November 19, 2025

The 2024-25 Presidential Transition: Lessons Learned and Recommendations

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Authors
Mary Monti, Sasha Blachman and Georgia Haddad
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The Partnership for Public Service’s Center for Presidential Transition is the nation’s premier nonpartisan source of information and resources designed to help presidential candidates and their teams lay the groundwork for a new administration or for a president’s second term.
Table of Contents

Forward

Every presidential transition in modern history has been unique and 2024 was no exception. Although the transition of power from the outgoing Biden administration to the incoming Trump administration was peaceful, it was characterized by significant departures from established norms and set a precedent for future transitions to stray from processes that ensure transparency, ethics and security. Indeed, the new administration’s willingness to deviate from existing norms has continued to characterize its approach to governing throughout its first year.

Modern transitions rest on the firm foundations of the Presidential Transition Act of 1963 —as amended on a bipartisan basis by Congress over the years—which provides a framework for transition teams, the outgoing administration and federal agencies to work together effectively. These foundations include robust engagement between transition teams, the White House and agencies, maintaining national security, and demonstrating ethical and transparent governance.

This framework has rested on the assumption that candidates will voluntarily seek and accept the transition support services to which they are entitled under law, along with the legal protections and conditions tied to those services. The services authorized under the transition law are nonpartisan and designed to help a new administration move seamlessly into its role governing the nation.

The 2024-2025 cycle showed that adherence to processes prescribed by law cannot be assumed. Some departures from established norms may have occurred because president-elect Donald Trump’s team arrived with experience and knowledge from a previous term, or because the incoming administration lacked trust in the outgoing administration or federal agencies. But the question remains whether this will set a precedent for future transitions to forgo additional processes designed to support secure and ethical transitions.

This last cycle also exposed the ways in which some traditional practices and support services appear to no longer meet the logistical or political needs of a modern presidential transition. Issues related to office space, information technology and other services referenced in the law deserve scrutiny and modernization.

Updates to transition processes can address these issues, with particular attention paid to ensuring that the building blocks are in place so that future transitions are cooperative, nonpartisan, ethical and peaceful. With transitions being relatively few and far between, Congress and the executive branch should approach legislative and regulatory changes to established practices not with an eye toward circumstances or candidates of a particular moment, rather with a focus on long-term applicability and appropriate flexibility for teams to utilize the services that best and most efficiently meet their needs.

Executive Summary

This report provides a summary of how the 2024-25 transition proceeded and recommendations for reforms to address challenges based upon the reflections of experts and individual participants in this transition cycle and available public reporting. These experts included members of the Trump transition; those involved in the planning for Democratic nominee Vice President Kamala Harris; members of President Joe Biden’s White House staff; and career experts who have served in federal agencies. For further resources on the basics of transition and recommended best transition practices, please visit the Center for Presidential Transition website, including our Presidential Transition Guide, Agency Transition Guide, Second Term Transition Guide and 2020-21 Lessons Learned report.

The stories of two transition teams

Both the Trump and Harris transitions operated under unusual circumstances and timelines. Each departed from certain core aspects of transition fundamentals, but the Trump team diverged more sharply from the typical path, opting out of or delaying practices relied on to protect national security and promote transparency. 

The Trump Transition

Transition teams typically name chairs and begin work in the spring of an election year. The Trump transition started later than is recommended, naming Linda McMahon and Howard Lutnick as formal transition co-chairs on Aug. 16. Still, Republican operatives had already spent many months preparing for 2024 in organizations that included the America First Policy Institute, Heritage Foundation and Center for Renewing America. Trump formally disavowed policy plans by these groups during the campaign, but all appear to have significantly influenced the transition and administration.

Members of these organizations, many of whom were veterans of Trump’s first term, spent years evaluating the successes and failures of that administration and developing policies, implementation strategies, appointee trainings and personnel databases to plug directly into a second Trump term. Heritage’s Project 2025 attracted extensive media attention, but the months since Trump’s inauguration suggest that AFPI’s America First Transition Project had a much greater influence on the transition itself, while all three institutions contributed policy plans and personnel to the early Trump administration. For example, at least 73 AFPI alumni were serving in the Trump administration as of May 2025, including McMahon, who was chair of AFPI before joining the transition.

In the administration itself, nine Cabinet members have strong affiliations with AFPI, and Trump’s director of the Office of Management and Budget Russ Vought led that office during Trump’s first term, then helped Heritage author Project 2025 and founded the Center for Renewing America. Further demonstrating the influence of these organizations on the policy process, AFPI developed transition action plans on many policy areas, then passed these plans to transition team members—many of whom were the same AFPI staffers who had drafted the plans and then joined the formal transition.

By drawing on the volumes of work done by these think tanks, the Trump administration was able to rapidly enact plans and set early records for the rate of executive orders issued. This model of transition—relying on outside groups for policy development—has been used before and will likely continue to be used more aggressively in future transition cycles. However, it comes with tradeoffs that future transitions should account for, such as potential blind spots in policy plans created without insights gleaned from current officials.

