BIS Funded 585 Positions. Its Covered Workforce Has Since Fallen to 433.

Two days after the Bureau of Industry and Security announced its latest export-enforcement settlement, the federal office responsible for policing strategic technology still faced a more basic unresolved question: does it have the workforce it needs?

BIS has become one of Washington's principal instruments for restricting the movement of advanced semiconductors, manufacturing equipment and other dual-use technology. It reviews export-license applications, maintains lists of restricted parties, checks foreign end users and investigates violations. Its rules reach companies and supply chains around the world. Its decisions also pass through an interagency process involving the departments of Defense, Energy and State.

Congress financed a substantial expansion. BIS grew from 403 funded positions in fiscal 2013 to 585 in fiscal 2024, according to the Government Accountability Office. Appropriations rose from $93.6 million to $191 million over the same period, or 52% after GAO adjusted the earlier figure to 2024 dollars.

But funded positions are not the same as employees on board. FederalHiringData found that the bureau's covered federal headcount reached 528 in late 2024 and then fell to 433 in June 2026, a decline of 95 employees, or 18%. The contraction was concentrated in occupational series used for licensing, industry analysis and compliance. Public recruiting also remained far below its 2023 and 2024 pace.

The result is not proof that BIS is too small. Application volume fell in 2025, criminal-investigator headcount held steady at the endpoints examined, engineering increased and the administration proposed a large enforcement expansion. The public record does not contain a validated staffing target against which 433 employees can be judged.

That is the central problem. GAO said BIS had not assessed its long-term workforce needs by size and composition. As of May 2026, Commerce had provided no implementation update. The United States expanded the institution, but the bureau still has not published the plan needed to show whether its people are aligned with the work.

BIS expanded late in a long period of relatively flat staffing

FederalHiringData reconstructed BIS covered employee headcount from Office of Personnel Management records. The series uses September observations from 1998 through 2025 and June 2026, the latest public partial-year point.

BIS had 408 covered employees in September 2000. Headcount generally remained between the low 300s and high 300s for the next two decades. It fell to 324 in September 2009, climbed to 386 in September 2021 and then rose sharply: 456 in September 2023 and 527 in September 2024.

The late expansion was real. September 2024 headcount was 49% higher than in September 2019. It also arrived after export controls had taken on a much larger role in policy toward China and Russia.

Then the direction changed. Covered headcount fell to 443 in September 2025. It declined to 417 in May 2026 before rising to 433 in June.

The chart is a headcount measure, not full-time-equivalent employment. It excludes contractors and people outside OPM's covered personnel data. The June 2026 point is an onboard snapshot, not a full-year average. Those distinctions matter because budget documents use positions and FTE while public personnel records count covered employees.

The difference is visible when the two series are placed together.

In fiscal 2024, GAO counted 585 funded positions. OPM recorded 527 covered employees in September and 528 in both November and December. GAO separately reported that 52 funded positions, about 9%, were vacant at the end of fiscal 2024. The measures are not expected to match exactly, but together they show that authorization and funding did not automatically become onboard capacity.

The distinction also prevents a misleading comparison. Saying that BIS “grew to 585 employees” would be wrong. It grew to 585 funded positions. The largest covered headcount FederalHiringData found was 528.

Most of the new positions did not go to licensing

The 182-position increase was distributed unevenly.

Export Administration, the organization most directly associated with licensing and export-control policy, moved from 217 funded positions in fiscal 2013 to 218 in fiscal 2024. Export Enforcement grew from 171 to 247, adding 76. A new Office of Information and Communications Technology and Services, or ICTS, accounted for 104 positions after its creation in fiscal 2023. Management and support made up the remaining small difference.

The ICTS office does consequential national-security work, including implementing rules aimed at risks from foreign information and communications technology. Its positions are not idle capacity available for license review. Counting the whole bureau increase as growth in the traditional export-control workforce would obscure where the money went.

The enforcement increase was also tied to a specific period. GAO said about $58 million of BIS's $97 million nominal funding increase arrived in fiscal 2022 and 2023. Congress provided resources to implement and enforce controls responding to Russia's invasion of Ukraine and to create ICTS. BIS converted 56 positions initially supported by emergency Ukraine supplemental funding into permanent vacant positions: 26 in Export Enforcement and 30 in Export Administration.

