as timely filing of tax returns; excessive alcohol use, without evidence of rehabilitation, of a nature and duration that would keep someone from performing the job or threaten the safety or property of others; illegal drug use without evidence of rehabilitation; knowing and willful acts designed to overthrow the U.S. Government by force; violent conduct; and any statutory or regulatory bar to employment. The agency must also weigh the additional considerations it finds pertinent, including the nature of the position, the seriousness, circumstances and recency of the conduct, and rehabilitation, so the decision turns on the case and not on the bare presence of a listed issue.
For excepted-service fitness, the agency must apply the 731.202 factors as a minimum and may add job-related ones. For contractor employees, 731.101(c) says the agency exercises "due regard" to Part 731 and OPM's supplemental guidance, and E.O. 13488 section 3(a), as amended, leaves the adjudicative criteria to the agency head.
A security clearance is a different decision on a different track: eligibility for access to classified information, adjudicated against the 13 SEAD 4 guidelines. Executive Order 13526 defines three classification levels, Top Secret, Secret and Confidential. Public Trust is not one of them.
| Public Trust | Secret | Top Secret | |
|---|---|---|---|
| What it decides | Suitability or fitness for a moderate- or high-risk position | Eligibility for access to Secret information | Eligibility for access to Top Secret information |
| Classified access | None | Up to Secret, with need-to-know and an SF 312 | Up to Top Secret, with need-to-know; SCI is a separate access decision |
| Typical investigation | Tier 2 (moderate risk) or Tier 4 (high risk) | Tier 3 | Tier 5 |
| Questionnaire | SF 85P | SF 86 | SF 86 |
| Standard applied | 5 CFR 731 suitability factors; agency fitness criteria for contractors under E.O. 13488 | SEAD 4 adjudicative guidelines | SEAD 4 adjudicative guidelines |
| Who decides | The employing or contracting agency; OPM keeps certain suitability cases | A national-security adjudicator for the sponsoring agency | A national-security adjudicator for the sponsoring agency |
For the full ladder of levels, see the US security clearance ladder. For how SCI sits on top of Top Secret, see TS/SCI, decoded.
What are the Public Trust tiers?
The tier numbers come from the December 2012 Federal Investigative Standards, which OPM's Position Designation Tool page notes also apply to investigations for contractor employee fitness. DCSA's case types and forms chart maps each position designation to an investigation and a form:
| Tier | Position designation | Form | Reinvestigation type | Legacy name | Track |
|---|---|---|---|---|---|
| Tier 1 | Non-sensitive, low risk | SF 85 | No reinvestigation requirement | NACI | Suitability and credentialing; not Public Trust |
| Tier 2 | Non-sensitive, moderate risk | SF 85P | T2R | MBI | Public Trust |
| Tier 4 | Non-sensitive, high risk | SF 85P | T4R | BI | Public Trust |
| Tier 3 | Noncritical-sensitive, moderate risk | SF 86 | T3R | NACLC / ANACI | National security |
| Tier 5 | Critical- or special-sensitive | SF 86 | Set by national-security policy | SSBI | National security |
Tier 1 sits outside Public Trust because 731.106(b) reserves the label for high and moderate risk. The numbering interleaves two tracks, so a Tier 4 is not "above" Secret in any access sense; our explainer on investigation tiers vs. clearance levels walks through why.
Agencies set the designation with the Position Designation System and its automated tool. OPM describes a four-step process that looks at a position's duties for two separate things: risk to the efficiency or integrity of the service, which sets the Public Trust level, and potential harm to national security, which sets sensitivity. 731.106(c)(2) requires every risk-designated position to carry a sensitivity designation too (Special-Sensitive, Critical-Sensitive, Noncritical-Sensitive or Non-sensitive). Per OPM, a critical- or special-sensitive designation "automatically confers high-risk public trust designation," and a noncritical-sensitive designation confers moderate risk unless the duties require higher. For covered positions, a Secret-level job is therefore also a Public Trust position, and the combined designation is what decides which investigation it gets; that is why it is vetted on the SF 86 rather than the SF 85P.
OPM proposed a consolidated Personnel Vetting Questionnaire in a 2022 Federal Register notice; that proposal alone does not establish which questionnaire your agency currently uses. Follow your security office's instructions.
How do you get a Public Trust clearance?
You can't apply for one on your own. The position triggers it, and the hiring agency, or for contractors the agency the contract supports, decides it. For a new hire, the sequence generally runs like this:
- The agency designates the position's risk and sensitivity. Under Executive Order 13488 as amended by E.O. 13764, contractor fitness "is subject to the same position designation requirements and investigative standards, policies, and procedures" as civil service fitness.
