Introduction: why this is common sense
A digital wallet that holds a verified learning and employment record, connected to a talent marketplace and grounded in credential registry data, is common sense for one reason. The federal government has already decided, many times over, that it needs what this infrastructure provides.
This paper inventories more than 70 federal actions: executive orders, statutes, pending bills, and agency initiatives. They come from different authorities and serve different populations. Read together, they ask the same handful of questions again and again.
| The question federal policy keeps asking | Where it is asked | How it is answered today | How a wallet, LER, registry, and marketplace are designed to answer it |
|---|---|---|---|
| Can this person do the job? | EO 13932, EO 14170, the Merit Hiring Plan, the Chance to Compete Act, the Skills-Based Federal Contracting Act | Degree proxies and self-rating questionnaires, both of which federal policy is retiring | The applicant presents skills and credentials that the issuer has verified |
| Is this credential worth public money? | Workforce Pell, EO 14278, EO 14279, the 529 expansion, America's Talent Strategy | Separate provider lists and directories that do not connect | One open, machine-readable description of each credential, its skills, and its outcomes |
| What did this service member learn, and what is it worth in a civilian job? | 10 U.S.C. 1143 and 2015, FY 2025 NDAA section 574, EO 14426 | Paper records and manual translation of military training | A competency record in a standard digital format that employers and licensing boards can read |
| Is this license valid in the new state? | The Military Spouse Licensing Relief Act, EO 14417, interstate compact authorities | Reapplication and document requests after each move | A portable license record the spouse carries and the new state can check |
| Is this person working, training, or in school this month? | Medicaid community engagement, SNAP work requirements, TANF outcome pilots | Monthly paperwork from the individual and case-by-case data matching by the state | Participation and completion records the individual already holds and can share |
| What does a young person leaving foster care have to show for their education and work? | EO 14359, the Chafee program, the pending Fostering the Future Act | Records scattered across placements, schools, and agencies | One record that belongs to the young person and travels with them |
| Where are the skilled workers for AI, quantum, and the trades? | America's AI Action Plan, EO 14277, EO 14413, the one million apprentice goal | Job postings and resumes matched by keyword | Verified skills matched to skills-based job descriptions in real time |
Seven questions, one answer. That is the common-sense case. The alternative is for each program to build its own method of verification, which asks the same citizen to prove the same facts to several agencies in several formats.
The benefits follow from that single observation.
- Build once, serve many mandates. A state that stands up this infrastructure for Workforce Pell is positioned to use it for WIOA, Medicaid verification, military transition, and foster youth services.
- The individual owns the record. People carry their verified achievements from school to service to work, and decide what to share and with whom.
- Less paperwork for citizens and caseworkers. A record verified once at the source does not need to be re-documented for each program.
- Trust is built into the record. Issuer-signed credentials are designed to be checked at the source and to resist alteration.
- No central federal database. Individually held records are consistent with the data minimization commitment in the America.gov order.
- It adds to existing systems. Wage records, state longitudinal data systems, provider lists, and military and child welfare systems remain the systems of record. This infrastructure is designed to connect them.
- The funding path already exists. Labor guidance permits and encourages use of the WIOA Governor's Reserve, and Education has made talent marketplaces a grant priority.
- Better data for AI. AI tools that match people to opportunity are only as reliable as the credential and skills data they reason over.
The sections that follow document each authority so that readers in every Department can find their own mandates in the record.
Executive summary
Federal policy now requires, across hiring, training, benefits, and military transition, that someone be able to verify what a person knows and can do. Digital wallets, learning and employment records (LERs), credential registries, and talent marketplaces are the infrastructure designed to meet that requirement. This paper inventories the executive orders, statutes, pending bills, and agency actions that make them relevant to the White House and the Departments of Education, Labor, War, and Health and Human Services.
Six findings:
- Executive orders set the outcomes, not the tools. No executive order names LERs, wallets, registries, or talent marketplaces. The orders require skills-based federal hiring, one million apprentices, credential outcome transparency, integrated data, and skills-matched transitions for service members and foster youth.
- Enacted law creates the demand. Workforce Pell requires governors to certify that credentials are stackable, portable, and in demand. The Chance to Compete Act puts skills-based federal hiring in statute. The FY 2025 NDAA requires a standardized competency record for every separating service member. Medicaid community engagement requires states to verify education and training by January 1, 2027.
- Agency guidance since January 2026 names the components directly. Labor's TEGL 07-25 and TEGL 04-26 encourage states to build talent marketplaces composed of LERs, credential registries, and skills-based job description generators, and to fund them from the Governor's Reserve. Education adopted a formal definition of "talent marketplace" in April 2026 and is running a $15 million state challenge.
- Congress is moving to codify them. The MATCH Act of 2026 (H.R. 8183), which would define all three terms in WIOA, was ordered reported 33 to 0 in July 2026. The Skills-Based Federal Contracting Act cleared Congress on September 30, 2026.
- The gaps are specific and fixable. Wallets appear in federal identity policy but not in workforce policy. Open standards are cited once. War and HHS hold mandates that depend on verified records but have not yet referenced the architecture Labor and Education are funding.
- The White House is the missing catalyst. Progress depends on guidance, grant cycles, and a bill awaiting floor action. Trump Accounts went from enactment to national launch in twelve months with presidential backing and named sponsors. The same approach could put a digital wallet in the hands of every American.
