Lane 3 · Federal personnel vetting, including Public Trust
Public Trust and PVMS Appendix C
The owner-provided Federal Personnel Vetting Management Standards (PVMS), Appendix C, Version 2 (May 2, 2025), describes minimum continuing-reporting requirements for covered personnel. It is not yet effective; until implementation, follow the sponsoring agency’s currently effective policy. Agencies designate the required channel, recipient and procedures, and may add requirements consistent with governing policy.
Timing rule for PVQ updatesWhen a life event changes an answer previously provided on the investigative form or PVQ in a category Appendix C requires the person to update, “promptly” means within three business days unless exceptional circumstances prevent it. This is not a universal deadline for every reporting duty. The agency must tell covered people which changes to report, how and to whom. Check the applicable risk tier and agency procedure.
Low risk
Appendix C §§E.1: update these PVQ/investigative-form answers when the response changes.
- §01 General information: full name, U.S. Social Security number, additional names.
- §11 Police record: arrest, charge, conviction or sentencing for a crime; domestic-violence, restraining, protective, stay-away, no-contact, anti-harassment or similar order.
- §18 Associations: membership in an organization dedicated to and engaged in violent overthrow of the U.S., a State or tribal government; knowing participation in violent overthrow activity; planning, contributing to, attempting or carrying out unlawful force/violence against a person, group or property; membership in a domestic/international terrorist organization; knowing terrorist acts or association; advocacy of terrorism.
Moderate / high risk · Non-sensitive
Appendix C §E.2: update all low-risk items, plus the following.
- §12 Drug activity: illegal drug use/misuse or controlled-substance misuse (excluding cannabis); intentional prescription misuse; illegal possession, purchase, manufacture, cultivation, trafficking, production, transfer, shipping, receipt, handling or sale; use in a national-security or criminal-justice/public-safety position; ordered or voluntary treatment related to covered illegal drug activity.
- §13 Marijuana/cannabis derivatives: use; use in a national-security or criminal-justice/public-safety position; illegal manufacture, cultivation, trafficking, production, transfer, shipping, receipt, handling or sale.
- §15 Federal debt: failure to file a Federal tax return or pay Federal taxes; currently past due on Federal non-tax debt.
- §17 Protected information: illegal/unauthorized access or attempted access; deliberate noncompliance with safeguarding rules.
- §19 Alcohol: use negatively impacts life; ordered or voluntary counseling/treatment due to alcohol use.
- §18 Associations: all low-risk association/violence/terrorism triggers.
- §23 Financial record: bankruptcy; alimony/child-support delinquency over 120 days; any debt delinquency over 120 days.
- §28 Psychological/emotional health: only certain Public Trust law-enforcement positions when D/A policy applies: court/administrative finding of mental incompetence; ordered mental-health consultation (with stated military-superior-order exception); hospital admission/required hospital evaluation for a mental-health condition or behavioral emergency; diagnosis of the specified disorders listed in Appendix C.
Moderate / high risk · Sensitive
Appendix C §E.3: update all applicable lower-tier items, plus these sensitive-position items.
- §03 U.S. citizenship / §04 Additional citizenships: citizenship status; citizenship of another country; foreign passport, identity card or similar international-travel document.
- §05 Residences / §07 Employment: current residence; service in a foreign government.
- §16 IT systems: illegal/unauthorized access or attempted access; unauthorized modification, destruction or manipulation of system information; denial or attempted denial of others’ access; unauthorized introduction, use or removal of hardware, software or media.
- §18 Associations: all low-risk association/violence/terrorism triggers, plus the additional sensitive-position triggers in Appendix C concerning advocacy/membership in organizations engaged in force or violence, including violence to prevent exercise of constitutional rights and unlawful violence.
- §20 Relationship status: current relationship status.
