I Why the requirement exists
Financial disclosure reports are the primary tool agency ethics officials use to determine whether employees in covered positions are complying with the conflict-of-interest and standards-of-conduct provisions that apply to them.
The logic is preventive rather than punitive. An ethics official reviewing your report is looking for holdings or arrangements that could create a real or apparent conflict with your official duties, so that the conflict can be addressed — through recusal, divestiture, a waiver, or a change in assignment — before it becomes a problem. Most reports are reviewed, certified, and never mentioned again.
One framing worth internalizing: compliance with financial disclosure requirements is a condition of employment for employees required to file. It is not an administrative courtesy, and agencies treat it accordingly.
The system is designed to surface conflicts, not to catch you — which is why an early conversation with your ethics official about an uncertain holding is almost always cheaper than a late correction to a filed report.
II Who files which form
Your position determines your form. You do not choose, and grade alone does not settle it.
| OGE Form 278e (public) | OGE Form 450 (confidential) | |
|---|---|---|
| Who files | PAS appointees, SES, Senior Level (SL), Scientific & Professional (ST), Schedule C, certain SGEs and IPA detailees | Employees in positions designated by their agency under 5 CFR 2634.904, certain SGEs and IPA employees not filing a 278e |
| Typical grade | Senior level and above | Generally GS-15 and below |
| Public availability | Available to the public upon request | Not public — internal ethics review only |
| Detail required | Extensive | Shorter, less detail |
| Annual deadline | May 15 | February 15 |
| Periodic transaction reports | Required (OGE 278-T) | Not required |
Confidential filer designations attach to positions involving significant discretion in sensitive areas — contracting, procurement, grant administration, regulatory decisions, and similar functions. That is why two GS-14s in the same agency can have different obligations: the designation follows the duties, not the grade.
Some criteria also reach employees whose basic pay exceeds a threshold tied to the GS-15 minimum. If you have moved into a new position, been promoted, or had your duties change, do not assume your filing status stayed the same — ask.
III The four report types
Both forms are used for multiple report types, which is a frequent source of confusion.
| Report type | When | Applies to |
|---|---|---|
| New entrant | Generally within 30 days of assuming a covered position | Both forms |
| Annual | May 15 (278e) · February 15 (450) | Both forms |
| Termination | Within 30 days of leaving a covered position | Public filers |
| Periodic transaction (278-T) | Rolling — see the STOCK Act section | Public filers only |
Two wrinkles worth knowing. Public filer candidates frequently must be cleared before entering on duty, which in practice means submitting a draft new entrant report well before your start date rather than within 30 days after it. And an annual report is generally required if you remained in a covered position for more than 60 days during the year — so a short stint in a covered role may or may not trigger one.
IV Deadlines, in one place
| Obligation | Deadline |
|---|---|
| Annual OGE Form 278e | May 15 |
| Annual OGE Form 450 | February 15 |
| New entrant, either form | Generally 30 days after assuming the position |
| Termination report (public filers) | Within 30 days of leaving the covered position |
| Periodic transaction report (278-T) | 30 days after notification, never later than 45 days after the transaction |
| Extension request | Up to 90 days, but must be requested before the due date |
| Late fee trigger | More than 30 days past the deadline including extensions |
Agencies routinely set internal deadlines ahead of the statutory dates so that ethics officials have review time, and many distribute annual notifications through an electronic filing system in January. Confirm your agency's actual date with your ethics office rather than working backward from May 15 or February 15 — the internal date is the one that governs your notification and, in practice, your reminders.
V What actually has to be reported
The public OGE Form 278e requires detailed disclosure of financial interests for you, your spouse, and your dependent children. That scope catches people — a spouse's brokerage account is generally in scope even though it is not yours.
The general reporting threshold for assets held for investment or the production of income:
- Value exceeded $1,000 at the end of the reporting period, or
- The asset generated more than $200 in income during the reporting period.
Either condition triggers reporting; both do not have to be met. Beyond assets, the public form covers positions held outside the government, agreements and arrangements, sources of compensation, transactions, liabilities, and gifts and travel reimbursements.
Values are reported in ranges rather than exact figures, which surprises first-time filers who expect to disclose precise balances. The confidential OGE Form 450 is shorter and requires less detail, though the underlying conflict-of-interest logic is the same.
Diversified mutual funds and similar widely held investment vehicles are treated differently from individual holdings, and certain retirement accounts have their own treatment. The rules here are genuinely technical, they are set out in OGE's Public Financial Disclosure Guide, and guessing produces omissions. If you are unsure whether something is reportable, ask your ethics official — that question is exactly what they are there for.
VI Filing Requirement Navigator
Select your filer type and situation. The tool returns which reports apply to you, the deadlines that govern them, and the obligations most commonly missed in your category.