This history explains why the overall position total rose so abruptly. It does not establish what the bureau needs over the next five or ten years. GAO found that the last bureau-wide workforce-planning effort was in 2016. BIS instead assessed staffing through its annual budget process.

Annual budgets can identify immediate requests. A long-term plan asks a different set of questions: which occupations are needed, where retirements and departures create risk, how training pipelines work, and whether new technology controls change the balance between policy, engineering, licensing, intelligence and enforcement.

The workload grew, but not every measure rose

GAO compared seven BIS workload measures between fiscal 2013 and fiscal 2023. Five increased and two fell.

Entity List additions increased from 185 to 465, up 151%. License applications processed rose from 24,782 to 37,943, up 53%. Licensing determinations referred for interagency resolution increased from 2,222 to 3,411, also about 54%. End-use checks rose 46%, and a combined measure of deterrence, prevention and charged cases increased 32%.

Commodity-classification requests fell from 5,577 to 3,700. BIS recommendations to State on commodity-jurisdiction requests fell from 1,203 to 191, a change connected in part to items transferred from the U.S. Munitions List to the Commerce Control List.

These measures cannot be added into a single workload total. An Entity List addition, license application, end-use check and enforcement case require different skills and amounts of staff time. GAO also cautioned that BIS metrics do not measure the time or staffing needed to complete each activity.

Licenses themselves became more complicated. In a March 2025 presentation, BIS said it was processing more than 40,000 applications a year in recent years and that newer rules operated at the leading edge of technology, used broader extraterritorial authorities, applied to a larger Entity List and reached complex supply chains.

The annual totals later changed. BIS reported approximately 30,500 applications in calendar 2025, down from about 40,700 in 2024. The average processing time was 62 days, compared with 60 days in 2024. BIS noted that a 43-day government shutdown slowed work at Commerce and partner agencies during the fourth quarter of 2025.

Earlier published processing-time data show another shift, though the series has a coverage break. For 2018 through 2022, the published average excluded deemed-export applications. The 2023 through 2025 annual figures describe the applications BIS reported more broadly.

The 2025 decline in volume is important counterevidence. It would be unreasonable to imply that every visible workload measure moved upward continuously. But fewer applications do not necessarily mean proportionally less work. License policy, complexity, interagency review, end-user restrictions and the composition of applications all matter. Public data do not provide staff-hours per application.

Processing time is also an end-to-end measure, not a stopwatch on BIS employees alone. Executive Order 12981 sets an interagency structure in which Commerce refers applications to Defense, Energy and State when appropriate. Cases can move to the Operating Committee and, if disagreement remains, to a higher-level advisory committee. BIS reported 614 Operating Committee cases and 45 further escalations in fiscal 2023. Those reviews may represent especially consequential or contested applications, but their counts do not identify the hours each agency spent. A workforce plan should therefore connect BIS staffing to the portions of the process it controls while acknowledging delays and expertise elsewhere in government.

Enforcement expanded on a separate track

BIS's enforcement activity also intensified. Its fiscal 2025 annual report listed 53 administrative enforcement actions, 65 criminal convictions involving individuals and companies, 455 warning letters, 705 detentions, 232 seizures and 1,840 end-use checks in 73 countries. It reported 162 indictments and arrests in calendar 2025, compared with 112 in 2024.

The bureau imposed $108 million in administrative penalties in calendar 2025 and reported $216 million in criminal fines, forfeitures and restitution, compared with $10 million and $6 million respectively in 2024. Those dollar totals reflect the facts and statutory exposure of particular cases. They are not a measure of employee productivity.

BIS continued announcing administrative orders in 2026. Its public export-violations list included the Aug. 24 Container Manufacturing settlement, an Aug. 14 order involving Plexon, a June 16 Robert Bosch settlement and several earlier semiconductor, aviation and technology cases. The list demonstrates current activity, not a standardized annual case-rate series.

