Last Updated: July 29, 2026 Reading Time: 10 min

OPM is pressing agencies to shrink the pool of career-reserved SES positions, the senior executive slots that by law can only be held by career civil servants. FedWeek reported the latest push on July 28: agencies told to review career-reserved designations with the goal of "maximum flexibility in opting for non-career officials."

The numbers say this is not a paperwork exercise. Total SES membership has fallen from 8,780 in September 2024 to 6,651 by May 2026, and career executives now number 5,805. Political (non-career) appointees have reached roughly 12% of the SES, above the 10% government-wide cap that federal law sets. If you are one of the remaining career executives, here is what the redesignation campaign actually changes, what it legally cannot change, and the pay math you should run before deciding your next move.

What OPM Actually Directed

Three documents define the campaign:

Date Action Deadline it set
Jan 20, 2025 Presidential memo "Restoring Accountability for Career Senior Executives" Directed OPM to act
Feb 4, 2025 OPM memo: redesignate all career-reserved SES CIO positions to general Feb 14, 2025
Feb 5, 2025 OPM memo: revert positions that were general on Jan 19, 2021, or held by noncareer appointees in the first Trump term 45 days to report
Mar 24, 2025 Full revised career-reserved lists due from every agency Mar 24, 2025

OPM's stated rationale: many career-reserved positions are not the "technical" impartiality-critical roles the designation was built for, and agency leadership should have flexibility to install non-career officials. OPM also notes the current career-reserved count sits at roughly double the 3,571-position statutory floor.

Two structural facts frame everything else. First, the law caps non-career SES at 10% government-wide and 25% per agency (5 U.S.C. 3133), and the government-wide number is already above the cap. Second, no position can change designation without written OPM approval under 5 C.F.R. 214.402, which makes OPM the referee of its own campaign.

Redesignation Is Not Removal

The single most important distinction, and the one most coverage blurs:

Position type (career-reserved vs. general) controls who may fill the job in the future. Appointment type (career, non-career, limited) is what you personally hold.

When your position flips from career-reserved to general, your career SES appointment continues untouched. You keep your pay, your position, and every statutory protection. What changes is succession: once you leave, voluntarily or otherwise, the agency can install a political appointee in the slot.

Redesignation does not push career executives out directly. It raises the long-term value of your departure, which is why the pressure that follows tends to arrive as reassignment proposals, performance recertification, and RIF restructuring rather than as anything labeled "removal for redesignation."

The Four Ways a Career Executive Can Be Displaced, and the Rights in Each

Scenario Can they do it? Your rights
Position redesignated to general Yes, with OPM written approval You stay; appointment unchanged; succession risk only
Performance-based removal from SES Yes, for less than fully successful executive performance Informal hearing before an MSPB-designated official (request it at least 15 days out); guaranteed fallback to GS-15 or equivalent
RIF / position abolished Yes, under SES RIF procedures Retention register, 45 days written notice minimum, guaranteed placement outside the SES under 5 U.S.C. 3594
Disciplinary removal (misconduct) Yes, under 5 U.S.C. 7541-7543 Full MSPB appeal, but no fallback placement; removal is from federal service entirely

Note the trap in the last row: refusing a directed reassignment is treated as a misconduct ground. An executive who declines to move can convert a fallback-protected situation into a no-fallback disciplinary one. Get advice before refusing anything in writing.

The 120-day moratorium. Under 5 U.S.C. 3592(b), you cannot be involuntarily removed from the SES within 120 days after a new agency head is appointed, or within 120 days after appointment of a new noncareer supervisor with removal authority over you. Acting officials do not start the clock. If your agency has a new head or your chain just gained a political supervisor, count the days; that window is breathing room to plan.

The Fallback Pay Math Nobody Shows You

Fallback rights guarantee a landing spot at GS-15 or equivalent. They do not guarantee SES pay forever. The 2026 numbers:

Pay point (2026) Amount
SES maximum, certified performance system $228,000
SES maximum, non-certified system $209,600
SES minimum $151,661
GS-15 Step 1 base ~$126,384

An executive near the certified maximum who falls back to a GS-15 slot faces a basic-pay reduction that can reach $70,000 to $100,000+ depending on locality and step placement.