On the formal transition, McMahon and Lutnick were part of an insular group of trusted deputies close to Trump. This group also included Susie Wiles, who was announced as White House chief of staff on Nov. 7. Information was tightly controlled, with loyalty and communication skills being key criteria for participation in the transition and the eventual administration. Trusted deputies picked their own trusted aides to build out staffing for the transition and the administration. The transition operation was designed to remain lean and insular to avoid leaks and allow fast decision-making. Far fewer transition members obtained security clearances than in typical years, and rank-and-file transition members and volunteers had little visibility into other workstreams or leadership.

Transition team members said that work was organized primarily around key tenets of Trump’s agenda and directed from the top down by the president-elect’s close circle. Leadership operated mainly out of Mar-a-Lago, Trump’s Florida residence and resort, where he spent much of his time. Washington, D.C.-based transition operatives communicated with or traveled to Florida as needed.

Significant delays agreeing to memoranda of understanding to govern interactions between the Trump team and executive branch agencies led to a slow start of key transition processes. The Presidential Transition Act directs the administration and transition teams to reach agreements regarding logistical support and information sharing by certain calendar dates “to the maximum extent practicable,” directions which typically have been closely heeded. Teams also traditionally sign an MOU with the Department of Justice outlining procedures for FBI background checks for transition team members and potential appointees. The Trump team ultimately signed only two of the typical set of transition agreements—one with the Biden White House defining the terms on which agency review team members go into agencies during the formal transition, and another with the Department of Justice. To avoid being bound by disclosure agreements, they declined to sign an agreement with the General Services Administration to receive government support services for the transition, including office space, funding and IT (e.g. devices, cybersecurity, .gov email addresses).

The delays in signing these documents contributed to the team’s agency engagements beginning later than usual, causing the team to forego roughly six weeks of collaboration. The team did not sign the White House agreement until Nov. 26 and agency review teams did not begin arriving at agencies until mid-December, despite agencies’ readiness to begin work immediately post-election. Trump’s team also did not send its first ethics review packages for political appointees to the Office of Government Ethics, which works with agencies to prevent conflicts of interests for political appointees, until late December. The MOU with the Department of Justice was not signed until Dec. 4, preventing the FBI from processing background checks for future appointees or transition team members. Without existing security clearances, transition team members could not receive classified transition briefings.

Despite the slow start and compressed timeline, transition work occurred in agencies during the formal transition period. Briefings and onboardings were offered and delivered to members of the agency review teams. This effort was aided by existing relationships between agency career staff and the many transition team members who had worked in the agencies during the first Trump administration. Agencies received instructions to provide information only to individuals whose names had been directly communicated to the agency by GSA as agency review team members, but some agencies reported individuals not on these lists arriving at agencies or contacting employees directly to ask for physical or electronic access. Some identified themselves as the “Department of Government Efficiency,” or DOGE,1 team and had different priorities from typical agency review team members.

Many agency leaders differentiated the pre-inauguration transition period from the days immediately following Jan. 20 when executive orders to reshape the federal workforce began flowing, significantly impacting the ability of agencies to complete work and maintain morale. The speed with which these policies were released can be traced to the pre-work done by third-party organizations.

The Harris transition

Vice President Kamala Harris’ transition work also started later than usual due to the candidate switch. Her campaign announced Yohannes Abraham as transition chair on Aug. 23, a few weeks after President Biden formally bowed out of the race, but had people start early transition preparations before Abraham was able to jump in. Led by Abraham, who was the 2020-21 Biden transition executive director, the team focused on essential transition functions. This team was smaller than the 2020-21 Biden team due to the shortened timeline and the team’s familiarity with the current government.

The Harris team relied on an intentional mix of experienced government operators, prior transition alumni, and longtime Harris staffers. These included Josh Hsu, a former Biden transition official and longtime senior Harris advisor, who served as executive director. The team kept in close touch with the Office of the Vice President and a small set of campaign leaders, particularly at key inflection points.

The team organized itself into typical transition workstreams—agency review, personnel, policy and operations, which were modified to account for the relatively rare task of preparing for a sitting vice president. As of Election Day, the Harris transition was prepared to deploy agency review teams, had built a large personnel vetting operation, including large numbers of personnel vetting attorneys and former Office of Presidential Personnel staff, and had teed up critical personnel decisions. The team strove to protect the vice president‘s time on the campaign, but prioritized some personnel decisions pre-election. For example, Harris chose Secretary of Veterans Affairs Denis McDonough as her chief of staff in early October and had been reviewing memos on policy and decision-making processes since September. Post-election, Harris planned to shift heavily to transition work and the team intended to bring campaign staffers and staff from her White House office into transition work.

Part 1: Updating transition practices for a modern world

As demonstrated this past cycle, the world moves fast and some well-established and customarily used transition practices may miss the mark and no longer meet the needs of an incoming administration. These should be refreshed to better serve the fundamental goals of the transition process. 

Amend the Presidential Transition Act to strengthen incentives for transition teams to comply with practices that promote security, transparency and ethics.