The administration also requested a much larger enforcement organization in its fiscal 2026 budget submission: 473 Export Enforcement positions, 226 above the fiscal 2024 level, and 416 FTE. The proposal said 193 additional special agents would reduce average field-agent caseloads from 23 toward the six-to-ten range it cited for comparable FBI and Homeland Security Investigations work. It also proposed adding 18 overseas Export Control Officers to an existing network of 12.

A budget request is not an enacted workforce. It describes what the administration sought and why. FederalHiringData did not treat the proposed positions as current employees.

The public personnel data show a narrower form of counterevidence. BIS had 143 employees in OPM's Criminal Investigation series in January 2025 and 143 in June 2026. That endpoint was stable even as several other large series fell.

Licensing and compliance occupations contracted

OPM's occupational series cannot identify every employee's office or exact assignment. A General Business and Industry specialist could work on policy, licensing or another program. A General Inspection, Investigation, Enforcement and Compliance employee could perform several forms of oversight. The series are useful as transparent bureau-wide proxies, not as an internal organization chart.

Between January 2025 and June 2026, General Business and Industry fell from 126 employees to 97, down 29, or 23%. General Inspection, Investigation, Enforcement and Compliance fell from 90 to 59, down 31, or 34%. Miscellaneous Administration and Program fell from 44 to 32.

General Engineering moved in the other direction, rising from 21 to 29. The Attorney series went from no publishable count in the January data to three in June. Information Technology Management slipped from 19 to 18. Smaller technical series, including computer and electronics engineering, remained in the single digits.

These shifts do not prove that licensing output deteriorated or an enforcement case went unworked. They show that the bureau's workforce composition changed during a period when BIS was still administering complex controls. The missing long-term plan is what should connect staffing supply to mission demand.

Personnel-action records help explain the timing. BIS recorded 133 accessions and 43 separations in 2023, then 93 and 52 in 2024. In 2025, the pattern reversed: 39 accessions and 134 separations. During January through June 2026, the records show 82 accessions and 38 separations, evidence of a hiring rebound that is consistent with the headcount increase from May to June.

Those are personnel actions, not necessarily unique people. They also do not identify which internal office received each person. An accession can reflect an appointment action; a separation can reflect a departure action. The data support a rapid 2025 contraction and a partial 2026 response, not a claim about motive.

Public recruiting narrowed, then changed shape

FederalHiringData counted distinct BIS announcements opened from Jan. 1 through Aug. 26 in each year, using the same partial-year window to avoid comparing 2026 with full prior years.

The bureau posted 87 announcements in that window in 2023 and 78 in 2024. The count fell to 21 in 2025 and remained 21 through Aug. 26, 2026.

An announcement is not a vacancy or a hire. One control number can advertise multiple positions, locations or grades. Another can be canceled or produce no selection. The archive measures the public recruiting channel.

The 2026 titles show targeted activity. BIS advertised directors for Exporter Services and Export Enforcement, supervisory criminal-investigator positions, six Antiboycott Compliance Specialist announcements, an Export Policy Analyst, an Export Compliance Specialist, three technology positions and a General Engineer. The technology postings included an IT Cybersecurity Specialist and two IT Product Manager roles.

Related research

Put this finding in context

All articles

Data investigations/August 25, 2026

FDIC Cut 1,360 Authorized Positions as Insured Deposits Passed $11 Trillion

Covered FDIC headcount fell 23.6%, including 600 bank examiners, while the insured system grew larger and more concentrated.

Data investigations/August 24, 2026

NOAA Lost 2,630 Employees. Its Technical Workforce Was Still Thinner in June 2026.

NOAA's covered workforce fell 21.1% from December 2024 through June 2026, with broad losses across science and technical occupations and only selective rebuilding.

This is not evidence of a large semiconductor-specific hiring drive. Only four same-window 2026 announcements fell into the engineering and technical group, the same count as in 2025 and below 14 in 2024. Public titles also cannot reveal every technical assignment. A Business and Industry specialist may work on semiconductor controls without “chip” appearing in the title.

The staffing mix therefore cannot be inferred from title keywords alone. It can be assessed only through a workforce plan that identifies competencies and links them to anticipated work.

Interagency review does not enlarge the BIS headcount

Export-license review is an interagency process. Defense, Energy and State review applications alongside Commerce when appropriate. GAO found that BIS did not always provide the reviewing agencies ready access to all relevant application information and sometimes changed or removed agreed license conditions without consultation.

