H.R. 2455 — Special Government Employees Transparency Act of 2025

This section establishes a limit on special government employee (SGE) service in the executive branch of 130 days during any 365 consecutive days, after which the individual ceases to qualify as an SGE. (As background, SGEs under 18 U.S.C. § 202(a) are temporary or intermittent appointees, such as experts or consultants, who are exempt from certain ethics and financial disclosure requirements applicable to full-time federal employees.) If the 130-day threshold is exceeded, the employing authority must, not later than 30 days after cessation of SGE status, (1) determine the individual's appropriate civil service classification and position, (2) apply the relevant federal personnel framework consistent with the position's duties, and (3) provide written notice of the determination and applicable appeal rights; the individual then becomes subject to all laws, obligations, and rights applicable to that position. For counting days toward the limit, each full day of service counts if the individual (1) performs more than 1 hour of purely administrative tasks (e.g., confirming a meeting date or filing personnel paperwork), (2) performs any non-administrative service (e.g., reading official materials or preparing for a meeting) regardless of duration, or (3) receives government compensation for SGE service.

This section establishes transparency requirements for covered special government employees (SGEs)—defined as SGEs (i.e., individuals serving no more than 130 days in any 365-day period under 18 U.S.C. §202(a)) who are not on advisory committees (excluding Department of Government Efficiency entities), have duties comparable to GS-11 level or above, and are not in student civil service positions at institutions of higher education (per 20 U.S.C. §1002)—across executive agencies (including the Executive Office of the President). Specifically, it (1) directs the Director of the Office of Personnel Management (OPM), in consultation with the Office of Government Ethics, to establish a searchable, sortable, publicly accessible SGE Database within 210 days of enactment containing each covered SGE's name, position title, pay rate, employing agency and component, appointment date, and termination date (if applicable), with agencies required to report personnel actions within 30 days and periodically verify data accuracy; (2) requires OPM to audit agency compliance and report to specified congressional leaders within three years on database implementation and data quality; and (3) mandates public availability of financial disclosure reports filed by covered SGEs after enactment (using 5 U.S.C. §13107 procedures and overriding §13109 confidentiality), excluding reports with national defense information, those filed by certain high-level officials or non-covered SGEs, or student appointees.