What do you owe, and when?
General guidance. Your agency ethics office determines your filer status and may set earlier internal deadlines.
The Filing Calendar — Deadlines Across a Year
Days from January 1 to each recurring annual deadline, with the rolling STOCK Act periodic transaction window shown as its outer 45-day limit. Confidential filers face the earlier annual date; public filers carry the additional rolling obligation that has no fixed calendar position.
VII The STOCK Act periodic transaction report
This is the obligation public filers miss most often, because unlike everything else on this page it has no fixed calendar date. It is triggered by a transaction.
Public filers must report covered transactions in stocks, bonds, and other securities exceeding $1,000 by the filer, spouse, or dependent child, using OGE Form 278-T. The deadline is:
- No later than 30 days after you receive notification of the transaction, and
- In no case later than 45 days after the transaction occurred.
Both conditions apply. The 45-day outer limit governs regardless of when you learned about the trade, which matters when a spouse trades independently or a managed account transacts without your involvement.
A spouse's account trades, the filer does not learn of it for weeks, and by the time the statement arrives the 45-day clock has nearly run. If anyone in your household trades individual securities, set up notification arrangements that reach you promptly — the outer limit does not wait for your quarterly statement. Late 278-T filings carry the same $200 fee as a late annual report.
VIII Extensions
Filers may generally request an extension of up to 90 days from the appropriate ethics official where good cause is shown.
One condition controls everything: the request must be made before the original due date. An extension sought after the deadline has passed does not cure the lateness, and the late fee clock has already started.
The practical implication is to treat the extension as a planning tool rather than a remedy. If you know that gathering valuations, retrieving statements from a former employer's plan, or resolving a spouse's account documentation will take longer than the window allows, request the extension early. Ethics officials generally handle these routinely; what they cannot do is reach backward.
IX Late fees, discipline, and criminal exposure
Three distinct consequences sit behind these forms, and they escalate sharply.
The $200 late filing fee. An employee required to file an OGE Form 278e or a periodic transaction report who files more than 30 days after the statutory deadline, including any granted extension, is subject to a $200 fee. Agencies describe this as a statutory requirement they must enforce — it is not a discretionary penalty and it is generally not waived for ordinary busyness.
Disciplinary action. Compliance is a condition of employment for those required to file. Employees who fail to file in a timely manner may be subject to disciplinary action up to and including removal from government service. Failure to provide requested information may result in separation.
Civil and criminal exposure. An employee who willfully falsifies information, willfully omits required information, or willfully fails to file may be subject to civil penalties and to criminal prosecution by the Department of Justice.
Willfully. An inadvertent omission, discovered and corrected promptly through your ethics official, is a materially different matter from a knowing misstatement. If you realize after filing that something was missed or misreported, raising it and amending is generally the appropriate course — and promptness is part of what distinguishes the two categories. Waiting and hoping is the choice that converts an administrative correction into something else.
X The mistakes that cause the most trouble
| Mistake | Why it happens |
|---|---|
| Missing a periodic transaction report | No calendar date triggers it — only a trade does, and often someone else's |
| Forgetting spouse and dependent child holdings | The scope reaches beyond your own accounts |
| Requesting an extension after the deadline | The request must precede the due date to have any effect |
| Assuming filer status did not change | The designation follows duties — a promotion or reassignment can change it |
| Reporting exact values instead of ranges | The forms use ranges; exact figures are not what is asked for |
| Guessing at whether a fund is reportable | Diversified funds and retirement accounts have technical treatment |
| Missing a termination report | Due within 30 days of leaving, when your attention is elsewhere |
| Working from the statutory date | Your agency's internal deadline is usually earlier |
XI What happens after you file
An ethics official reviews your report against your official duties, looking for real or apparent conflicts. Most reports are certified without further action.
Where a potential conflict surfaces, the usual remedies are proportionate and negotiated rather than punitive:
- Recusal from particular matters — the most common outcome by a wide margin.
- Divestiture of a holding, sometimes with a certificate of divestiture providing favorable tax treatment.
- A waiver, where the interest is too remote to affect your integrity in the matter.
- Reassignment of specific duties.
Reaching one of these outcomes is the system working as designed. The failure mode is not having a reportable holding — it is having one, not disclosing it, and then participating in a matter it touches. The broader conflict-of-interest and standards-of-conduct framework is covered in Topic 39, and outside employment questions in Topic 42.