During this past transition cycle, the Trump team did not accept the services provided by the General Services Administration and significantly delayed using the services from the Department of Justice and Office of Government Ethics. This inhibited the team’s ability to prepare essential staff and enabled them to avoid disclosing transition donors, agency review team members and the use of their transition funding. Without acceptance of the services, no legal mechanism could force cooperation with these goals historically identified by Congress as important. Government transition officials had to develop transition implementation instructions in real-time and weigh supporting maximum readiness for the Trump team against its potential noncompliance with national security and ethics practices.

For example, because the Trump transition did not use a government-provided server or .gov email addresses, agency officials had to negotiate how to securely exchange information with agency review teams. The lack of standard infrastructure created a risk of inadvertently sharing sensitive information with unauthorized parties or sending it through unsecured channels that might be hacked, delaying the sharing of critical information until safe channels were obtained.

Without disclosures of donors or agency review team members, the public lost a valuable understanding of the individuals and organizations influencing the administration. More importantly, such disclosures create public scrutiny that encourages the transition team to police itself tightly against conflicts of interest. Without this external pressure, there are fewer eyes ensuring ethical governance and a reduced motive for the transition to guard against conflicts internally.

Congress should clarify presidential goals of transparency, ethics and national security by decoupling them from conditional acceptance of government services to ensure that transition teams are directed to meet those goals. However, enforcement of any such requirements must be reasonably flexible to avoid overly inhibiting the readiness of the next administration.

We recommend that the following amendments be made to the Presidential Transition Act to ensure greater security, transparency and adherence to ethics requirements:

  1. Public disclosure of agency review team members should be made by the day after the election and prior to being allowed access to transition services or agency personnel and information, with rolling disclosures as needed through the inauguration.2 
    • An alternative option would be to set public disclosure of any agency review team member’s name as a condition for their ability to access agency materials, regardless of whether the transition team accepts transition services under the Presidential Transition Act.
  2. Public disclosure of the names of transition team donors giving more than a threshold dollar amount, as specified by the transition law, as well as the value of each donor’s total contribution, should be available at checkpoint dates such as Nov. 1 and March 1.
  3. Public disclosure of transition team spending of public and/or private money should be made by 30 days post-inauguration, regardless of whether the transition team accepts transition services. Disclosures also could be mandated at other checkpoints, such as 30- and 60-days post-election.
  4. A deadline should be set or recommended for submission of the names of transition representatives who will be trained on the Office of Government Ethics’ system for filing financial disclosures so these individuals can serve as liaisons for the transition team by an appropriate date in the summer or early fall.
  5. A stand-alone submission to GSA and public disclosure of a transition team’s ethics plan should be required by Oct. 1. Congress may also want to define or recommend specific items to be included in these ethics plans. 3
  6. Clearer requirements for IT security are needed. Transition teams should either set up a .gov transition network or demonstrate that their IT platforms meet certain security requirements via pen testing and other security methods in order to communicate with and receive information from agencies.

 

Clarify points of confusion around the GSA MOU to minimize debate and delay.

Define the terms of equal agency access clearly and early.

Significant time and effort from agency and transition officials went into implementing new provisions created by the Electoral Count Reform and Presidential Transition Improvement Act of 2022. Preparation for a potential “multiple possible apparent successful candidate” period proved particularly challenging, as the legislation directed agencies to provide equal access to agency resources to the transition team of any candidate who might still be declared the winner in the event of an extended, contested election.

Had this occurred, uncertainty about what “equal” access meant in practice would likely have prevented this period from being used as intendedas a time for the transitions to operate fully4—due to concerns about agencies sharing requests for information with the opposing transition teams, thereby tipping the hand of one side’s policy interests with the election still pending. Agency leaders also worried that one transition or both transitions might flood agencies with requests such that agencies would become overwhelmed. GSA ultimately issued guidance that agencies did not have to alert one team about the other’s requests and instructed transition teams to clearly prioritize requests for agencies to triage. Agencies were instructed to exercise appropriate discretion in choosing both technical and practical procedures for information sharing.

To ease this confusion in future cycles, GSA should issue early guidance in the summer of the presidential election year to define equal access and spell out:

  1. If agencies must notify each team about requests from the other and proactively offer requested information.
  2. If they must not alert other teams of the requests made by each team but ensure that information is equally available to each team requesting it.
  3. Or, if agencies can choose which of these paths to take, as well as how and when they must communicate this policy to transition teams.

 

Clarify the criteria for ending a multiple possible apparent successful candidate period.

Clarification about how the GSA administrator determines the end of a multiple successful candidate period would reduce the stakes of that potential decision. In response to the 2022 amendments, GSA created a system of spreadsheets and internal trackers, but the process was intense, complex and politically sensitive. More importantly, some transition experts were concerned that the law’s new criteria could incentivize a candidate to delay a concession and continue receiving transition information. Clearer congressional directives about the criteria for the decision to end services would support GSA’s ability to make that decision efficiently and safely if needed.5

Streamline the process of negotiating MOUs.