GAO issued three recommendations on information access, consultation and written guidance in addition to the workforce-planning recommendation. All four remained open when FederalHiringData rechecked the recommendation page on Aug. 26, 2026.

The other agencies contribute federal labor to the licensing system, but their employees are not part of BIS's workforce. FederalHiringData did not fold them into the 433-person count. Nor did it estimate their export-control staffing, because public occupational data cannot reliably isolate the share of a Defense, Energy or State employee's work devoted to BIS license review.

That boundary matters in both directions. BIS is not the only federal organization doing the work. At the same time, the existence of partner-agency reviewers does not fill a vacant BIS licensing, technical or coordination position.

The missing plan is now the measurable finding

GAO's priority recommendation asks Commerce to ensure that BIS develops a long-term workforce plan specifying the resources and personnel needed for its growing workload. Commerce concurred when the report was issued in June 2025. GAO says Commerce told it in December 2025 that the department did not plan to respond further and confirmed in May 2026 that it had no implementation update.

That does not mean BIS stopped hiring or stopped working. The bureau completed enforcement actions, processed licenses, performed end-use checks, added technical and investigative staff, and proposed a major enforcement expansion. The covered headcount's June increase and 2026 accessions are evidence that the organization was not simply frozen.

It means the public cannot evaluate adequacy with a defensible denominator.

A credible plan would distinguish at least four separate capacity questions. Export Administration needs licensing officers, policy analysts, industry specialists, engineers and experts able to understand emerging technologies. Export Enforcement needs agents, analysts and overseas officers. ICTS has a distinct supply-chain security mission. Management, legal, budget and technology staff support the whole bureau. The plan would also explain how Defense, Energy and State review capacity affects the end-to-end process without counting those employees as BIS staff.

It would then connect those people to workload: applications by complexity, review time at each stage, interagency escalations, end-use checks, investigations, compliance outreach, new rules and expected turnover. Raw totals alone cannot do that.

The 585 funded positions show that Congress and Commerce recognized a need for more capacity. The 433 covered employees show that actual staffing has since moved in the other direction. The occupation and recruiting data show that the contraction was not evenly distributed.

The United States may decide to broaden, narrow or redirect export controls. That is a policy choice outside this analysis. Whatever the policy, the administrative question remains concrete: how many people, with which skills, are required to license lawful trade and enforce the restrictions the government adopts?

BIS has not published the answer. Until it does, a growing list of controls and settlements can demonstrate activity, but not whether the workforce behind them is sufficient.

Methodology and limitations

FederalHiringData analyzed OPM legacy FedScope and OPM Federal Workforce Data for BIS agency subelement CM67. The long-run series uses September observations from 1998 through 2025 and June 2026. Headcount represents covered employees, not FTE, funded positions or contractors.

Funded positions, office allocations and fiscal 2013-to-2023 workload endpoints come from GAO-25-107431. Appropriation figures are budget authority, not obligations or outlays. Office totals are funded positions, not verified onboard employees.

Occupation comparisons use exact OPM series at January 2025 and June 2026. They do not reveal office assignment or competency. Personnel-action counts may not equal unique people.

Historical recruiting uses distinct USAJOBS control numbers opened Jan. 1 through Aug. 26 in each year from 2018 through 2026. FederalHiringData historical USAJOBS coverage begins in March 2017. Announcements are not vacancies, applicants, selections or hires.

Licensing and enforcement statistics come from BIS publications. Definitions and coverage differ across series; the differences are stated rather than smoothed. Penalty amounts are not treated as productivity. The analysis does not estimate contractor headcount, a staffing requirement, the size of partner-agency review teams or the operational effect of any specific workforce change.

Sources and further reading

• GAO-25-107431: Export Controls — Commerce Should Improve Workforce Planning and Information Sharing
• BIS fiscal 2025 annual report
• BIS fiscal 2023 annual report
• BIS fiscal 2026 congressional budget submission
• BIS export violations and administrative orders
• OPM Federal Workforce Data
• FederalHiringData historical job research
• Browse federal workforce statistics
• Read more FederalHiringData investigations