- You get a conditional offer. Federal hiring rules in 5 CFR 731.106(g) generally bar specified criminal-history inquiries before a conditional offer (with an exception for certain excepted positions) and, for competitive service jobs, credit inquiries before that point unless the agency has an approved exception.
- The security office tells you which questionnaire to complete and in which system. For a non-sensitive moderate- or high-risk position that is the SF 85P; DCSA collects its questionnaires through NBIS eApp. A position that also carries a sensitivity designation goes on the SF 86 instead.
- You submit fingerprints on the SF 87.
- An authorized investigative service provider, such as DCSA, runs the investigation.
- The agency adjudicates. For contractors, E.O. 13488 section 3(a), as amended, leaves adjudicative criteria to the agency head, "with due regard" to OPM guidance.
- People in covered positions are subject to continuous-vetting requirements. Enrollment and implementation follow agency instructions, and continuous vetting requires a signed authorization for release of information under 731.106(d). Confirm your enrollment with the security office.
Current employees can be vetted too. Under 731.106(e), when a position's risk level is raised or an employee moves into a higher-risk position, the upgraded investigation should be initiated within 14 days. If you're coming in with no prior federal vetting, the sponsorship path explains how employers start the process for new hires.
How long does a Public Trust investigation take, and how long does it last?
Timing depends on the case and on which clock you mean. There are three. The investigation itself runs at DCSA or another provider, and its length moves with scope (the tier sets how much is checked), issues that need resolving, and errors or gaps on the form. Adjudication is the agency's own step after the file closes. Entry on duty depends on whether the agency or contract lets you start on a preliminary determination. The government-wide Trusted Workforce 2.0 quarterly progress reports track end-to-end timeliness and state that investigations are the longest phase within personnel vetting. Ask your security office for a case-specific estimate.
As for duration, a Public Trust determination has no printed expiration date. Under 731.106(d), people in positions subject to investigation are "subject to continuous vetting through periodic checks of their background at any time," and continuous vetting for a public trust position "satisfies the requirement for a periodic reinvestigation" set by E.O. 13488.
The determination is tied to employment in a designated position. Leave that work and what happens next depends on the break-in-service rules below. For the national-security side of the same question, see how long a security clearance lasts.
Does a Public Trust determination transfer to a new job or agency?
Often, yes. Agencies must accept qualifying prior investigations and favorable determinations under the reciprocity rules, subject to the exceptions below. Google's AI Overview for this search tells readers that Public Trust determinations are not transferable between employers through reciprocity, and it cites neither 5 CFR 731.104 nor E.O. 13488 section 3(c), the two rules that settle the question.
5 CFR 731.104 sets the rules for federal employment:
- An agency "must reciprocally accept a prior background investigation" on promotion, demotion, reassignment or transfer without a break in service, unless the new position is at a higher risk level.
- After a qualifying break in service (the length is set in OPM's supplemental guidance), an agency must accept a prior investigation that is at or above the level the new position requires, unless it obtains new information that calls your suitability or fitness into question. It must also run the checks the guidance specifies and enroll you in continuous vetting.
- If the prior investigation was favorably adjudicated, the agency "must accept the prior determination" unless your record shows conduct incompatible with the new position's core duties, or the agency has added fitness factors that the earlier adjudication didn't address. In that second case it adjudicates only those added factors.
- If the Central Verification System record shows no prior favorable determination, the agency reviews the prior investigation and makes one.
Contractors are covered too. E.O. 13764 rewrote section 3 of E.O. 13488 so that section 3(c) reads: "Fitness determinations and investigations for fitness determinations for contractor employees and for nonappropriated fund employees are subject to the same reciprocity requirements as those for employment in the civil service." The same order struck the original section 4, the 2009 reciprocity clause with its own exception list, so the current rules are the ones in Part 731.
In practice, moving from a Tier 2 task order at one agency to another Tier 2 role, with no break and no new issues, should mean acceptance rather than a new investigation. Moving from Tier 2 to a Tier 4 position doesn't: that's a higher risk level, and the upgraded investigation falls under 731.106(e).
Where are Public Trust jobs in the GovCon market?
In ClearMatch's scan of 119,737 ATS postings from 1,172 employer career sites, Sep 30 to Oct 14, 2026, 4,786 postings required Public Trust. In the same window, 57,491 postings required Secret or higher, with Secret at 53.2% of that group, TS at 15.5% and TS/SCI at 15.8%.