Two points of disagreement around the GSA-transition team MOU slowed down negotiations for both transition teams, delaying the start of services for the Harris team beyond the recommended date. The Trump team interpreted a signature on the MOU to mean that they were bound by disclosure requirements, while GSA said that signing the MOU meant agreeing to the list of services and funds that would be offered, but that the disclosures would become mandatory only if their team actually used the services. A separate acceptance of services from the MOU would be needed by GSA from each transition in order to start services. Despite this interpretation from GSA, the Trump transition’s strong aversion to signing any document which might trigger disclosures meant that they refused to sign the GSA MOU without certainty that no funding or agency review team member disclosures would be mandated if they did so.

While the Trump team was confident in their ability to provide their own funding and space for the transition and therefore not concerned about skipping the GSA-provided services, section 3 of the PTA also includes references to services offered by other agencies including the FBI, National Archives and Records Administration and the U.S. Postal Service. The Trump team wished to take advantage of those services, so negotiations remained open. Ultimately, officials were able to determine that those agencies could still provide services to the Trump team based on other authorizations, including the 2004 Intelligence Reform and Terrorism Prevention Act. Once the Trump team understood that they could take advantage of some services mentioned in the PTA through methods other than signing the GSA MOU, they chose to continue transition work without it.

Even though the Trump transition did not sign the GSA MOU, negotiation delays still impacted the Harris team because of GSA’s practice of offering identical MOUs to both transition teams. The GSA MOU is meant to be substantially based on prior MOU’s and to the agency’s “best effort,” should be identical for both teams. The Harris team wanted additional services such as security in shared space, which the Trump team was fine with. But, because the Trump team continued to be wary of signing at all, the ongoing negotiations contributed to delays. This meant the Harris team did not sign the MOU until Sept. 19 due to concerns about letting one team get started without the other. Political leadership within GSA was worried about the possible appearance of favoring the Harris team if it looked as if they were pressuring the Trump transition to agree to conditions that were set by the other team. Ultimately, the decision was made within GSA that the Harris team should be allowed to access services and that if the Trump team wanted to sign the GSA MOU or make further changes to it for services that they wanted to accept, this could be done with amendments to the document.

Clarifying in statute or GSA guidance ahead of the transition that the GSA MOU represents a menu of services and not acceptance of each service could ease both of these delays in future cycles.

Another possible solution might be to set two separate dates for transition teams to establish the boundaries of services. For example, transition teams could, to the maximum extent practicable, be required to agree by a particular date to a “menu” of services that both teams will be offered that year by GSA and then allowed to submit their “order” of services at a later date,6 after which services could kick in immediately. Separating the date of agreement to services and their start date could ease this year’s dynamic in which GSA did not want to pressure the Trump team to agree to the Harris MOU terms just because the Harris team signed first, but the process ended up disadvantaging the Harris team by delaying the start of their services.

Finally, because provisions in the GSA MOU impact the execution of the agency access and security clearance agreements and involve many of the same players, transition experts recommend that future administrations conduct negotiations for all three MOUs concurrently to make the process more efficient and ensure that dependencies between each document work as they should.

Update and modernize transition services offered by the government.

Offer alternative IT support to allow transitions to safely exchange information with agencies on their own servers.

Because the Trump team did not sign the GSA MOU, their transition only used an external, private server instead of switching to government-secured IT infrastructure. Agency transition leaders reported an inability to share sensitive information through email because of agency security standards and struggled to verify digital communications from individuals claiming to be transition personnel. Individuals would email agencies or appear in virtual meetings using addresses with a range of domain names, including “@transition47.com, @trumpvancetransition.com and @djtfp24.com”– and not all requests were from legitimate sources. Without the predictability provided by a certified .gov email address, agency leaders faced challenges to ensure that they only shared information with valid transition members. It was unclear if the domain platforms met government security requirements to share sensitive, unclassified information and there were also concerns about an external server’s vulnerability to cyberthreats.

To ensure future transition teams can efficiently and safely communicate with agencies, GSA should:

  1. Create a required certification or approval structure through which incoming teams may retain their external platform during the formal transition by demonstrating that their platform meets government security standards. Such certification could be overseen by an entity such as GSA’s Technology Transformation Services. Implementation would require planning to allow development of standards early enough that incoming teams have time to comply and determine their preferences. Allowing teams to maintain their existing systems might also ease transition team fears about the privacy of government IT that contributed to the MOU negotiation delays. Such a system also would relieve a typical transition burden of transferring a team’s operations from the systems used by the transition before GSA services become available in late summer.
  2. Further clarify directions for the types of materials agencies may share with candidate teams pre-inauguration and the channels through which to do so. Agency transition leaders reported incongruence across agencies and even within agencies on what materials were appropriate to share and how, leading to inconsistencies and struggles building trust with the incoming team.

 

Congress should consider reimbursing transition teams for office space of their choosing.