The opportunity is alignment. Four Departments are approaching the same individual through different programs. A shared set of definitions and open standards would let a state build this infrastructure once and serve all of them.
The four components and how they fit together
Federal documents now treat these four components as one system, most often under the single label "talent marketplace." Each does a different job, and each depends on the others.
| Component | What it is | What it depends on | Where federal text defines or names it |
|---|---|---|---|
| Credential registry | A public, machine-readable description of credentials: the skills, competencies, outcomes, cost, and provider behind each one. This is the grounding data that makes a credential interpretable by people and by software. | Open, linked data formats such as the Credential Transparency Description Language (CTDL) | Education final priority (91 FR 18780); Labor TEGL 07-25 and TEGL 04-26; Labor notice on linked open data (91 FR 53648); pending H.R. 8183 |
| Learning and employment record (LER) | A digital, machine-readable, verifiable record of what an individual has learned and done, controlled by the individual. | Issuers that verify achievements; registry data that explains what each credential means | Labor TEGL 01-26 (footnote citing W3C Verifiable Credentials and CTDL); Education final priority; Labor Strategic Plan FY 2026 to 2030; pending H.R. 8183 and H.R. 8210 |
| Digital wallet | The individual's tool for holding verified records and presenting selected parts of them to an employer, school, or agency. | Open credential standards; identity proofing | NIST SP 800-63-4 ("subscriber-controlled wallets"); TSA mobile driver's license rule (89 FR 85340) |
| Talent marketplace | The matching layer: employers describe jobs in skills terms, individuals present verified skills, and providers see demand. | All three components above, plus skills taxonomies such as O*NET | Education final priority (formal definition); Labor TEGL 07-25 and TEGL 04-26; pending H.R. 8183 and H.R. 8210 |
The logic runs in one direction. A registry without wallets is a catalog nobody carries. A wallet without registry data holds credentials that software cannot interpret. A marketplace without both falls back on self-reported resumes and keyword matching, which is the condition the federal hiring reforms described below are designed to move away from.
The quality of the grounding data matters more as agencies adopt AI. Education's April 2026 definition of a talent marketplace expressly includes the use of artificial intelligence to translate learning into competency statements. An AI system that matches people to jobs is only as reliable as the credential and skills data it reasons over. Structured registry data and issuer-verified records are designed to give those systems facts instead of inferences.
Executive orders and presidential actions
No executive order names learning and employment records, digital wallets, credential registries, or talent marketplaces. What the orders do is set the outcomes that those components are designed to deliver: hiring on demonstrated skill, credentials with transparent value, one million apprentices, integrated data, and faster transitions for service members and foster youth.
Skills-based hiring in the federal government
| Action | Date | What it directs | Why it matters here |
|---|---|---|---|
| EO 13932, Modernizing and Reforming the Assessment and Hiring of Federal Job Candidates | June 26, 2020 | Limits minimum education requirements to positions where a degree is legally required. Assessments must measure competencies, not educational attainment or self-ratings alone. | Establishes skills, not degrees, as the federal hiring standard. Verified skills records are the evidence that standard requires. |
| EO 14170, Reforming the Federal Hiring Process and Restoring Merit to Government Service | Jan. 20, 2025 | Requires a Federal Hiring Plan that implements technical and alternative assessments, reduces time-to-hire below 80 days, and uses data analytics and digital platforms. | Calls for digital platforms and faster verification of qualifications. |
| Merit Hiring Plan (Domestic Policy Council and OPM memorandum) | May 29, 2025 | Removes unnecessary degree requirements, requires skills-based assessments, phases out self-assessment questionnaires for ranking, and targets recruiting at community colleges, trade schools, and veterans. | Self-attestation is being retired. Issuer-verified records are a ready replacement. |
| EO 14356, Ensuring Continued Accountability in Federal Hiring | Oct. 15, 2025 | Requires all federal hiring to conform to the Merit Hiring Plan. | Makes the skills-based standard binding across agencies. |
Workforce, credentials, and AI
| Action | Date | What it directs | Why it matters here |
|---|---|---|---|
| EO 14278, Preparing Americans for High-Paying Skilled Trade Jobs of the Future | Apr. 23, 2025 | Labor, Commerce, and Education to report on program integration, alternative credentials mapped to employer skill needs, and harmonized performance measures. Plan to surpass 1 million new active apprentices. Outcome transparency for all federal workforce programs. | The source order for America's Talent Strategy. Its outcomes require credential and wage data that can be linked. |
| America's Talent Strategy: Building the Workforce for the Golden Age (Labor, Commerce, Education) | Aug. 12, 2025 | Five pillars: industry-driven strategies, worker mobility, integrated systems, accountability, flexibility and innovation. Names learning and employment records once. Commits to a Credentials of Value scorecard, skills-based practices, unified data systems, and standard APIs for authorized third parties. | The first strategy-level federal reference to LERs in this Administration. The scorecard is a registry use case. |
