The Open Ethics & Influence Data Modernization Act (OEIDMA)

Turning "PDF Transparency" into Real-Time, Auditable Public Infrastructure

Executive Summary

Americans are told that government ethics disclosures are "public." In practice, much of that transparency is paper-thin: records are scattered across websites, published as individual documents (often PDFs), and structured in ways that make it hard to search, compare, or analyze at scale. The result is a system where oversight often depends on slow, expensive, manual work---scraping filings, reading forms one-by-one, filing records requests---rather than quickly spotting patterns that matter, like money + meetings + decisions.^{1 4 15}

This is not a "gotcha" problem. It is an infrastructure problem. If ethics and influence data remains fragmented and unstructured, it will continue to be easiest for insiders to navigate---and hardest for the public to verify. Congress and the executive branch already require substantial disclosure under the Ethics in Government Act and related rules, but the public-facing output is frequently not built like modern data: not standardized, not easily linkable, and not reliably machine-readable.^{5 6 1}

OEIDMA proposes a straightforward modernization: treat ethics and influence records as a public data asset, the same way Congress has treated other transparency domains (like federal spending).^{11 10} Instead of "transparency by document dump," OEIDMA would require:

• One common data standard for ethics and influence records (across branches where feasible).¹

• "Documents + data" publication: keep the official filing, but also publish a structured dataset extract tied to it by a stable identifier.¹

• Bulk downloads + public APIs, plus a simple search interface for non-technical users.^{1 10}

• Timeliness requirements so the public can see whether agencies or branches are posting records quickly---or quietly delaying them.¹

• Missing links for accountability: standardized publication of recusals/waivers and (with safeguards) official calendars/visitor logs for covered senior officials, so oversight can connect access and ethics rules to real-world interactions.¹

• Audits and compliance dashboards, with automatic triggers for late posting or repeated noncompliance.¹

Why this matters: modern accountability is increasingly data-driven. Watchdogs already try to convert disclosures into usable datasets, but the current system forces third parties to do what government could do once, consistently, and transparently.⁴ OEIDMA would lower the cost of oversight, reduce ambiguity, and allow legitimate journalism and public-interest analytics to focus on substance---not data extraction.

Will this reform be popular? There is no high-quality poll asking the public whether they support "machine-readable ethics disclosures with APIs."² But public demand for ethics reforms is consistently high, and closely related measures---like banning congressional stock trading---show overwhelming bipartisan support in reputable surveys.²⁰ Meanwhile, long-run trends show low public trust in government, reinforcing the case for reforms that make accountability verifiable.¹⁹

OEIDMA is a practical, modern reform: it does not presume wrongdoing. It makes verification possible---quickly, fairly, and at scale---so conflicts can be detected and addressed before they become scandals.

The Problem Statement

1) "Disclosure exists" ≠ "Accountability works"

Federal ethics and financial disclosure frameworks require significant reporting, but the public-facing system often outputs disclosures as discrete documents, frequently in formats that frustrate automated analysis.^{1 5 6 15} This creates a structural advantage for sophisticated actors and a structural disadvantage for the public, journalists, and oversight groups who must reconstruct machine-readable datasets from PDFs.

This problem is compounded by volume. GAO reporting indicates the scale of the disclosure ecosystem is massive---on the order of hundreds of thousands of reports annually---making manual review infeasible as a primary accountability mechanism.³

2) Fragmentation across branches and systems

The federal disclosure and ethics ecosystem is not one system; it is multiple systems operating under different authorities and operational constraints. The executive branch has detailed disclosure regulations and supporting systems, while legislative and judicial approaches differ in implementation and public access patterns.^{1 6 13}

Fragmentation produces three predictable failure modes:

• Inconsistent formats (fields, definitions, and reporting categories) prevent longitudinal and cross-institution analysis.¹

• Weak interoperability prevents linking ethics records to other influence datasets in a disciplined way (lobbying, access patterns, recurring organizational relationships).¹

• Timeliness opacity undermines utility: even a "public database" can fail if posting is delayed or inconsistent.¹

3) Policy regression and unresolved privacy design

The STOCK Act's original transparency ambitions included requirements pointing toward searchable, modern disclosure outputs; subsequent amendments narrowed those requirements, reflecting unresolved tensions between transparency and privacy/security risks.^{7 8 9}

The lesson is not "don't modernize." The lesson is: modernization must be privacy-aware and engineered, with clear redaction rules, auditable exemptions, and narrowly tailored data fields that protect safety while preserving accountability.^{9 14}

The Proposed Reform

OEIDMA is best understood as a data infrastructure statute: it standardizes, publishes, and audits ethics-and-influence records the way modern government publishes other public datasets.^{1 2}

A. Scope: Covered Entities and Records

OEIDMA aligns with existing disclosure frameworks while modernizing publication.

