What is “titling” and “indexing,” how it happens, and what it means to you

When members of the military are the subject of an investigation by a service‑law‑enforcement agency—such as the U.S. Army Criminal Investigation Command (CID), the Naval Criminal Investigative Service (NCIS), the U.S. Air Force Office of Special Investigations (OSI), or other DoD entities, even a Command Investigation or Preliminary Inquiry—they may be “titled” and “indexed". This means the mere fact they were the subject of an investigation, regardless of the outcome, can result in an arrest being entered in to their record by the FBI. The unfortunate nature of military service is that many personnel may be subject of an investigation throughout their careers.  The fact of the matter is with the Marine Corps Prohibited Activities Order, Command Investigations, Preliminary Inquiries, the role of Convening Authorities, and even now, with the invent of the Office of Special Trial Counsel, many decision makers basically say “do an investigation and we’ll let things figure it out.”

So before we go any further, let’s define some key terms.

• Titling: The service investigator designates the individual as the “subject” of a criminal investigation. Under DoD policy, when there is “credible information” that the subject may have committed an offense, the investigator will begin the process of titling.   Credible information is a very, very low standard- it is below probable cause (which is required for a civilian arrest) and a naked allegation is sufficient to be deemed as “credible.”

• Indexing: Once titled, the individual’s name and identifying information are entered into the military’s investigative index (the Defense Central Index of Investigations or DCII) and may be transmitted to the FBI’s NCIC / Interstate Identification Index (III) for inclusion in criminal‑history/justice‑information systems.

  
  

In civilian law enforcement, entries to NCIC or the III are typically made only after an arrest, charge, or some adjudication. But the military standard is significantly lower: the entry may be made after an investigation begins or even before formal charges, based only on “credible information” of an offense. That means you don’t have to be NJP'ed, AdSep'ed, convicted at a court-martial, to be “titled” or “indexed.”  And unlike a civilian arrest, the standard is so low, and a member of the military may simply know there was an investigation and nothing happened but only later that they have been “titled” and “indexed.”

Because of these processes:

• A service member may be investigated (even informally), never arrested, never charged, never court‑martialed—and yet still end up with a criminal‑justice‑type record in NCIC / DCII.

• That record may appear later on background checks used by civilian employers, security‑clearance reviewers, licensing boards, etc., sometimes showing an “arrest” or “pending criminal history” even when none occurred.

  
  

This major difference creates serious and lasting consequences for service members and veterans like background checks, security clearances, job offers and VA claims.

Why this matters for veterans and servicemembers

The implications are broad:

• Employment: Many civilian employers, especially federal or state government jobs, contracting, or security‑clearance jobs, rely on criminal‑history checks that draw from NCIC/III. A titled entry can raise red flags and a person going through the process of getting hired may never know why they didn’t get a job they otherwise were qualified for.

• Security Clearances & Background Investigations: Being titled can affect clearance eligibility, reinvestigations, promotions, change in duties, or contract eligibility.

• Reputation & Career Progression: Even absent discipline, forget about a court-martial, not even a NJP or administrative entry, the mere notation of an investigation or “subject of criminal investigation” may harm promotion boards, reenlistment, assignment selection, or civilian transition.

• Personal Impact: Some veterans have said the titled entry lingered for years, blocking volunteering, civilian employment, home renting, and many other issues.

  
  

Because the standard for titling is comparatively low—and the remedies limited even if you know about the titling—many veterans and current service members find themselves burdened with inaccurate or misleading records that can only be fixed through serious efforts.

Legal and policy basis for correction

There are a number of laws and regulations that govern the correction of titling and indexing, specifically:

• 10 U.S.C. § 1552 (Correction of military records) empowers the Secretaries of the military departments to correct, remove or expunge certain records (including titling/indexing entries) when appropriate. This is similar to a BCMR and BCNR request.

• By October 1, 2025 the Secretary of Defense was supposed to create a system through which a person whose name has been placed in DCII or similar databases may request correction, expungement or removal under defined circumstances ( if probable cause did not exist).  However, this process is so new many wrinkles are still being figured out.

• The governing policy for military titling is DoD Instruction 5505.07 (“Titling and Indexing in Criminal Investigations”). This sets the criteria for when investigations are titled/indexed.

  
  

So, while the process is compl

ex and not automatic, there is a legal basis for service members and veterans to seek correction of titled/indexed records.  Rights to Records is here to help.

For veterans and former service members who discover titled/indexed entries in NCIC or the military’s investigative indices—even when no formal charges or punishment occurred—there is a pathway to correction. The key is: confirming the existence of the record, gathering documentation, requesting correction through the appropriate military investigative agency (and if needed, the correction board), and following up until the NCIC/III entry is amended or removed.  Rights to Records has extensive backgrounds in requesting and amending records.

While the process can be complex and time‑consuming, the stakes are significant: employment opportunities, security clearances, licensing, reputation and more can hinge on what appears in that database.  Rights to Records is here for you.