Guidance re Implementation of Executive Orders 14,251 & 14,343

On February 11, 2026, the Office of Personnel Management (OPM) issued guidance on Executive Orders 14,251 and 14,343, in which President Trump sought to terminate union representation for many federal employees, primarily citing to national security concerns. At the time that OPM issued this guidance, multiple court orders blocked at least parts of the implementation of these Executive Orders. However, OPM gave the following instruction in the original version of the guidance memo: "For various reasons, including litigation, implementation of these Executive Orders at certain agencies and agency subdivisions has been delayed. The U.S. Office of Personnel Management (OPM) now advises agencies and agency subdivisions covered by E.O. 14251 and E.O. 14343 that they should proceed to terminate or modify CBAs [(Collective Bargaining Agreements)] in order to fully comply with those Executive Orders . . . " After one union notified the court of the original memorandum, OPM modified the memo to add the following language: "This guidance does not apply to bargaining units where there is a currently-applicable court order preventing implementation of the executive orders with respect to those units." Where the memo and its attached guidance documents apply, agencies are instructed to terminate or modify CBAs, reclaim office space and equipment previously used by union representatives, stop approving union time during the work day, deny union requests for information, and take other steps to cease recognizing or supporting collective organizing.