Only the Harris team used the GSA-provided office space this year and in an environment of distrust between candidate teams, the prospect of close proximity to the challenging candidate’s team created security concerns. Meanwhile, the Trump team conducted its work in the Willard Hotel in downtown Washington, D.C., in New York City, at Mar-a-Lago and virtually. Transition officials still say a physical location supports important collaboration, as well as communication with agency and congressional officials, but as demonstrated by the significant transition work done virtually in 2020 and 2024, widespread embrace of hybrid work means that physical space matters less than it once did.

A better future model may be eliminating the option of GSA-provided space—which must be chosen far in advance and funded by taxpayers even when unused—from the menu of available transition services. Instead, Congress could increase the public funding available to transitions and designate a portion of it to reimburse teams for office space of their choosing, though such reimbursements should be capped to prevent costs from soaring too high.

Increase public funding available to transition teams.

Public funding for transitions should be increased across the board to meet the modern needs of candidate teams. Currently, teams may access public funding to cover transition-related expenses such as salaries and benefits, travel, printing and communication services for the presidents-elect’s team, but given the increasing cost7 of complex transitions, this cycle’s funding level of roughly $7.2 million for the 2024-25 transition covers relatively few expenses. While taxpayers do not need to fund the entire transition, Congress should consider additional appropriations to transition teams to cover the rising costs of robust transition planning and publicly signal the importance of such work.

Streamline appointee vetting paperwork.

As in past transitions, nominees for positions subject to Senate confirmation were surprised by the amount of vetting paperwork they had to fill out. Forms include any questionnaires the White House Office of Presidential Personnel may require, the SF-86 form for a background investigation, OGE ethics forms and questionnaires from the Senate Committees of jurisdiction.

Longstanding recommendations to reduce this burden, most notably by a bipartisan Working Group on Streamlining Paperwork for Executive Nominations,8 include eliminating overlap and duplication among the various forms that nominees must complete; creating a presumption for a 10-year background investigative scope for appointees subject to confirmation; and varying the paperwork and investigative scope based on the nature of the position. Both the executive branch and Congress should examine the progress made on these recommendations and work to further implement them.

The administration and the Senate should focus in particular on the development of a smart form to eliminate the need for nominees to answer comparable questions on different forms. They should also push to create an internal dashboard for the transition, incoming administration and nominees to track the status of paperwork. A smart form would improve vetting by keeping all parties apprised of uncompleted tasks and what is necessary for appointees to move forward, though its success would depend on also reducing questions that ask for similar information in slightly different ways.

Reforms to responsibly speed up vetting would ease the extended and growing length of time required for presidential appointees to be confirmed by the Senate and enact a president’s agenda. The Senate confirmation process alone had grown to take an average of 193 days per nominee by the end of the Biden administration. Some of this time is occupied by completion of extensive paperwork and is in addition to the pre-nomination vetting that all appointees—Senate confirmed and otherwise—must complete.

Protect essential work from government shutdown pauses.

To eliminate the risk of halting critical transition work during a lapse in appropriations, Congress or OMB should ensure that transition activities are deemed essential as part of agency shutdown plans. Given the limited timeline of each transition and the risks of an unprepared incoming presidential administration, pauses in transition work due to a government-wide shutdown, as was a possibility this cycle, must be avoided.

Projects that should be considered essential include the work of the federal transition coordinator, all agency transition directors9 and additional staff determined by each agency transition director to be necessary to executing transition activities. This clarification would give agencies additional guidance when determining their shutdown personnel policies in a confusing and stressful environment.

Raise the limit on transition donations.

Congress added the static $5,000 cap on transition donations to the law with a 1988 amendment. It should reset this cap to an equivalent modern threshold (roughly $14,000) and allow it to rise with inflation to ease the fundraising burden of transitions so they can focus more energy on core preparatory work.

Prepare career officials for possible reassignments on Jan. 20 but clarify rules under which career members of the Senior Executive Service may be reassigned.

Several agency transition officials expressed surprise at the rapid reassignment of career officials by the incoming administration after the inauguration. Transition law requires agencies to have in place, by Sept. 15 of a presidential election year, a succession plan for each senior noncareer position in the agency. These plans tell a transition team which career officials will step in to perform roles previously held by political appointees of the departing administration until new appointees arrive. In addition to being in place on Jan. 20, these career officials are key sources of knowledge for the incoming team during the transition and team members should engage with them during this time.

After the inauguration, though, a new administration has some flexibility to install political appointees into these positions temporarily held by career officials. For positions subject to Senate confirmation, the Federal Vacancies Reform Act governs which categories of officials may serve temporarily as the acting official while the agency waits for nomination and confirmation for the position. The available choices may or may not be a political appointee. The administration generally is able to move appointees more quickly into political positions not subject to Senate confirmation, non-career Senior Executive Service positions, or, subject to certain limits, “general” SES positions, which may be filled by a career official or a political appointee.