| EO 14277, Advancing Artificial Intelligence Education for American Youth | Apr. 23, 2025 | Labor to grow AI-related Registered Apprenticeships and encourage WIOA funds for AI skills. Labor and NSF to identify quality AI coursework and industry-recognized certifications. | AI credentials need a trusted way to be described, issued, and verified. |
| EO 14279, Reforming Accreditation to Strengthen Higher Education | Apr. 23, 2025 | Requires program-level student outcome data and addresses credential inflation. | Program-level outcome data is registry data. |
| America's AI Action Plan | July 23, 2025 | AI skills as a priority in CTE, apprenticeship, and training funding. National skill frameworks for priority occupations. An AI Workforce Research Hub at Labor. Rapid retraining for displaced workers. | National skill frameworks are only useful if records and job descriptions reference them consistently. |
| EO 14413, Ushering in the Next Frontier of Quantum Innovation | June 22, 2026 | Labor and NSF to track quantum occupations, skills, and credentials. Labor to prioritize quantum in training and apprenticeship. | A recent example of an order that assumes skills and credentials can be tracked at national scale. |
Data, identity, and service delivery
| Action | Date | What it directs | Why it matters here |
|---|---|---|---|
| EO 14243, Stopping Waste, Fraud, and Abuse by Eliminating Information Silos | Mar. 20, 2025 | Directs removal of barriers to data sharing across agencies and federal access to data from federally funded state programs. | Sets the cross-program data expectation that interoperable records are built to meet. |
| EO 14395, Establishing the Task Force To Eliminate Fraud | Mar. 16, 2026 | Minimum anti-fraud requirements including identity verification and cross-program data sharing with states. Labor and Education are members. | Issuer-signed credentials are designed to resist alteration and to be checked at the source, which self-reported and paper records are not. |
| Streamlining Access to Government Services Through America.gov | Sept. 29, 2026 | A single entry point for high-volume federal services, integrated with Login.gov, with data minimization and no centralized federal system of records on Americans. | The same design principle as an individually held wallet: the citizen presents what is needed, and no central dossier is built. |
| EO 14144 as amended by EO 14306 | Jan. 16 and June 6, 2025 | EO 14144 section 5 encouraged digital identity documents and mobile driver's licenses. EO 14306 struck that section. | Readers should know this history. Federal digital identity work now rests on NIST guidance and the TSA rule, not on an executive order. |
Service members, military spouses, and foster youth
| Action | Date | What it directs | Why it matters here |
|---|---|---|---|
| EO 14426, Accelerating Access to Veterans' Benefits and Employment Opportunities | Sept. 8, 2026 | War and VA to share personnel records permanently and require interoperability in IT contracts. Separating service members to be matched to open jobs that fit their skills, or enrolled in CTE, Labor programs, or registered apprenticeships. | Skills-based matching of separating service members is a talent marketplace function. The order does not specify the record format. |
| EO 14417, Establishing the President's Military Spouse Commission | Aug. 3, 2026 | Advisory commission on spouse employment, education, housing, and healthcare. References license portability. | Portable, verifiable license records are a practical form of license portability. |
| EO 14359, Fostering the Future for American Children and Families | Nov. 13, 2025 | HHS to modernize state child-welfare information systems. An online platform linking transition-age youth to housing, education, employment, and mentoring. Education and Training Vouchers expanded to short-term, credential-awarding programs. | Youth who age out of care often lose their records. An individually held record is designed to travel with them. |
| EO 14347, Restoring the United States Department of War | Sept. 5, 2025 | Authorizes "Department of War" as a secondary title. Statutory names remain controlling. | Explains the usage in this paper. Statutory citations below retain "Department of Defense" where the statute does. |
Enacted statutes
No enacted federal statute uses the terms "learning and employment record," "digital wallet," or "verifiable credential" for education or employment credentials. Enacted law creates the demand: it conditions funding, eligibility, and hiring on facts about credentials and skills that someone must be able to verify.
Workforce and education
| Statute | Relevant provisions | Why it matters here |
|---|---|---|
| Workforce Innovation and Opportunity Act, P.L. 113-128 (2014) | Section 122 governs state eligible training provider lists. Section 116 sets common performance indicators and wage-record matching. Authorizations lapsed after FY 2020; programs continue on annual appropriations. | Provider lists are an early, non-interoperable form of credential registry. State plans under WIOA are the vehicle Labor is now using to encourage talent marketplaces. |
| One Big Beautiful Bill Act, P.L. 119-21 (July 4, 2025): Workforce Pell Grants | Programs of 150 to 599 clock hours over 8 to fewer than 15 weeks. Governors must approve programs as serving high-skill, high-wage, or in-demand sectors. The credential must be stackable and portable across more than one employer. 70 percent completion and 70 percent placement thresholds, and a value-added earnings test. Effective July 1, 2026. | Every eligibility test is a data question about a credential. "Stackable and portable" is a statutory requirement that registries and LERs are designed to demonstrate. |