- §22 Foreign travel: unofficial foreign-country travel. Submit itinerary and receive approval in advance under D/A policy; report itinerary deviations within five business days after return. In an emergency, at minimum verbally advise supervisor/management chain before departure and fully report within five business days after return, unless D/A policy identifies an exception. Update the PVQ after the event as required.
- §25 Foreign contacts: contact with a foreign national, except contact only during official U.S. Government business; covered spouse/partner’s foreign-national contact as specified by Appendix C.
- §26 Foreign financial interests: foreign financial interest owned by the individual or specified spouse/partner/dependent child; control on another’s behalf; specified foreign-country benefits or future eligibility; financial support to a foreign national.
- §27 Foreign business/government activity: advising/supporting/consulting for foreign-owned business or organization; foreign official request for advice/consulting involving individual or specified family/partner; foreign-national job/consulting solicitation; business venture with foreign national; contact with foreign government/agency by individual or immediate family; sponsorship of foreign national to U.S.; foreign political office; vote in a foreign election.
- §28 Psychological/emotional health: the defined court/agency orders, hospitalization/required evaluation and diagnoses listed in Appendix C.
Foreign travel for sensitive positions
Submit an itinerary for unofficial foreign travel and receive approval before travel according to agency policy. Report deviations from the approved itinerary within five business days of return. When emergency circumstances prevent full advance reporting, verbally advise the supervisor or management chain before departure with the details required by agency policy, then fully report the travel within five business days of return. The agency may identify conditions when advance reporting or approval is not required. Update the designated vetting record when required.
Third-party reporting
Covered personnel report known concerns about another covered person as soon as practical through an appropriate agency official. Appendix C categories include unwillingness to comply with security requirements, unexplained affluence or excessive debt, alcohol or drug concerns, conduct affecting safe handling of protected information, criminal conduct, misuse of Government property or systems, and loss, compromise or tampering. Use the agency route for the concern; do not investigate it yourself.
Agency responsibilities
Agencies explain reporting expectations during onboarding and recurring awareness; identify reporting channels; evaluate reports and take any appropriate investigative, adjudicative or record-update action; and protect information under applicable privacy rules.
Public Trust self-reporting and agency disposition
- Agency explains the rule.At onboarding/indoctrination and annual refresher, the D/A identifies the employee’s risk/sensitivity tier, PVQ sections/questions to update, Executive-Agent self-reporting system, agency-specific duties, recipients, timing, evaluation process and available assistance (Appendix C §§A–B).
- Individual submits the change.When a life event changes a previously supplied answer listed for the tier, update it in the Executive-Agent-designated system within three business days unless exceptional circumstances prevent that. Also use the agency’s separate channel for additional/advance reporting; foreign-travel rules have their own advance and post-travel steps.
- Report a concern about another person.Any member of the trusted workforce reports covered peer/supervisor concerns as soon as practical to the appropriate D/A official, which may include personnel vetting, IG, insider threat, EEO or law enforcement (Appendix C §F). Do not investigate the person yourself.
- Agency evaluates and acts.The D/A combines the report with continuous-vetting alerts and other authorized information; requests new investigative work through the ISP when triggers are met; and conducts adjudicative activity when needed (Appendix C §§C–D).
- Update trust records and notify authorized offices.The D/A considers, changes or resolves authorized exceptions/conditions, affords applicable due process if a determination becomes unfavorable, updates the Federal personnel-vetting record and any internal system, and notifies other affiliated D/As/complementary missions when required.
Who to talk to: the agency’s personnel-vetting/security office listed in the employee’s onboarding instructions. For a contractor in a Public Trust position, Appendix C says to notify the sponsoring D/A for its agency-specific requirements and the private-sector security official (such as the FSO) when appropriate. The FSO does not become the adjudicator or replace the agency’s reporting channel.
Appendix C is a minimum standard. Agency implementation determines the actual reporting channel, applicable position category and any additional policy. It does not replace separate duties under criminal law, agency policy, contract terms or other reporting frameworks.