In planning for potential movement of career SES members into different roles, incoming administrations must adhere to a statutory moratorium on involuntary reassignments. This moratorium is intended to overcome incoming political teams’ suspicions of career appointees and prevent politicized reassignments. This moratorium applies within 120 days after the appointment of an agency head, or after the appointment of the career SES official’s most immediate supervisor who is a political appointee and has authority to conduct the performance review of the career SES members. The Office of Personnel Management’s 2024 Presidential Transition Guide explains that designating an acting official is not the same as making an appointment and therefore does not trigger the statutory moratorium. Agencies may at their own discretion decide to apply the moratorium, the advantage being if the acting official eventually receives a permanent appointment to the position, time spent as the acting official counts toward the 120-day moratorium. In many cases, though, incoming Trump political acting officials chose to reassign SES members within days of the inauguration, leading to confusion and chaos as officials found themselves in roles that they had neither expected nor prepared for.

The following steps should be taken to provide more clarity to the career workforce on role reassignments that may occur after an inauguration, and to better preserve the intent of the 120-day moratorium:

  1. The leadership of the Agency Transition Directors Council should provide briefings on these rules to the transition directors so that they can help raise awareness within their agencies of the rapid changes that may occur early in a presidential administration.
  2. Transition teams should seek to inform agencies before Jan. 20 of changes they intend to make to acting official assignments to ensure that those officials have sufficient notice to prepare for their acting roles.
  3. Congress should ensure that the 120-day moratorium on involuntarily moving SES personnel will also apply universally under new acting heads of agencies/supervisors of SES.

 

Clarify the rules and goals of detailing personnel to a transition team.

Congressional staff detailees often support presidential transition teams, but the rules for this process are vague and vary from election year to election year. If this practice is to continue, clearer guidance from congressional ethics entities and/or OPM’s 2024 Presidential Transition Guide should be established to prevent conflicts between a staffer’s oversight role in Congress and their role on the transition team.

Clearer rules—both in the executive branch and in Congress—on the use of agency detailees may also be helpful in the case of a future vice president to president transition, as was possible this year, to ensure appropriate differentiation of a detailee’s role in an agency that they currently serve in and any work they do for a transition team related to their day job’s subject matter.

Increase appropriations for transition service providers and teams.

Transition service provider agencies, including the GSA, OGE, the Department of Justice and the National Archives and Records Administration, experience intense pressure to quickly process requests from incoming teams during a transition period and would have to shoulder even greater pressure should a future transition have a multiple possible apparent successful candidate period. Increasing transition activity appropriations for these agencies will ensure that they can fully meet the intense demands of such a moment.

The intent of Congress regarding appropriations for transition teams in a contested election scenario should also be made clear and permanent. After the 2022 transition law updates, it remained unclear whether appropriated transition funds should be shared between teams in a multiple candidate period. Congress provided an additional appropriation for 2024 to ensure full funding for each potential transition, but this is not guaranteed in future years. The amount of funding that Congress intends to provide to one transition should be established permanently as the maximum budget for each transition for as long as two (or more) transitions are operating. This would reduce pressure on the GSA administrator to shut off services to remaining candidate(s) during a contested election and ensure full resources for each team.

Create a structure for security provisions for transition-related staff.

Given the stakes of a multiple possible apparent successful candidate scenario, immense pressure and focus is placed on the GSA administrator to determine the end of the multiple candidate period. Former GSA and OPM staff reported concerns for the safety of senior GSA personnel and other transition-related staff during the period surrounding the election. Appropriations should be considered for GSA to provide security services for senior transition officials and facilities during a multiple possible apparent successful candidate period or if there are viable threats to people or property.

Prepare for future transitions in which AI will introduce new challenges and opportunities for operations and agency review.

While the use of artificial intelligence in the federal government is not new, the 2024-25 transition was the first since the release of ChatGPT and other widely adopted generative AI tools. Reporting suggests that the Trump administration used AI to evaluate vast amounts of government data early in the administration, demonstrating one way that AI may be incorporated into a new administration’s approach to governing. Given the daunting challenge of running the federal government, it is likely that future transition teams will use AI to scale and improve their preparations, especially when it comes to analyzing information from agencies in the post-election period.

Any use of AI by a transition team should comply with legal, IT, security and privacy rules and policies that are a part of the service agreements that the transition team signs with the federal government. Future transitions should use those agreements, as well as responsible AI principles, to guide the implementation of AI into their workflows, operations and governance structures. For example, any transition members using AI tools should receive appropriate training on their use and data security practices.

If transition teams continue to use external servers rather than federal IT systems, additional structures may be needed to keep federal data secure with AI use. Agency transition leaders and government officials responsible for approving information shared with transition teams must have enough insight into a transition’s AI use to confirm compliance with service agreements while respecting its status as a non-government entity. Transition teams also should be aware of the terms governing their interactions with any government AI tools. All parties using AI should follow approved protocols that account for federal records laws around data used for or generated by AI when sunsetting transition operations.

Part 2: Building on proven successes

Decades of practice and study built the foundation for presidential transitions which have enabled peaceful transitions of power, including in 2025. While this year’s transition was indeed peaceful, many of the core transition values were found to be reliant on norms and are at risk. These basic principles should be upheld and where needed, bolstered and protected for future transitions.

Prioritize security, transparency and ethics in the transition process.