Covered entities (conceptual model):

• Executive branch agencies and covered filers under existing disclosure rules.⁶

• Legislative branch disclosure publishing offices and ethics enforcement bodies (publication modernization without redefining underlying ethics rules).¹³

• Judicial branch publication systems for covered disclosures (modernization of format, timeliness, interoperability).¹

Covered records (three buckets):

1. Financial disclosure data: assets, liabilities, gifts, travel, outside positions, and periodic transaction reporting where applicable.^{5 6 7}

2. Ethics actions: recusals, waivers/authorizations, and (where already required) ethics agreements---published in structured form with clear redaction codes.¹

3. Influence logs: official calendars and visitor logs for covered senior officials, with national-security and personal-privacy carveouts and standardized "reason for redaction" codes.¹

B. Core Mechanics

1) Establish an "Ethics & Influence Data Standard" (EIDS)

OEIDMA creates a versioned, open schema (JSON + CSV as baseline; XML/XBRL-compatible extensions permitted where useful) with:

• Required fields: filer identity (stable ID), reporting period, asset/liability type, gift/travel details, transaction dates/amounts (where applicable), recusal subject matter, meeting participants/topics (with redaction codes).

• Controlled vocabularies: standardized categories for asset types, relationship types, redaction reasons, and ethics action types.

• Versioning and migration: schema updates managed by a multi-stakeholder working group, with backward-compatible migration tools and clear sunset timelines for deprecated versions.

Design principle: The schema should be usable (simple enough for common oversight queries) but extensible (supporting advanced cross-system joins and edge cases).

2) "Documents + Data" Publication Model

Every covered filing must be published in two parallel streams:

• Official document: the scanned or electronic form (PDF, original format) remains the authoritative legal record.

• Structured data extract: a machine-readable version tied to the official document by a stable identifier (e.g., UUID), published simultaneously or within a strict deadline (e.g., 48 hours).

This dual publication preserves the legal integrity of the original filing while enabling modern oversight tools.

3) Public Infrastructure Requirements

Each publishing entity must provide:

• Bulk downloads: Full dataset exports (updated at least daily) in standard formats (CSV, JSON).

• Public API: RESTful API supporting field-level queries, filtering by date range, entity, transaction type, etc.

• Simple search interface: A no-code web portal for journalists, researchers, and members of the public who are not technical users.

• Documentation: Clear API documentation, data dictionaries, and sample code in multiple programming languages.

Precedent: This approach mirrors requirements under the DATA Act and OPEN Government Data Act.^{10 11}

4) Timeliness and Compliance Dashboards

OEIDMA requires real-time publication of:

• Filing receipts: When a disclosure is received by the ethics office.

• Publication dates: When the structured data and official document are made public.

• Compliance status: Automated flags for late filings, missing data fields, or repeated noncompliance.

Publishing entities must maintain a public compliance dashboard showing aggregate statistics on filing timeliness, redaction frequency, and system uptime. This creates accountability for the accountability system itself.

5) Privacy, Security, and Redaction

OEIDMA incorporates lessons from STOCK Act amendments⁸ and constitutional precedent¹⁴:

• Mandatory redaction fields: Personally identifying information (home addresses, phone numbers, account numbers, minor children's names) must be redacted automatically.

• Discretionary redaction codes: National security classifications, ongoing law enforcement investigations, or safety concerns require a standardized "reason for redaction" code published alongside the redacted data.

• Audit trail: All redactions must be logged and periodically reviewed by inspectors general to prevent overuse.

• Limited retrospective application: The structured data requirement applies only to new filings; existing archives may be converted on a best-effort, prioritized basis (e.g., senior officials first).

This framework balances transparency with legitimate privacy and security needs.

