OGE Ethics Guidance on Financial Disclosure Filing Extensions for Schedule Policy/Career Employees

The Office of Government Ethics (OGE) issued a statement indicating that it was working to exempt Schedule Policy/Career employees from financial disclosure requirements, and the statement urged ethics officials in federal agencies to grant extenstions of filing deadlines to Schedule Policy/Career employees so that they would not have to file their disclosures before OGE issued the exemption. On June 3, 2026, Trump designated the positions of approximately 8,000 employees as Schedule Policy/Career.

Financial dislcosure requirements applied to Schedule Policy/Career employees because the Trump administration designated their positions as confidential or policymaking positions. Under the Ethics in Government Act, all executive branch employees in positions designated as confidential or policymaking must file public confidential financial disclosure reports. Employees moved into Schedule Policy/Career who were not already public financial disclosure filers would therefore have been required to file New Entrant Public Financial Disclosure Reports within 30 days of reclassification, and Periodic Transaction Reports for any subsequent reportable financial transactions. However, the law authorizes OGE's Director to exempt any individual or group of individuals in these types of positions, "but only in cases in which the Director determines such exclusion would not affect adversely the integrity of the Government or the public's confidence in the integrity of the Government." This guidance document anticipated that OGE would exempt Schedule Policy/Career employees from the reporting requirements but had not done so yet.