At its core, transition law intends to ensure an orderly transfer of power in order to protect the safety and well-being of the country. Transparency and ethics are also essential tenets of good government and a good transition. Current laws create a framework that encourages transition teams to act according to these ideals. During the 2024-25 cycle, we saw for the first time that not all teams will adhere to the framework. The Trump team delayed signing the MOU with the Department of Justice which then delayed the start of background checks on future administration members until the end of November. They also declined GSA’s offer of a government-secured IT platform for sharing information with agencies, opting instead to conduct their transition work on private servers. Both choices created national security risks, but experienced government officials adapted to make the transition as safe and secure as possible.

By not accepting GSA services, the Trump team was not legally obligated to make the donor, funding and agency review team disclosures directed in the transition law and chose not to do so voluntarily. Still, the team disclosed its internal ethics plan, OGE ensured conflict reviews for incoming appointees happened at record speed and top nominees underwent Senate review before they could officially take their seats.

The Trump team’s delays and departures from normal procedures put longstanding transition values at risk, but Congresses and administrations throughout the decades have baked in processes designed to keep the country safe and provide ethical guardrails for every part of the transition process. Even if not strengthened, these procedures serve the best interests of the American public and should, at a minimum, be respected and carried out by future transitions.

Use expert experience to ease and speed up processes.

Transitions, and as a result, transition experts, are rare. Intentional use of experience across transition stakeholder groups enabled efficiencies for transition teams and agency leaders during this transition cycle.

The Harris team, led by Biden transition veterans, compressed planning to construct a streamlined transition operation within the 107 days between Harris’ selection as candidate and the election. They stuck to familiar transition fundamentals and were ready to sprint post-election.

The Trump transition also had a deep, experienced bench. Many members of the team served in Trump’s first administration and used their existing base of knowledge, in addition to the work developed by think tanks, to focus on seeking out specific answers during agency review and preparing personnel.

Career agency transition directors also emphasized the value of the Trump team’s recent experience during the agency review process. Many team members previously served in the agencies they were reviewing, meaning that career employees and transition team members could rekindle trusted relationships. Agency review team members were also generally knowledgeable about the workings of agencies, frequently asking second-order questions.

Finally, experience boosted agencies’ internal preparations. Many agency transition directors highlighted how their smooth preparations and ability to adapt to challenges were supported by effective internal knowledge management of previous transition work, which had been built up by career officials across many cycles.

In future transitions, all stakeholders in both the transition teams and administration should follow the example set this cycle and learn from those who have done this work before.

Build upon new advances in second term transition planning.

The past election season began with a rare case of two presidents vying for second terms and both candidates made new advancements in second-term transition planning, a historically underexplored area.

In late spring of 2024, senior Biden officials began work on a plan for a comprehensive review of the executive branch, with a particular emphasis on personnel. A small, central team began conversations on who they wanted to keep or reassign in the Cabinet and senior leadership, as well as which officials wanted personally to stay or go. This work also identified roles that were perpetually hard-to-fill and required focused effort to replace if vacated (e.g. the commissioners of the Social Security or Food and Drug administrations), or were no longer needed (e.g., positions that had become redundant). Had this work not paused when Biden left the race, the team planned to expand its efforts by surveying all political staff about their career intentions in a potential second term, and as in a first term transition, eventually bring the president into decision-making conversations.

Similar efforts were carried out by political appointees within some agencies, such as the departments of Agriculture and Labor. Agency appointees took stock of current personnel and initiatives completed in the past four years and identified goals, changes and new initiatives to focus on in a second term.

Once Harris became the Democratic candidate, much of this work was left to stand with the expectation that it could be presented to or resumed by a Harris transition team, and that some personnel would be retained. However, Biden officials emphasized the importance of drawing “bright lines” between the work that continued to execute objectives already in progress by the administration and any planning done for a future Harris administration.

Work done by veterans of the first Trump administration in think tanks that fed into the second Trump term might also be considered a form of second term planning. These groups reviewed the successes and failures of the first Trump term and developed proposals for improvements in the second. Strategies and best practices used in this work might also support second term planning by sitting administrations in future cycles. However, the core work of transition planning by which candidates prepare to lead the operations of government should still be protected from the battles of partisan policymaking and done collaboratively between transition teams, outgoing administrations and career officials.

New practices developed by members of both parties to learn from and improve upon a first term should be replicated and further improved by the next administrations preparing for a potential second term.

Political leaders should support career officials’ essential leadership role in preparing a smooth transition.

Transition expertise developed among agency career leaders across multiple transitions proved valuable during this cycle. Despite several unusual twists and challenges, career leadership throughout the executive branch met the moment, carried out their statutory duties and supported the Trump administration’s preparations to re-take office.

GSA officials played an essential role in coordinating transition activities across government. Federal transition coordinator Aimee Whiteman received well-deserved accolades from all corners for her work negotiating between the transition teams and maintaining order while shepherding transition work across agencies. Led by Whiteman’s guidance, agency transition directors across the government prepared throughout 2024 for transition. These preparations included the establishment of new systems to enact the 2022 transition amendments, which created an apparatus for two transitions to access agencies in parallel. Agencies were ready to meet this new challenge and once the election outcome was clear, were also ready to meet the needs of the incoming Trump team.