C. Implementation

Phase 1: Schema Development and Pilot (Year 1)

• Convene a multi-stakeholder working group (ethics offices, OGE, Congressional ethics committees, judiciary representatives, civil society, academic experts).

• Draft EIDS schema v1.0, publish for public comment, finalize.

• Select 2-3 pilot agencies/offices to test publication workflows.

Phase 2: Rollout and Integration (Years 2-3)

• Executive branch: OGE coordinates phased rollout across agencies, with cabinet-level departments first.

• Legislative branch: House and Senate ethics committees modernize publication systems (or contract with a shared service provider).

• Judicial branch: Administrative Office of U.S. Courts implements structured publication for judicial financial disclosures.

Phase 3: Cross-System Interoperability (Year 4+)

• Enable cross-branch queries (e.g., "all ethics waivers granted to former lobbyists in the past 5 years").

• Integrate with related datasets (lobbying registration, campaign finance, procurement) via shared identifiers where legally permissible.

• Publish annual compliance reports and schema improvement recommendations.

Impact Analysis

1) Oversight effectiveness and public-value gains

Lower oversight costs: By publishing structured data once, government reduces duplicative third-party extraction efforts and improves baseline data quality.⁴

Faster detection: Standardization and APIs enable rapid identification of anomalies, trends, and repeat patterns across time.¹

Fairer accountability: A standardized public dataset reduces selective access and makes oversight less dependent on insider knowledge or specialized scraping tooling.^{1 15}

2) Economic and administrative impact

OEIDMA is an IT modernization and data-governance bill. The principal costs are:

• schema development and versioning,
• ETL/publishing pipelines,
• redaction tooling and compliance processes,
• training and operational staffing.

Precedent suggests these costs are manageable when phased and standardized: Congress has already enacted transparency modernization in other domains through government-wide standards and machine-readable publication requirements.^{11 12 10}

A pragmatic approach is a staged rollout:

• Phase 1: financial disclosures "documents + data," standard schema, bulk downloads, basic API.¹

• Phase 2: waivers/recusals standardized and published.¹

• Phase 3: calendars/visitor logs with carveouts and redaction codes.¹

• Phase 4: interoperability crosswalks and advanced compliance analytics.^{1 12}

3) Legal and policy precedents

OEIDMA builds on strong statutory precedent for open, machine-readable government data:

• OPEN Government Data Act (open data as a default expectation for agencies).¹⁰

• DATA Act (government-wide data standards for transparency datasets).¹¹

• Financial Data Transparency Act (machine-readable financial regulatory data with common identifiers).¹²

• State precedents: Florida's searchable ethics disclosure system demonstrates feasibility at scale.²⁵

• International precedents: UK Parliament's Register of Members' Financial Interests and the EU Transparency Register show mature, multi-institution transparency systems.^{17 18}

4) Public support (proxy evidence)

There is no direct polling on "machine-readable ethics disclosures."² However:

• Related measures: Polls show high support for banning congressional stock trading, implying strong public appetite for stronger, easier-to-verify accountability rules.²⁰

• Trust context: long-run measures show low trust in federal government, strengthening the rationale for reforms that make accountability verifiable.¹⁹

A defensible public-support claim for OEIDMA is therefore conditional: high likelihood of clearing 65% support, but with an explicit caveat that the estimate is inferred from related measures rather than direct polling.^{2 20 19}

Conclusion

OEIDMA addresses a foundational weakness in modern accountability: our ethics rules are enforced in a world of PDFs, while influence, finance, and access operate at digital speed. Today's fragmented, document-based transparency makes oversight slow and expensive, and it makes it harder for the public to separate genuine conflicts from noise.

OEIDMA is not a partisan weapon and it does not presume misconduct. It is a modernization act that builds the missing public infrastructure: a common data standard, documents-plus-data publishing, APIs and bulk downloads, timeliness requirements, and auditable privacy protections.^{1 2}

In an era of low trust and high information velocity, the choice is not between transparency and privacy. The choice is between engineered transparency that respects privacy---and performative transparency that cannot be analyzed until after the damage is done.^{9 1 10}

OEIDMA is an upgrade from "disclosure exists" to "accountability works."