| Workforce Pell final rule, 91 FR 29254 (May 19, 2026) | Governors certify each program and report completion and placement data. The rule does not require a credential registry, linked open data, or LERs. | The compliance burden falls on governors. The infrastructure choice is left to states. |
| P.L. 119-21, section 70414: 529 qualified postsecondary credentialing expenses | Eligibility turns on named federal lists: state WIOA section 122(d) provider lists, the VA WEAMS directory, the military COOL directory, accredited industry credentials, registered apprenticeship certificates, and occupational licenses. Treasury, consulting Labor, may identify others. | Federal tax law now relies on credential directories to define what counts. The statute does not name any specific registry or data standard. |
| Perkins V, P.L. 115-224 (2018) | Recognized postsecondary credential attainment is an accountability indicator, aligned with WIOA. Administered by Labor under a May 2025 interagency agreement. | CTE accountability depends on knowing which credentials students earned and what they are worth. |
| Consolidated Appropriations Act, 2026, P.L. 119-75 (Feb. 3, 2026) | Kept separate WIOA funding lines and did not adopt the proposed Make America Skilled Again consolidation. ◆ | The existing program structure, including the Governor's Reserve, remains the funding path for now. |
Federal hiring
| Statute | Relevant provisions | Why it matters here |
|---|---|---|
| Chance to Compete Act of 2024, P.L. 118-188 (Dec. 23, 2024) | Requires skills- and competency-based technical assessments for most competitive-service hiring, in place of self-rating questionnaires alone. OPM must study sharing assessments through an online platform. | Puts skills-based federal hiring in statute, beyond the reach of a change in executive policy. |
Service members, veterans, and military spouses
| Statute | Relevant provisions | Why it matters here |
|---|---|---|
| 10 U.S.C. 2015 | Requires a program for members to earn civilian-recognized credentials, with quality standards. | The statutory basis for COOL and service credentialing programs. |
| 10 U.S.C. 1143 | Certification of job skills and experience on separation. Training information made available to states and employers for licensing. SkillBridge. | A long-standing mandate to verify military training for civilian use. |
| FY 2025 NDAA, section 574, P.L. 118-159 | Each member receives at separation a standardized "competency record" of training, certifications, and qualifications, with authentication. A report with state and employer feedback is due Dec. 23, 2026. The statute does not require a digital or machine-readable format. | The closest enacted analogue to a military LER. The format question is open and the report is due this year. |
| Military Spouse Licensing Relief Act, P.L. 117-333, 50 U.S.C. 4025a | A license in good standing is portable to a new state on relocation under orders. | Portability in law still requires proof of the license in practice. |
| 10 U.S.C. 1784(h), made permanent by FY 2025 NDAA section 581 | Authorizes the Department to support interstate licensing compacts through the Council of State Governments. | Compacts and verifiable license records address the same barrier from two sides. |
Health and human services
| Statute | Relevant provisions | Why it matters here |
|---|---|---|
| P.L. 119-21, section 71119: Medicaid community engagement | 80 hours a month of work, community service, a work program including WIOA, or at least half-time education. States must implement by Jan. 1, 2027, and must verify from existing reliable data before asking the individual. | States need a low-burden way to verify education and training participation. A record the individual already holds is one such source. |
| CMS interim final rule, 91 FR 33348 (June 3, 2026) | Defines qualifying educational programs to include higher education, Perkins-defined CTE, and high school equivalency. Names data sources for verification. Does not mention apprenticeship or credential data. | The verification design is being set now. |
| P.L. 119-21, section 10102: SNAP | Extends work requirements for able-bodied adults without dependents to ages 18 to 64. | Expands the population that must document work and training activity. |
| Chafee program, 42 U.S.C. 677 | Education and Training Vouchers for current and former foster youth. | The existing statutory channel for foster youth education and training support. |
| Fiscal Responsibility Act of 2023, P.L. 118-5 | TANF outcome pilots in five states measuring employment and earnings. | Moves TANF toward the same outcome measures the workforce system uses. |
Data and digital identity
| Statute | Relevant provisions | Why it matters here |
|---|---|---|
| Foundations for Evidence-Based Policymaking Act, P.L. 115-435 (2019) | Machine-readable, open-by-default federal data. | The statutory basis for publishing credential data in open formats. |
| REAL ID Modernization Act, P.L. 116-260 (2020), and the TSA final rule, 89 FR 85340 | Brings mobile driver's licenses into the REAL ID framework and incorporates ISO/IEC 18013-5. | Federal acceptance of a credential held in a phone wallet is already law for identity. Skills credentials can follow the same pattern. |
◆ Based on secondary reporting; the law and explanatory statement were not read in full for this paper.
Pending legislation, 119th Congress
Two House bills would write talent marketplaces, credential registries, and learning and employment records into WIOA for the first time. One cleared committee 33 to 0.