The employers posting the most Public Trust roles in that window:
By region, 1,818 of those Public Trust postings (38%) were in DC Metro, 648 (13.5%) were tagged remote-eligible, and 1,989 (41.6%) were tagged "Other," outside the named metro regions ClearMatch breaks out. Browse remote cleared roles to see the current set.
What should you confirm when a posting says "Public Trust required"?
These questions pin the requirement down with the recruiter or security office:
| Posting phrase | What it usually signals | What to ask |
|---|---|---|
| "Public Trust required" | Moderate or high risk; tier not stated | Is the position designated moderate (Tier 2) or high (Tier 4) risk, and which agency adjudicates? |
| "MBI" or "Moderate Risk Public Trust" | Tier 2, SF 85P | Will a current favorable determination at this level be accepted? |
| "BI" or "High Risk Public Trust" | Tier 4, SF 85P | If my prior investigation is Tier 2, when will the Tier 4 be initiated? |
| "Active Public Trust" | They want someone already vetted | Does the agency apply added fitness factors, and will it check the Central Verification System? |
| "Must be able to obtain Public Trust" | They will start the process after a conditional offer | Which questionnaire and system will I use, and can I start work before the determination? |
| "Public Trust; Secret preferred" | Possible national-security sensitivity too | What are the position's risk and sensitivity designations, and which questionnaire and investigation do they require? |
Frequently asked questions
How do I apply for a Public Trust security clearance?
You can't apply directly. The vetting is triggered by a position an agency has designated moderate or high risk: for a new hire, after a conditional offer, and for a current employee, when the position's risk level is raised or the person moves into a higher-risk role. The security office then tells you which questionnaire to complete, usually the SF 85P for a non-sensitive Public Trust position, and the agency makes the suitability or fitness determination when the investigation is done.
How hard is it to get a Public Trust clearance?
No official source cited here publishes an approval rate. For suitability and excepted-service fitness, the agency weighs the investigation against the ten factors in 5 CFR 731.202, such as criminal conduct, dishonesty, illegal drug use without evidence of rehabilitation and unmet financial obligations, along with the nature of the position, the seriousness and recency of the conduct, and rehabilitation. For contractor employees, the agency head sets fitness criteria with due regard to Part 731 and OPM guidance.
What are the four types of security clearance?
Executive Order 13526 defines three classification levels: Top Secret, Secret and Confidential. Lists of "four" usually add Public Trust, which is a suitability or fitness determination, or count SCI, which is an access control layered on Top Secret. Neither is a separate clearance level.
Is Public Trust higher or lower than Secret?
Neither; they sit on different tracks. Public Trust measures risk to the integrity or efficiency of the service and grants no classified access, while Secret is eligibility for classified information. OPM's position designation guidance makes a noncritical-sensitive (Secret-level) position at least moderate-risk Public Trust as well.
Does a Public Trust clearance expire?
There's no fixed expiration date. Under 5 CFR 731.106(d), people in Public Trust positions are subject to continuous vetting, which satisfies the periodic reinvestigation requirement. After a break in service, reuse of the prior investigation depends on the qualifying break-in-service rules in 5 CFR 731.104.
Can a Public Trust determination be upgraded to a Secret clearance?
Not by itself. Secret eligibility requires a national-security adjudication under SEAD 4 and a position with a national-security sensitivity designation. The combined risk and sensitivity designation, plus any prior investigation that can be reused, determines what additional investigation is needed; for the typical moderate-risk, noncritical-sensitive position, DCSA's chart lists a Tier 3 on the SF 86. Your security office decides what applies when your position's designation changes.
What this looks like inside ClearMatch
// PUBLIC TRUST IN THE SCAN
ClearMatch tracks Public Trust postings separately from Secret-and-above, which is how the 4,786 count above was built from the Sep 30 to Oct 14, 2026 scan.
Browse cleared and Public Trust roles by the requirement each posting states, or run a posting through the job fit check before you ask the recruiter which tier it is.
Sources: 5 CFR Part 731, Suitability and Fitness, 5 CFR 731.101, Definitions and purpose, 5 CFR 731.104, Investigation and reciprocity requirements, 5 CFR 731.106, Designation of public trust positions, 5 CFR 731.202, Criteria for suitability and fitness determinations, OPM Position Designation Tool, OPM Suitability Adjudications, DCSA Case Types and Forms, Executive Order 13488, Federal Register, Executive Order 13764, Federal Register, Personnel Vetting Questionnaire notice, Federal Register, Trusted Workforce 2.0 at performance.gov, Executive Order 13526. Suitability, fitness and reciprocity policy is set by the federal government and changes over time; confirm your own case with your FSO, security office or the official sources above.