XII The playbook
| Situation | What to do |
|---|---|
| You do not know if you are a filer | Ask your agency ethics office. The designation follows your duties, not your grade. |
| Public filer, household trades securities | Set up notifications that reach you fast. The 45-day outer limit does not wait for statements. |
| Deadline is approaching and data is missing | Request an extension before the due date. Afterward it does nothing. |
| Recently promoted or reassigned | Confirm whether your filing obligation changed. Do not assume. |
| Unsure whether a holding is reportable | Ask the ethics official. That question is what they exist for. |
| You filed and then found an error | Raise it and amend promptly. Willfulness is the dividing line. |
| Leaving a covered position | Public filers owe a termination report within 30 days. Calendar it now. |
| You are already past the deadline | File immediately. The $200 fee triggers at 30 days past, and the discipline exposure grows with delay. |
What to confirm this month
- Confirm with your ethics office whether you are a public filer, a confidential filer, or neither — and whether that changed with your last position change.
- Find your agency's internal deadline, which is generally earlier than May 15 or February 15.
- If you are a public filer, inventory whether you, your spouse, or a dependent child holds individual securities.
- Set up account notifications so a covered transaction reaches you well inside the 45-day outer limit.
- Calendar the periodic transaction obligation as a standing rule rather than an annual event — it has no date of its own.
- If you anticipate a data problem, request an extension before the due date. Up to 90 days is generally available for good cause.
- Report values in ranges, not exact figures, and use the OGE guide rather than guessing on fund treatment.
- Ask your ethics official about anything uncertain before filing rather than after.
- If you are leaving a covered position, calendar the termination report for 30 days out.
- If you discover an error in a filed report, raise it and amend promptly — willfulness is what separates a correction from a referral.
Frequently asked questions
Two populations. Public filers submit the OGE Form 278e and include Presidentially appointed Senate-confirmed officials, Senior Executive Service members, Senior Level and Scientific and Professional employees, Schedule C employees, and certain special government employees and Intergovernmental Personnel Act detailees. Confidential filers submit the OGE Form 450 and are employees whose positions their agency has designated as requiring confidential reporting under the criteria at 5 CFR 2634.904 — typically positions involving significant discretion in contracting, procurement, grants, or regulatory matters, generally at the GS-15 level and below. Your agency ethics office determines which category your position falls in.
Annual public reports on the OGE Form 278e are due May 15 each year. Annual confidential reports on the OGE Form 450 are generally due February 15. New entrant reports for both forms are generally due within 30 days of assuming a position designated for filing, though agencies may request them earlier and public filers frequently must be cleared before entering on duty. Termination reports for public filers are due within 30 days of leaving a covered position. Individual agencies may set earlier internal deadlines, so confirm yours with your ethics office rather than relying on the statutory date.
An employee required to file an OGE Form 278e or a periodic transaction report who files more than 30 days after the statutory deadline, including any granted extension, is subject to a $200 late filing fee. Agencies describe this as a statutory requirement they must enforce rather than a discretionary penalty. Separately, compliance with financial disclosure requirements is a condition of employment for those required to file, and employees who fail to file in a timely manner may be subject to disciplinary action up to and including removal from government service.
Under the STOCK Act, public filers must report covered transactions in stocks, bonds, and other securities exceeding $1,000 by the filer, spouse, or dependent child on the OGE Form 278-T. The report is due no later than 30 days after the filer receives notification of the transaction, but in no case later than 45 days after the transaction occurred. This is a rolling obligation separate from the annual report, and it is the requirement public filers most frequently miss, because it is triggered by trading activity rather than by a calendar date.
Yes. Filers may generally request an extension of up to 90 days from the appropriate ethics official where good cause is shown, but the request must be made before the original due date. That last condition is the one people miss — an extension requested after the deadline has already passed does not cure the lateness. If you know in advance that gathering account statements or valuations will take longer than the window allows, request the extension early rather than filing late and explaining afterward.
The public report requires detailed disclosure of financial interests for the filer, their spouse, and dependent children. Assets held for investment or the production of income are generally reportable if their value exceeded $1,000 at the end of the reporting period or if they generated more than $200 in income during it. The form also covers positions held outside the government, agreements and arrangements, sources of compensation, transactions, liabilities, and gifts and travel reimbursements. Values are reported in ranges rather than exact figures, which is a common point of confusion for first-time filers.
No. The confidential report is reviewed internally by agency ethics officials to identify conflicts of interest and is not available to the public. It is also shorter than the public form and requires less detail. The public OGE Form 278e, by contrast, is available to the public upon request — which is the practical difference that matters most to filers deciding how much attention the form deserves, and it is worth understanding before you complete either one.
An employee who willfully falsifies information on a report, willfully omits required information, or willfully fails to file may be subject to civil penalties and to criminal prosecution by the Department of Justice, in addition to agency disciplinary action. The operative word throughout is willfully — an inadvertent omission corrected promptly is a materially different matter from a knowing misstatement. If you discover an error in a filed report, raising it with your ethics official and amending it is generally the appropriate course, and doing so promptly matters.