Bills that name the components
| Bill | Status | What it would do |
|---|---|---|
| H.R. 8183, MATCH Act of 2026 (Modernizing Access to Talents, Credentials, and Hiring Act). Rep. Owens, with Reps. Moore (UT), Messmer, and McBath. | Introduced Apr. 2, 2026. Ordered reported, as amended, by Education and Workforce on July 21, 2026, 33 to 0. No floor action. No Senate companion found. | Amends WIOA to define "talent marketplace," "credential registry," and "learning and employment record" (a digital, machine-readable record of an individual's education and employment history, verified by employers and providers). Funds Workforce Data Quality Initiative grants of up to three years from a 5 to 10 percent reservation of existing WIOA funds. Lets governors establish talent marketplaces. Does not use the terms "digital wallet" or "verifiable credential." |
| H.R. 8210, A Stronger Workforce for America Act of 2026 (WIOA reauthorization). Rep. Walberg. | Introduced Apr. 6, 2026. Ordered reported Apr. 21, 2026, 19 to 14. No floor action. No Senate counterpart found. | Requires state plans to describe skills-based initiatives that treat demonstrated skills as an alternative to degree-only requirements. Carries the same component definitions as the MATCH Act. Adds a report on the interoperability of federal and state databases. |
| S. 4382, Workforce Data Enhancement Act. Sens. Hickenlooper and Marshall. | Introduced Apr. 23, 2026. Referred to HELP. | Competitive grants for data linkage, standards adoption, skills and credential data, and learning-records systems, with priority for multi-state interoperable infrastructure. The nearest Senate analogue to the MATCH Act's data title. |
Bills that raise the demand for verified skills and credentials
| Bill | Status | Relevance |
|---|---|---|
| H.R. 5235, Skills-Based Federal Contracting Act of 2025. Rep. Mace. | Passed House Feb. 23, 2026. Passed Senate by unanimous consent Sept. 30, 2026. Cleared for the President; not yet signed as of Oct. 2, 2026. | Bars minimum education requirements for contractor personnel in federal solicitations unless justified in writing. Extends skills-based hiring from the federal workforce to the federal contractor workforce. |
| H.R. 7432, Fostering the Future Act. Reps. LaHood and Moore (WI). | Passed House May 19, 2026. In Senate Finance; S. 4854 is the companion. | Raises the Education and Training Voucher from $5,000 to $12,000 and allows its use for Workforce Pell programs and apprenticeships. |
| FY 2027 NDAA, H.R. 8800 and S. 4784 | House passed July 22, 2026. Senate pending. | House section headings include skills-based hiring for Department civilian positions and skills-based requirements for contractor personnel. Section text was not reviewed. |
| S. 2511 and H.R. 4806, College Transparency Act | Senate bill placed on the calendar Aug. 4, 2026. | A student-level postsecondary data system at NCES covering completion and post-college outcomes. |
| H.R. 1446, Validate Prior Learning to Accelerate Employment Act | Referred Feb. 21, 2025. | Adds prior-learning and competency assessments to WIOA services. |
| H.R. 7270, Stop Identity Fraud and Identity Theft Act of 2026 | Referred Jan. 27, 2026. | Treasury grants for state mobile driver's licenses and digital IDs aligned to NIST guidelines. |
| H.R. 5035, Veteran and Spouse Licensing Flexibility Act of 2025 | Referred Aug. 26, 2025. | License portability for veterans and spouses. |
Congressional record
The House Education and Workforce Subcommittee on Higher Education and Workforce Development held a hearing titled "Building a Talent Marketplace: How LERs Empower Workers and Expand Opportunity" on December 10, 2025. Witnesses represented Western Governors University, EBSCO, Credential Engine, and AACRAO.
Agency initiatives
The most specific federal language on these components is in agency guidance issued since January 2026. Labor and Education now name talent marketplaces, LERs, and credential registries directly, define them, and attach funding to them.
Department of Labor
| Action | Date | What it says |
|---|---|---|
| TEGL 07-25, Modification Requirements for WIOA State Plans for Program Years 2026 and 2027 (joint with Education) | Jan. 26, 2026 | Encourages states to integrate AI-powered tools, including talent marketplaces composed of learner records or LER solutions, credential registries, and skills-based job description generators. Calls for publishing education and training programs in structured, open, linked, and interoperable data formats. |
| TEGL 04-26, Using WIOA Governor's Reserve Funding to Advance Workforce Development Priorities | Aug. 25, 2026 | States are "permitted and encouraged" to use the Governor's Reserve to develop talent marketplaces made up of credential registries, skills-based job description generators, and LERs. Also encourages use of the Reserve for Workforce Pell implementation, including data system and wage record improvements. |
| TEGL 01-26, FY 2026 RESEA operating guidance | July 29, 2026 | Lists LERs among reemployment services. A footnote describes LERs as verifiable, learner-controlled records built on open standards such as W3C Verifiable Credentials or CTDL. |
| TEGL 03-26, Workforce and Labor Market Information Grants to States | Aug. 24, 2026 | References portable LERs, skills-based navigation, and AI tools in state labor market information work. |
| TEGL 02-25, Change 1, Industry-Driven Skills Training Fund, Round 2 | July 7, 2026 | About $40 million for state workforce agencies. Encourages states to leverage resources for LER deployment. |
| Linked Open Data on Credentials, information collection notice, 91 FR 53648 | Aug. 19, 2026. Comments due Oct. 19, 2026. | A new collection requiring Strengthening Community Colleges grantees to publish data on all grant-funded credentials using CTDL specifications. |
