The Office of Personnel Management (OPM) is taking effect a final update to 5 CFR part 731 on July 30, 2026. OPM says the rule improves how OPM and agencies vet suitability and fitness risks—and it formalizes that employees can face suitability procedures and actions based on post-appointment conduct.

What “post-appointment conduct” means in practice

In OPM’s framing, the rule connects conduct that happens after someone is hired/appointed into Federal service to the same suitability process that has long been used for applicants. Importantly, OPM also stresses that this is about character and conduct, not performance issues.

Where the authority shifts: agencies flag; OPM decides the Part 731 outcome

A key change is how the regulation separates roles when an issue involves an employee’s post-appointment conduct in the competitive service or career Senior Executive Service (SES).

• Agencies: If an agency has information suggesting an employee’s post-appointment conduct may implicate one or more suitability factors, the agency head or designee decides whether a proper and sufficient referral should be sent to OPM.
• OPM: Under Part 731, only OPM may take a suitability action against the covered employee when the basis is post-appointment conduct—and OPM reviews the referral to decide whether an action is warranted.

OPM also cautions that a referral must be supported by substantiated conduct (not just continuous vetting alerts, unverified allegations, or anonymous complaints).

What changes inside the suitability “factor” system

OPM says the final rule updates the suitability factors used in Part 731 decisions, including expanding the set from nine to ten. OPM also says the rule makes clear that the ten factors may be considered in assessing an individual’s suitability or fitness regardless of whether the person is an applicant, appointee, or employee—closing a gap that previously limited which factors could support OPM action against employees.

Training requirements are embedded in the regulation

OPM says the final rule incorporates expectations that people responsible for suitability screening, review, or determinations be trained to the National Training Standards (NTS) for Suitability Adjudicators. OPM also notes that it published the June 30, 2026 final rule and that relevant training content “reflects” the final rule changes that will not be effective until July 30, 2026.

What federal employees and HR teams should do next

• Check internal post-appointment conduct pathways: make sure your agency knows when issues may implicate one or more of the suitability factors and how to prepare a referral package.
• Strengthen documentation: OPm emphasizes that “proper and sufficient” referrals must be complete and supported by credible, verifiable evidence that the conduct occurred.
• Confirm training compliance: suitability adjudicators and HR personnel who handle adjudication-related responsibilities should ensure they are meeting the NTS training expectations tied to the July 30 rollout.
• Remember the limits: this rule is an additional suitability pathway; it does not automatically replace other authorities like Chapter 75 adverse actions.

What to watch next

Between now and July 30, 2026, agencies are expected to transition to the updated Part 731 framework. After the effective date, the practical “watch” will be how agencies document evidence and how OPM applies the updated suitability factors and referral standard in employee post-appointment conduct cases.

Sources

• OPM Suitability Executive Agent (SuitEA) — OPM overview/implementation information
• Federal Register (via GovInfo) — OPM final rule revising 5 CFR part 731 (PDF)