The career-led work was aided by senior Biden political appointees, who set the tone for a responsible, career-led transition early on. White House Chief of Staff Jeff Zients led a kickoff for transition preparations in May 2024, throwing his political heft behind the importance of transition work. Interagency coordinating units like the White House Transition Coordinating Council and Agency Transition Directors Council met regularly, worked well and were particularly useful for discussing best practices for handling the cycle’s unusual circumstances and new legislation. “ABC” meetings, which convened the agencies, boards and commissions too small to be included in the ATDC meetings, were new this cycle and proved useful for supporting agencies facing unique challenges.

Agency transition officials cited the benefit of strong support for these entities from the political leadership, such as the OMB deputy director for management and the OMB associate director for performance and personnel management. Because these political leaders chaired the transition convening groups, they could provide valuable political cover and reemphasized the administration’s ongoing support for nonpartisan transition activities.

In future transition cycles, career officials should play a leading role to emphasize the nonpartisan nature of transitions. Political officials in the outgoing administration should remain neutral and provide support when needed to aid their work.

Use the transition period to thoroughly vet and prepare appointees for Day One.

The Trump transition set a brisk early pace of appointee announcements immediately post-election, announcing future officials faster than any other recent president-elect through Dec. 2024. By inauguration, the transition had announced 163 future appointees, second only to Biden’s transition, which had announced 230. Trump’s transition demonstrated a unique focus on Senate-confirmed appointees, which accounted for more than two-thirds of the nominees announced during the formal transition. This suggests an increasing trend of focusing on identifying and vetting nominees early, which should be commended and built upon in future transitions.

Despite the blistering pace of announcements, serious questions arose during the transition period around nominees’ qualifications and vetting. Transition leadership touted loyalty as a key qualification for future appointees and potential job candidates were asked about their voting records and views on the validity of the 2020 election. High profile reversals such as the withdrawal of Matt Gaetz’s attorney general nomination attracted significant media attention. Meanwhile, the team considered eschewing typical security practices by forgoing FBI background checks and using private firms to evaluate appointees’ fitness for security clearances instead. While speed is important to have staff in place on Day One, transitions should balance haste with caution and a thorough evaluation of nominees through designated systems to ensure that officials are not just chosen, but well-qualified, on Jan. 20.

Conclusion

The actions of the Trump transition team, particularly their breaking of norms and declining of services, calls into significant question whether those norms can or should be reinstituted. With that in mind, it is incumbent on Congress to ensure guardrails of ethics, transparency and security are solidified, while other aspects of transition practice are updated and modernized to encourage candidates to accept them. Such guardrails will be particularly essential to ensure a smooth transition in 2028 because of the vast amounts of expertise being lost from government as a result of this administration’s reductions of the federal workforce.

The foundational practices of transition are supported by decades of application and inform the best practices recommended for all stakeholders. During this recent cycle, expert leaders navigated challenges and managed to transfer power from the Biden administration to the second Trump administration, but overall, this year’s process fell short of a gold standard. As the details of transition evolve to keep pace with the ever-changing threats, technology and politics of our modern world, these strong foundations can and should be reviewed, revised and bolstered to offer a relevant road map for future transitions that will ensure security and stability for the American people.

Footnotes
  • 2. Note: Requirements for disclosures are primarily important for the transition team of the winning candidate.
  • 5. This amendment was made as a direct response to the 2020 transition, during which GSA administrator Emily Murphy came under pressure to ascertain the election result and enable provision of transition services. Under the new system, the GSA administrator does not authorize the start of services but determines when they should stop for all but one candidate.
  • 7. Because the Trump team did not sign the GSA MOU, they did not have to disclose their fundraising totals.
  • 8. In response to significant concerns about onerous and duplicative paperwork requirements, Congress created this bipartisan working group in 2012.
  • 9. Agencies use different titles for these officials, but the PTA mandates that there be a “senior career employee of each agency and senior career employee of each major component and subcomponent of each agency designated under subsection (f)(1) to oversee and implement the activities of the agency, component, or subcomponent relating to the Presidential transition.”
Project Team

Mary Monti
Associate Manager, Center for Presidential Transition and Government Affairs 

 

Georgia Haddad
Senior Manager, Center for Presidential Transition and Government Affairs

 

Sasha Blachman
Associate Manager, Center for Presidential Transition and Government Affairs 

 

Jenny Mattingley
Vice President, Government Affairs

 

Chantelle Renn
Former Senior Manager, Center for Presidential Transition 

Max Stier
CEO, Partnership for Public Service

 

Bob Cohen
Senior Writer and Editor 

 

Sam Donaldson
Vice President, Communications

 

Jason Labuda
Design and Video Content Manager

 

Kristine Simmons
Senior Advisor

 

Troy Thomas
Senior Advisor