| Strengthening Community Colleges, Round 6, FOA-ETA-26-40 | Announced Feb. 17, 2026 | $65 million. Linked open data on credentials is required. Talent marketplaces, credential registries, and LERs are encouraged. |
| O*NET Request for Information, 91 FR 34833 | June 9, 2026. Comments closed Aug. 10, 2026. | Asked about skill granularity, aligning O*NET with other education and workforce data, detecting emerging skills, and linked-data and API infrastructure. |
| Labor Strategic Plan, FY 2026 to 2030 | 2026 | Commits to LERs to make learning portable and transferable, and to modernizing occupational and skill taxonomies. |
| Registered Apprenticeship circulars and Circular 2026-04 on Workforce Pell | Mar. 9 and Sept. 8, 2026 | A completion data portal, a 30-day registration clock, and guidance connecting apprenticeship to Workforce Pell. |
Department of Education
| Action | Date | What it says |
|---|---|---|
| Final Priority: Career Pathways and Workforce Readiness, 91 FR 18780 | Apr. 13, 2026. Effective May 13, 2026. | Makes development of talent marketplaces a priority for discretionary grants. Provides the only formal federal definition found: a publicly available digital system maintained by a state that integrates a Learning and Employment Record, a Credential Registry, and a skills-based job description generator, and uses AI. |
| Connecting Talent to Opportunity Challenge | Announced Dec. 15, 2025 | Up to $15 million in prizes for governor-led teams building or scaling talent marketplaces. Ten semifinalists: Alabama, Arizona, Arkansas, Georgia, Hawaii, Massachusetts, Montana, South Carolina, Tennessee, and West Virginia. |
| OCTAE Program Memorandum 26-3, aligning WIOA and Perkins V, transmitted to the workforce system by Labor TEN 08-25 | Mar. 26, 2026 | Describes interoperable talent marketplaces with an integrated LER, credential registry, and job description generator. Lists machine-readable, open, linked data as a criterion for recognized credentials. |
| Career Pathways Exploration Program competition, 91 FR 25870 | May 12, 2026 | State-level competition with talent marketplaces as the competitive preference priority. |
| State Workforce Pell Certification Form, GENERAL-26-44 | July 1, 2026 | Governors certify each program; institutions submit the form with their application. |
| Interagency agreements with Labor | May 21 and Nov. 18, 2025 | Labor administers Perkins and adult education on Education's behalf. In May 2026, 21 states filed combined WIOA plans that include Perkins V. |
The federal lineage predates this guidance and has continued across administrations. The American Workforce Policy Advisory Board published "Learning and Employment Records: Progress and the Path Forward" in September 2020.
Labor and Commerce issued a Skills-First Hiring Starter Kit for employers in November 2024, and Labor's Workforce Data Quality Initiative (Round 10, 2025) listed interoperable LER systems and credential registries as allowable uses.
Department of War
| Action | Date | What it says |
|---|---|---|
| Project Patriot Pipeline, Secretary of War memorandum | June 3, 2026 | A portal combining career exploration, credentialing, SkillBridge, and defense-industry jobs. |
| GigEagle, Defense Innovation Unit | Ongoing | An AI talent-matching prototype for the civilian skills of Guard and Reserve members. |
| Department of the Air Force digital badging | Ongoing | Issues digital badges under the Open Badges 2.0 standard. |
| Competency record under FY 2025 NDAA section 574 | Report due Dec. 23, 2026 | Implementation of the standardized separation record described under enacted statutes. |
GAO has repeatedly found gaps in the evidence base for these programs: inconsistent SkillBridge data (GAO-24-107352) and limited evidence of effectiveness for credentialing programs (GAO-22-105261). No Department-wide LER, verifiable credential, or wallet pilot was found in the public record.
Department of Health and Human Services
| Action | Date | What it says |
|---|---|---|
| Fostering the Future implementation, Administration for Children and Families | 2026 | A platform for transition-age youth covering education, housing, and careers, planned for fall 2026. A Child Welfare Technology Incubator for state information system modernization. |
| Medicaid community engagement interim final rule, CMS | June 3, 2026. State compliance by Jan. 1, 2027. | States must verify work, training, and education from existing data before asking the individual. |
| TANF pilot | Sept. 25, 2025 | Arizona, Iowa, Nebraska, Ohio, and Virginia measure employment, earnings, and reduced benefit dependency. |
| HRSA Licensure Portability Grant Program | Awards from July 2024 | Supports licensing boards in multi-state compacts for the health workforce. |
OPM, GSA, NIST, and DHS
| Action | Date | What it says |
|---|---|---|
| Competency-based qualification standard for the IT Management Series 2210, OPM | Apr. 13, 2026 | Moves a major federal occupation to competency-based qualification. |
| U.S. Tech Force, OPM | Dec. 15, 2025 | Cohorts of about 1,000 fellows selected through skills-based assessments. |
| NIST SP 800-63-4, Digital Identity Guidelines | July 31, 2025 | Adds "subscriber-controlled wallets" that hold signed attribute bundles from an issuer and present them with selective disclosure. This is the federal technical baseline for wallets. |
| TSA mobile driver's license rule, 89 FR 85340 | Oct. 25, 2024 | Federal acceptance of state-issued credentials held in a phone wallet. |
| Login.gov acceptance of mobile driver's licenses | Sept. 22, 2026 | Reported acceptance through commercial phone wallets. |
| DHS Science and Technology, Silicon Valley Innovation Program | July 2024 | Six wallet contracts with USCIS built on W3C Verifiable Credentials and Decentralized Identifiers. |
What this means for each reader
Each agency already holds a mandate that these components are designed to serve. The table shows the mandate, the dependency, and the nearest decision point.
