GAO Audited DOGE's Ethics Paperwork. Most of It Could Not Be Verified.

Every federal employee knows the annual routine: ethics training, records management training, and — for many positions — a financial disclosure form with a certification block someone has to sign. A new Government Accountability Office report asked whether the DOGE personnel who reshaped the federal workforce completed that same paperwork. For most of them, GAO could not find out.

The report is DOGE: Information on Personnel and Ethics Activities, GAO-26-108403, released August 5, 2026.

What GAO Set Out to Examine

GAO identified 206 individuals serving in DOGE positions within the Executive Office of the President between January 2025 and January 2026. Twenty-seven of them were classified as special government employees, a category that allows a person to keep private-sector employment while serving in government.

The questions GAO asked were the ordinary compliance questions any agency asks its own workforce: Did these people complete ethics training? Did they complete records management training? Did they file financial disclosures?

What the Records Actually Showed

GAO was able to obtain records for 64 of the 206 personnel, drawn from the nine agencies that cooperated with the review. Within that group:

• Ethics training: 49 of 64 completed it.
• Records management training: 18 of 64 completed it.
• Financial disclosures: 38 of 64 filed with the agency.

The records management figure is the one worth pausing on. That training covers the obligation to preserve federal records — the same obligation that produces removal and suspension charges against rank-and-file employees. According to the report, the Department of Defense provided no records management training to sixteen DOGE personnel and told GAO that it does not provide that training to special government employees.

The report also notes financial disclosures that were filed but never certified — no reviewing official ever signed off — and that some of those individuals had already left government service.

The Records GAO Could Not Get

The larger finding is what was missing. The Executive Office of the President did not respond to GAO’s requests for access to training records and financial disclosures for DOGE personnel. Ten agencies did not provide the information GAO sought. That is why the denominator in every figure above is 64 rather than 206.

GAO also asked the Office of Government Ethics about oversight responsibility for DOGE personnel at the White House. OGE reported that it had limited responsibilities concerning DOGE personnel activities and did not plan to review the ethics program, citing the July 4, 2026 termination of the U.S. DOGE Service.

What GAO Did Not Find

This distinction matters, and it should not be blurred. GAO did not find that anyone broke the law. It did not conclude that any individual had an unresolved conflict of interest. What it found is that the records needed to answer the question were not made available, and that in the portion of the record GAO could review, completion rates for required training were low.

The finding is an absence of verification, not a finding of misconduct. That is a meaningful difference, and any federal employee who has been on the receiving end of a proposed action understands why the difference cuts the way it does.

Why This Lands Differently for Federal Employees

If you are a career federal employee, an unverifiable compliance record is not an outcome available to you. A missing training certificate generates an email, then a follow-up, then in some cases a proposed disciplinary action. An error on a financial disclosure form can become a lack-of-candor charge, which agencies treat as a serious offense because it goes to trustworthiness.

The asymmetry is real, and it is documented in a GAO report rather than in anyone’s opinion. But it is worth being precise about what that asymmetry does and does not give you. It does not create a defense. “Someone else was not audited” is not a recognized affirmative defense to a charge in any federal forum, and raising it as one tends to hurt rather than help.

What the report does provide is context — the kind of context that matters when an agency argues that a paperwork lapse reflects on your character rather than on a busy year.

What to Take From This

A few practical points, none of which depend on the politics of the report:

• Keep your own records. Save completion certificates for required training, and keep a copy of every financial disclosure you file along with the date. Agency systems are not always reliable, and the burden of showing you completed something tends to land on you.
• A charge still has to be proven. If an agency proposes discipline over a training lapse or a disclosure error, it must prove the charge by a preponderance of the evidence and show that the penalty is reasonable. The record has to support what the proposal notice says.
• Ask for the material relied on. In most adverse action procedures, you are entitled to review the evidence supporting the proposal. Request all of it, and use the full reply period rather than a fraction of it.
• Watch for the gap between the memo and the file. If the proposal describes a record that the evidence file does not actually contain, that gap is the substance of your reply.

The full report is available free at gao.gov under GAO-26-108403.

If you are facing a proposed action over training, recordkeeping, or a disclosure form, the details of your evidence file matter more than the headline. The federal employee lawyers at Southworth PC represent federal employees nationwide and offer free consultations.

Legal Disclaimer: This content is for general informational purposes only and does not constitute legal advice. Federal employment situations are fact-specific and time-sensitive. Please consult a qualified federal employment attorney about your specific situation.