S. 1196 — Special Government Employees Transparency Act of 2025

This section defines special government employees (SGEs) as temporary executive branch personnel qualifying under 18 U.S.C. §202(a) or other federal law and limits their service to 130 days during any 365 consecutive days, regardless of consecutiveness, after which SGE status ceases. (As background, SGEs are typically experts or advisers hired for limited periods and exempt from certain ethics and financial disclosure requirements applicable to full-time federal employees.) If the limit is exceeded, the employing authority must within 30 days (1) determine the individual's appropriate civil service classification and position; (2) apply relevant federal personnel rules consistent with those duties; and (3) provide written notice of the classification and appeal rights, after which the individual is subject to all laws governing that position. Days count toward the 130-day limit for (1) any day with more than one hour of purely administrative SGE service (e.g., confirming a meeting by phone or filing paperwork); (2) any day with non-administrative SGE service (e.g., reading official materials or preparing for a meeting), regardless of duration; or (3) any day compensated for SGE service.

This section defines a "covered special Government employee" as a special Government employee (as defined in 18 U.S.C. §202(a)) whose duties are comparable to GS-11 level or above, who is not serving on an advisory committee (excluding specified Department of Government Efficiency entities), and who is not appointed to a civil service position fillable only by full-time students at an institution of higher education (as defined in 20 U.S.C. §1002). It 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, for each covered special Government employee, the name, position title, basic pay rate, employing executive agency and organizational component, appointment date, and termination date (if applicable); requires the database to be freely available on OPM's website with API access and full accessibility compliance. It further requires executive agency heads to notify OPM of relevant personnel actions within 30 days, periodically review agency data in the database for currency, and authorizes OPM to audit submissions, with OPM required to report to specified congressional parties within three years on implementation efforts and data accuracy. Finally, it requires executive agencies to publicly release, using specified procedures, any financial disclosure reports filed after enactment by covered special Government employees (notwithstanding 5 U.S.C. §13109), except for reports filed by certain individuals, non-covered special Government employees, or those containing national defense information.