OPM performance rating rules change: Jan. 1, 2027 starts for non-SES

The Office of Personnel Management (OPM) published a final rule on July 7, 2026 that overhauls major mechanics of the federal performance appraisal system for non–Senior Executive Service (non-SES) employees—covering General Schedule (GS) and prevailing-rate workers in the affected appraisal system. The rule is now official, and key provisions begin requiring agency compliance starting January 1, 2027.

What changes in plain English

According to the Federal Register summary, OPM’s final rule for non-SES employees:

• Removes the prior prohibition on forced/standardized rating distributions. Agencies are no longer barred from using standardized distribution approaches for performance rating levels.
• Eliminates the “Level 2” summary rating. The rule streamlines the summary-level pattern by removing Level 2.
• Ends mandatory review of Level 1 (“Unacceptable”) ratings. The rule removes the required mandatory review step for Level 1 ratings of record.
• Removes one dispute pathway for a “rating of record.” The rule removes the option to grieve a rating of record through negotiated grievance procedures under 5 U.S.C. 7121.
• Raises supervisory accountability expectations. The rule requires a supervisory critical element for all supervisors covered under the subpart.
• Changes oversight rhythm. OPM will conduct biennial certifications of agency appraisal systems.

Who’s affected (and who’s not)

This final rule is for non-SES performance appraisal programs, including most GS and prevailing-rate workers in the regulatory coverage described by OPM. It does not replace the separate performance appraisal framework that applies to Senior Executive Service (SES) leaders.

For many employees, the practical impact arrives when agencies update policies, supervisor practices, and HR workflows ahead of the compliance timeline that starts in 2027.

What changes for challenging a “rating of record”

One of the most consequential employee-facing shifts is how a disagreement over a “rating of record” can be contested. Under the final rule, the negotiated grievance/arbitration route under 5 U.S.C. 7121 is no longer available for challenging a rating of record.

That said, employees may still have other challenge options depending on the specific facts and the legal or contract frameworks that apply in their workplace. The new rule specifically removes this “rating of record” grievance option.

Timing: what’s official now vs. what starts in 2027

The rule is now published and final. The implementation planning date that HR and supervisors will focus on is January 1, 2027, when agencies must begin complying with specified provisions tied to these changes.

What to watch next

In the coming months, watch for agency rollout materials—especially updates to:

• how supervisors build and document performance standards and supervisory critical elements,
• how appraisal systems handle summary rating structure now that Level 2 is removed, and
• how HR employees are directed to handle disputes involving a rating of record after the 7121 grievance pathway is removed.

Sources

• Federal Register: OPM final rule (2026-13715 / OPM-2025-0273)
• OPM FAQ: Performance Appraisal Programs
• Federal News Network: Practical overview of the changes