| Reader | Mandates already in force | What those mandates depend on | Nearest decision point |
|---|---|---|---|
| White House | Skills-based federal hiring (EO 13932, EO 14170, EO 14356). One million apprentices and outcome transparency (EO 14278). Data integration (EO 14243). America.gov with data minimization. | A common, verifiable way to show skills across agencies. Individually held records are consistent with the commitment not to build a centralized federal record on Americans. | No executive order yet names the components that Labor and Education guidance now treats as standard. Agency definitions differ in detail. |
| Department of Education | Workforce Pell eligibility and accountability. The April 2026 talent marketplace priority and definition. The Connecting Talent to Opportunity Challenge. | Governors must show that credentials are stackable, portable, and tied to in-demand occupations. Registry data is the evidence. | Semifinalist incubation for the Challenge is under way. The Workforce Pell rule leaves the data method to states. |
| Department of Labor | WIOA state plans (TEGL 07-25). Governor's Reserve guidance (TEGL 04-26). Linked open data for grant-funded credentials. O*NET modernization. Administration of Perkins and adult education. | Program data published in open, linked formats, and skills taxonomies that records and job descriptions can both reference. | Comments on the Linked Open Data on Credentials collection close Oct. 19, 2026. O*NET RFI responses are in hand. |
| Department of War | Credentialing and verification of military training (10 U.S.C. 2015 and 1143). The separation competency record (FY 2025 NDAA section 574). Skills matching for separating members (EO 14426). Spouse license portability. | A record of military training that civilian employers and licensing boards can read and trust without manual translation. | The section 574 report is due Dec. 23, 2026. The statute leaves the record's format open. A digital, standards-based format would align it with what Labor and Education are funding in states. |
| Department of Health and Human Services | Medicaid community engagement verification by Jan. 1, 2027. The foster youth platform and expanded vouchers (EO 14359). TANF outcome pilots. Health workforce licensure portability. | Low-burden proof of education, training, and work activity. Records that follow a young person out of care. | State Medicaid verification systems are being designed now. The foster youth platform is planned for fall 2026. |
Three cross-agency points follow from the table.
- The same individual appears in several of these systems. A separating service member may be a SkillBridge participant, a Workforce Pell student, a WIOA participant, and a federal job applicant within one year. A single record the individual controls is designed to serve all four without four separate verifications.
- The agencies are funding the same architecture through different instruments. Labor uses state plan guidance and formula flexibility. Education uses grant priorities and a prize. Neither War nor HHS has yet named the components, though both hold mandates that depend on them.
- These components add to existing systems. Wage records, state longitudinal data systems, eligible training provider lists, COOL, and child welfare information systems remain the systems of record. Registries and LERs are designed to connect them and to put a verified copy in the individual's hands.
Gaps in the federal record and considerations for action
The federal record is strong on purpose and uneven on specification. Six gaps stand out, each paired with a consideration for the agencies reading this paper.
| Gap | Evidence | Consideration |
|---|---|---|
| No statute names the components. | "Learning and employment record," "credential registry," and "talent marketplace" appear only in pending H.R. 8183 and H.R. 8210 and in agency guidance. | Enactment of the MATCH Act definitions, or their inclusion in WIOA reauthorization, would give the guidance a durable statutory footing. |
| Wallets are absent from workforce policy. | The term appears in federal identity policy (NIST SP 800-63-4, the TSA rule) but was not found in any workforce or education guidance reviewed. | Workforce guidance could reference the NIST wallet model so that skills credentials and identity credentials follow one federal technical baseline. |
| Open standards are cited once. | Only TEGL 01-26 was found to cite W3C Verifiable Credentials and CTDL by name. No federal document reviewed cites Open Badges 3.0 or the Comprehensive Learner Record 2.0. | Naming open standards in grant terms is designed to keep state investments interoperable and to avoid records that work in one state or one vendor's system only. |
| Definitions differ across agencies. | Education defines a talent marketplace as state-maintained. H.R. 8183 describes an array of publicly and privately owned platforms. | A shared interagency definition would let a state build once and satisfy both Departments. |
| War and HHS mandates do not yet reference the architecture. | EO 14426, NDAA section 574, the Medicaid rule, and EO 14359 each require verified skills or participation data without specifying a format. | Each could adopt the same open formats that Labor and Education are funding, so a service member's or a foster youth's record is readable by state systems on day one. |
| Evidence of outcomes is still thin. | The Talent Strategy favors tools with demonstrated labor-market outcomes over interoperability in theory. GAO has noted weak outcome evidence for military credentialing. | Federal funding could require outcome reporting from talent marketplace investments: time to hire, placement, and earnings. |
Individual ownership as a design principle
The America.gov order commits to data minimization and bars a centralized federal system of records on Americans. LERs held in an individual's wallet are consistent with that commitment. The individual holds the record, decides what to share, and the issuer's signature lets a verifier trust it without calling a central database.
The White House as catalyst
The federal record shows agreement on direction and no one accountable for speed. A common-sense initiative is moving at the pace of guidance letters, grant cycles, and committee calendars. The White House is the one actor positioned to change that pace, and Trump Accounts show how.
Why the current path is too slow
- Six years of consensus, no statute. A federal advisory board published the case for learning and employment records in September 2020. As of this writing, no enacted statute names them.
- Legislation is stalled behind larger vehicles. WIOA authorizations lapsed after FY 2020. The MATCH Act cleared committee 33 to 0 in July 2026 and has had no floor action and no Senate companion.
- Guidance encourages; it does not require. Labor and Education guidance permits and encourages states to build this infrastructure. Adoption then proceeds one state at a time. Ten states are semifinalists for a $15 million prize.
