This year’s Sunshine Week, which promotes the importance of government transparency, is particularly momentous. President Donald Trump’s 30,573 documented false or misleading claims battered the public’s trust in government, and his administration waged an unrelenting assault on transparency, the balance of power and the rule of law itself.

Now, a new administration that has committed to transparency and broad government ethics reform has just passed the halfway mark in its first 100 days. But while candidate Joe Biden campaigned on those promises, it’s not clear that President Biden is on track to keep them.

On the campaign trail, Biden promised a legislative overhaul of the federal government’s ethics and anticorruption systems. He envisioned a new agency empowered to aggressively investigate violations, issue subpoenas, tighten loopholes in financial disclosure laws, impose civil penalties and alert the public if the Justice Department refuses to prosecute lawbreakers inside the government. He promised new conflict-of-interest laws compelling divestiture of assets and compliance with ethics agreements, not only by executive branch officials but also members of Congress. He promised new laws granting inspectors general subpoena power and increasing their independence. He promised new protections for whistleblowers. He said he would issue an executive order creating new ethics requirements for political appointees and would work with Congress to “codify into law” those requirements.

Of particular interest this Sunshine Week, Biden pledged greater transparency. He promised a public database — “a new one-stop website” — for all ethics, campaign-finance and lobbying records. He committed to releasing lists of White House visitors. He called for requiring every candidate for federal office to disclose 10 years’ worth of tax returns. He said he would expand the reach of lobbying laws by seeking to change the definition of “lobbyist” so that it includes people engaged in behind-the-scenes shadow lobbying. He promised legislation requiring lobbyists “to disclose in detail exactly what they are doing: with whom they are meeting, the materials they are sharing, any specific legislative (or regulatory) language they are proposing, and precisely what outcomes they are seeking.”

Biden’s campaign promises addressed a root cause of ethical failure in Washington: campaign finance. He promised legislation to get dark money out of politics, barring certain nonprofit organizations from election spending and requiring others to disclose their contributors. He promised legislation to ensure “superPACs are wholly independent of campaigns and political parties.” He pledged to break the deadlock that has incapacitated the Federal Election Commission by amending the law to give the agency an odd number of commissioners. He pledged to seek public matching funding for small-dollar donations and “a constitutional amendment to entirely eliminate private dollars from our federal elections.”

There is historical precedent for such measures, although Biden ambitiously proposed that his interventions would be “even more aggressive.” In the aftermath of the Watergate scandal, Congress overhauled the way government works by restructuring the entire civil service. In the process, it created new protections for federal employees against politically motivated actions that could otherwise create pressure to follow unlawful orders. It established inspector general offices that boast a combined workforce of 14,000 who are dedicated to investigating and auditing corruption, fraud, waste and abuses of power. It created the Office of Government Ethics, which issues standards of ethical conduct, and the Office of Special Counsel, which investigates whistleblower retaliation.

We’re now at a similar moment, but Biden can’t make good on his promise to surpass that ethical sea change if he waits passively for Congress to do all the work. “Aggressive” change doesn’t just happen; it requires strong leadership. True, the new administration is just getting started and has been occupied with fighting the coronavirus. And Biden has made great strides in turning around the Trump administration’s disastrous pandemic response, in part with his appointment of a strong pandemic czar. But his success on that front, deriving as it does from smart appointments, serves only to illustrate why the lack of clear leadership on the ethics and transparency front is disappointing.

In 2009, President Barack Obama named a confidant, Norman Eisen, to a senior post as his ethics and government reform czar. Eisen energized the ethics program and worked closely with nonprofit watchdogs such as the one I work for, the Project on Government Oversight. Biden has declined to follow suit and name a top official to pursue the ambitious government ethics reform agenda he promised as a candidate.

The administration’s failure to appoint a senior ethics czar or solicit input from outside good-government groups may be the cause of some early missteps. For example, Biden made good on his promise to release lists of White House visitors, but he undermined the value of this move when he declined to disclose the countless visits being held virtually during the pandemic. He also has chosen not to direct federal agencies to disclose their visitor logs. These omissions run contrary to the spirit of his campaign promise to seek legislation requiring disclosure of meetings with lobbyists.

Biden’s appointment of Tom Vilsack to be agriculture secretary is similarly hard to reconcile with the spirit of his campaign promise to expand the definition of who counts as a “lobbyist.” Before joining the administration, Vilsack led the U.S. Dairy Export Council, a dairy industry advocacy shop. Because Vilsack didn’t personally register as a lobbyist, he slipped through the cracks of Biden’s ban on appointing lobbyists, even though he directed the group’s lobbying efforts. Biden deserves praise for reinstating the ban on employing lobbyists and for acknowledging that “our lobbyist regulations are filled with loopholes.” But he let Vilsack drive a milk truck through a loophole in his ethics executive order.

The White House ethics office also appears to have not met the deadline for releasing the financial disclosure reports of its appointees. My organization filed numerous requests for these disclosures, and federal law required the White House to release any that had been filed at least 30 days before the date of our requests. This means that any disclosures filed on Jan. 20 needed to be released on Feb. 19. Instead, the White House advised us that it would withhold them for an additional month. (It is remotely possible that no staff members filed their disclosures for several weeks after entering government, but that would be cause for even greater concern.) The White House defended this delay by citing the Trump administration’s failure to release its disclosures until late March 2017, a worrying sign that broken norms had themselves been normalized.

None of this is to suggest anything approaching equivalence to the ethical failure of the prior administration. Unlike Trump, Biden did not come into government with conflicting financial interests and has not set about enriching himself at our expense. He got off to a good start with an executive order on ethics that is stronger than either of the ethics executive orders that Trump and Obama issued. Among other noteworthy measures, the Biden ethics executive order reinstates an Obama-era ban on appointing lobbyists and slows the revolving door by imposing new restrictions on his appointees lobbying the government after they leave.

Biden has also taken steps to reestablish the independence of the Justice Department. Political interference in criminal investigations and prosecutions was one of the most dangerous features of Trump’s war on the rule of law. In response, Biden’s ethics executive order directs his appointees to uphold the independence of federal law enforcement. Newly installed Attorney General Merrick Garland reassured the Senate’s Judiciary Committee: “The president has promised that those decisions will only be made by the attorney general, and that is what I plan to do. I do not plan to be interfered with by anyone. I expect the Justice Department will make its own decisions in this regard.”

But we can’t afford to let the standard for government ethics become merely “better than the former guy.” If the past four years have taught us anything, it’s that going back to the way things were is not enough. Biden needs to understand that leading an ethical administration won’t keep future threats at bay: He also needs to undertake lasting reforms to guard the nation against an unethical future administration.

To his credit, Biden applauded the House’s passage of H.R. 1, the For the People Act, this month, but it has little chance of making it through the Senate unless he wins new supporters in that chamber. More important, if the new president is going to live up to his promises, he will need to do more — and soon. The momentum for reform may wane as memories of the past four years fade; worse from Biden’s perspective, he may not hold leverage over both chambers of Congress for long. If he hopes to make good on his pledge to put the post-Watergate reformers to shame, the time is now before the window closes. There is no shortage of ideas for reform, nor is there any shortage of good-government groups willing to help him develop proposals. The only thing in short supply is time.