Reference List

1. Document A (OEIDMA policy mechanics draft) — Open Ethics & Influence Data Modernization Act (OEIDMA). Internal working document.
2. Document B (Source Library & evidence map) — Open-Source Ethics & Financial Data Modernization: Comprehensive Source Library. Internal working document.
3. U.S. Government Accountability Office — GAO-25-107039: Financial Disclosure: Updates Are Needed to the Public Reporting Requirements (2025). https://www.gao.gov/products/gao-25-107039
4. OpenSecrets — Personal Financial Disclosures Database and Methodology. https://www.opensecrets.org/personal-finances
5. U.S. Code — Ethics in Government Act of 1978 (as amended), 5 U.S.C. §§ 13101–13111. https://uscode.house.gov/view.xhtml?path=/prelim@title5/partIV/chapter131&edition=prelim
6. eCFR / U.S. Office of Government Ethics — 5 CFR Part 2634: Executive Branch Financial Disclosure. https://www.ecfr.gov/current/title-5/chapter-XVI/subchapter-B/part-2634
7. Congress.gov — STOCK Act of 2012 (Pub. L. 112-105 / S.2038). https://www.congress.gov/bill/112th-congress/senate-bill/2038
8. Congress.gov — STOCK Act 2013 Amendments (Pub. L. 113-7 / S.716). https://www.congress.gov/bill/113th-congress/senate-bill/716
9. National Academy of Public Administration — The STOCK Act: An Independent Review (2013). https://napawash.org/academy-studies/the-stock-act-an-independent-review
10. Congress.gov — OPEN Government Data Act (H.R. 4174 / enacted 2019; codified in 44 U.S.C.). https://www.congress.gov/bill/115th-congress/house-bill/4174
11. Congress.gov — Digital Accountability and Transparency Act (DATA Act) of 2014 (S.994 / Pub. L. 113-101). https://www.congress.gov/bill/113th-congress/senate-bill/994
12. Congress.gov — Financial Data Transparency Act of 2022 (S.4295 / Pub. L. 117-263, Title LVIII). https://www.congress.gov/bill/117th-congress/senate-bill/4295/text
13. Congressional Research Service — R47320: Financial Disclosure in the U.S. Government: Frequently Asked Questions. https://www.congress.gov/crs-product/R47320
14. Congressional Research Service — IF12388: First Amendment Limitations on Disclosure Requirements. https://www.congress.gov/crs-product/IF12388
15. Campaign Legal Center — How Congress Hides Stock Holdings in Plain Sight (2022). https://campaignlegal.org/update/how-congress-hides-stock-holdings-plain-sight
16. Congress.gov — H.R. 8597: Transparency in Government Act of 2024 (machine-readable disclosure proposal). https://www.congress.gov/bill/118th-congress/house-bill/8597/text
17. UK Parliament — Register of Members' Financial Interests (transparency system precedent). https://www.parliament.uk/mps-lords-and-offices/standards-and-financial-interests/parliamentary-commissioner-for-standards/registers-of-interests/
18. European Union — EU Transparency Register (multi-institution transparency precedent). https://transparency-register.europa.eu/
19. Pew Research Center — Public Trust in Government: 1958–2025 (context on trust). https://www.pewresearch.org/politics/2025/12/04/public-trust-in-government-1958-2025/
20. Program for Public Consultation (University of Maryland) — Congressional Stock Trading Survey (proxy public support). https://publicconsultation.org/united-states/stock-trading-by-members-of-congress/
21. Open Data Charter — Principles for Open Data (best practices framework). https://opendatacharter.org/principles/
22. World Bank — Open Government Data Toolkit (open data + anti-corruption case evidence and implementation guidance). https://opendatatoolkit.worldbank.org/
23. Government Information Quarterly / ScienceDirect — "Transparency-by-design: What is the role of open data portals?" (design evidence: machine-readable + human-readable). https://www.sciencedirect.com/science/article/abs/pii/S0736585321000447
24. Harvard Journal on Legislation (2025) — "Congressional Stock Trading Ban Challenges Transparency-Based Remedies" (limits of transparency-only approaches). https://journals.law.harvard.edu/jol/2025/11/03/congressional-stock-trading-ban-challenges/
25. Florida Commission on Ethics — Electronic Financial Disclosure System (state-level searchable disclosure precedent). https://disclosure.floridaethics.gov/PublicSearch/Filings

Changelog

• December 27, 2025 — Updated OEIDMA report with improved citation links and anchor navigation