- No single owner. Four Departments hold mandates that depend on the same infrastructure, with differing definitions and no lead office.
- The deadlines arrive first. Workforce Pell took effect July 1, 2026. The military competency record report is due December 23, 2026. States must verify Medicaid community engagement by January 1, 2027. Each program is on course to build its own verification method before a shared one exists.
The Trump Accounts precedent
Trump Accounts show what happens when the White House puts its name and its convening power behind a simple, universal idea. Congress created the accounts in the One Big Beautiful Bill Act (Internal Revenue Code section 530A). The accounts launched on July 4, 2026, one year after enactment. A published list counts 100 contributing entities, led by a $6.25 billion pledge from Michael and Susan Dell. By September 2026, seven to eight million children had been signed up, and Treasury projected more than 60 million accounts through automatic enrollment.
The same playbook fits a national digital wallet initiative.
| Element | Trump Accounts | A national digital wallet initiative |
|---|---|---|
| A simple, universal promise | Every eligible child has an investment account. | Every American has a digital wallet holding a verified record of what they have learned and done. |
| A federal seed | A one-time $1,000 federal deposit for children born 2025 through 2028. | The federal government seeds each wallet with records it already holds or funds: military training, federal employment, registered apprenticeship completions, and federally funded credentials. |
| Named sponsors | The Dell pledge of $250 each for 25 million children. Ray and Barbara Dalio. Micron. Employer contributions from JPMorgan Chase, BlackRock, Goldman Sachs, Morgan Stanley, Bank of America, Charles Schwab, Vanguard, State Street, and Visa, among others. | Nationally known employers, colleges, certification bodies, and technology companies pledge publicly to issue verified records and to accept them in hiring. |
| A challenge to states | Treasury's 50 State Challenge, with 20 states reported to be working toward it. | A governors' challenge that builds on the ten Connecting Talent to Opportunity semifinalists and the Governor's Reserve guidance. |
| Delivery partners | A Treasury app, a financial agent, and a private brokerage. | America.gov and Login.gov as the front door, with multiple private wallet providers competing on open standards. |
| Enrollment by default | Treasury rules authorize automatic account opening. | A wallet is offered by default at moments government already touches: graduation, military separation, apprenticeship completion, an unemployment claim. |
| Speed | Enactment to national launch in twelve months. | A national goal with a date certain, announced by the President. |
Two differences should be stated plainly. First, Trump Accounts rest on a statute and appropriated funds. A wallet initiative could begin under the existing authorities and guidance documented in this paper, with the MATCH Act definitions providing a statutory footing when enacted. Second, the ask of sponsors is smaller. Trump Accounts sponsors give money. Wallet sponsors would give something they already have: the records of what their workers and students have achieved, and a commitment to accept those records from others.
What named sponsors would pledge
| Sponsor | The pledge | What it delivers |
|---|---|---|
| Large employers | Issue every worker a verified record of employment and skills. Accept wallet credentials in hiring. Write job descriptions in skills terms. | Wallets fill with records that have immediate value in the labor market. |
| Colleges, training providers, and certification bodies | Issue every credential in an open, verifiable format. Publish every program to a credential registry. | The grounding data that makes each credential interpretable by people and by AI. |
| State licensing boards | Issue and accept licenses as portable, verifiable records. | License portability in practice for military spouses and health workers. |
| Technology and wallet providers | Adopt open standards. Guarantee portability between wallets. Offer the wallet at no cost to the individual. | Choice for citizens and no lock-in to any one vendor. |
| Philanthropy | Fund onboarding for small employers, rural colleges, and community organizations. | Reach beyond large institutions. |
| Governors | Commit Governor's Reserve funds and name a state lead. | A talent marketplace in every state. |
| Federal agencies | Act as issuers of first resort for the records they already hold. | Every service member, federal employee, and apprentice starts with a wallet that is not empty. |
What the White House could do
- Set a national goal with a date. Every American offered a digital wallet, with a verified record in it, by a date certain.
- Issue an executive order. Name the four components, adopt one interagency definition, reference open standards and the NIST wallet model, and designate a lead office.
- Make federal agencies the first issuers. Direct War, Labor, Education, HHS, and OPM to issue the records they hold in a common, verifiable format.
- Convene named sponsors. Announce the first pledges at a White House event and publish the list.
- Challenge the governors. Extend the Connecting Talent to Opportunity model into a 50-state commitment.
- Set the guardrails. The individual owns the record. Participation is voluntary. No central federal database is built. Standards are open and no vendor is preferred.
- Report results. Publish wallets issued, records verified, and hiring outcomes, so that the initiative is judged on evidence.
None of this requires waiting for the slowest piece of legislation. It requires a decision that the infrastructure already described in federal guidance is a national priority, and a public invitation for the country's largest institutions to sign on.
About the author
Greg DiDonato is Vice President of Business Development and Strategic Partnerships at EBSCOed, a division of EBSCO Information Services, and testified at the December 10, 2025 House subcommittee hearing cited above. EBSCOed provides the technology for the Alabama Talent Triad, and Alabama is a semifinalist in the Connecting Talent to Opportunity Challenge. Readers should weigh the paper with that interest in mind. Contact: gdidonato@ebsco.com.