The pension effect is what makes timing critical. Your FERS annuity is High-3 average × multiplier × years of service. The High-3 is your three highest-paid consecutive years. Spend your final years at $228,000 and the pension is computed on roughly that. Get pushed to GS-15 three years before retiring and the High-3 rebuilds around the lower salary, cutting the annuity permanently. Run your own numbers with the High-3 Calculator and the FERS Retirement Calculator, and if a RIF is in play, the Severance Calculator covers the separation math.

One more pay squeeze is already in effect: OPM's FY2026 guidance caps Level 4-5 performance ratings at 30% of each agency's career SES. Since SES raises and bonuses ride on ratings, most career executives will see compressed pay growth this cycle regardless of what happens to their position designation.

Which Positions Are Safe, and Whether You Can Fight a Redesignation

The impartiality standard in 5 U.S.C. 3132(b)(1) still has teeth. Positions whose functions are adjudication, audit, investigation, law enforcement, or oversight are extremely difficult to redesignate: senior SES roles in Inspectors General offices, the MSPB, the Office of Special Counsel, and OPM's own merit-system oversight. OPM's 2025 memos conspicuously targeted CIO, CHCO, and policy-titled positions instead.

Challenging a redesignation directly? There is no MSPB appeal for the designation decision; it is a management function, not an adverse action against you. The viable route is the Office of Special Counsel: if the redesignation is part of targeting you personally, retaliation, or a scheme to circumvent merit principles, that is a prohibited personnel practice complaint under 5 U.S.C. 2302. A designation change alone has not been held a PPP; a designation change plus your name on it, so to speak, can be.

Your Move List for the Next 12 Months

  1. Confirm your position's current designation. Ask HR for the position's SES designation of record and whether a redesignation request went to OPM in the March 2025 submission.
  2. Date your 120-day windows. New agency head or new political supervisor with removal authority? Write down the appointment date.
  3. Run the High-3 scenarios now. Compute your pension at current pay, at GS-15 fallback pay, and at your planned exit date. The difference is your negotiating and timing information.
  4. Document performance continuously. Performance-based removal is the lowest-friction displacement tool, and the 30% rating cap makes strong documentation more valuable, not less.
  5. Do not refuse a directed reassignment in writing without counsel. That refusal converts fallback-protected removal into no-fallback discipline.
  6. If you smell targeting, preserve evidence early. OSC complaints turn on the paper trail connecting the position action to you personally.

Calculate Your High-3 Exposure

You can put an exact dollar figure on the pension consequence of an SES exit. Use the free High-3 Calculator to see what your annuity looks like at SES pay versus GS-15 fallback pay. Try it now →

Frequently Asked Questions

If OPM redesignates my SES position from career-reserved to general, do I lose my job immediately?

No. Redesignation changes who can fill the position in the future. Your career SES appointment, pay, and protections continue until a separate personnel action is taken, and that action must comply with 5 U.S.C. 3592-3595.

What is the 120-day moratorium and does it protect me right now?

You cannot be involuntarily removed from the SES within 120 days after a new agency head is appointed, or within 120 days after a new noncareer supervisor with removal authority is appointed above you. The clock resets with each qualifying appointment, and acting time does not count.

If my SES position is eliminated in a RIF, what do I fall back to?

Guaranteed placement outside the SES, typically at GS-15 or equivalent, under 5 U.S.C. 3594, with at least 45 days written notice if you cannot be placed from the retention register.

Which SES positions are essentially impossible to redesignate?

Senior oversight and adjudicatory roles: IG offices, MSPB, OSC, and merit-system administration. The impartiality standard clearly covers them, and OPM must approve any change in writing.

Can I challenge a redesignation of my position?

Not directly at MSPB; the designation itself is a management decision. If it is combined with retaliation or merit-principle violations aimed at you, file with the Office of Special Counsel as a prohibited personnel practice.

How does losing SES pay affect my FERS pension?

The annuity is built on your High-3 average. Dropping from SES pay to GS-15 in your final working years rebuilds the High-3 around the lower salary and lowers the pension permanently. Model the scenarios before events choose your timing for you.

Sources: OPM Feb 5, 2025 career-reserved memo · CRS IF11743, July 21, 2026 · 5 U.S.C. 3592 · OPM 2026 SES salary table · FedWeek, July 28, 2026