Ten Thousand Commandments 2025
Introduction
Record federal debt is contributing to record-setting regulatory burdens. While new spending programs show up in budget figures, new regulations requiring the private sector to do similar things at its own expense do not. Off-budget regulations have grown common despite congressional attempts to limit them. And politicians’ Biden-era appetites for mandates in energy and climate, and equity initiatives such as family leave and child care, have not disappeared with the return of Donald J. Trump.
Off-budget or not, these regulatory costs drag down the economy, much as overspending can. Just as consumers shoulder much of the corporate income tax and tariff burden, regulatory compliance costs and mandates borne by businesses percolate through the economy and materialize as higher prices, lost jobs, and lower output.
The Congressional Budget Office’s 2025 Budget and Economic Outlook, covering fiscal year (FY) 2024 with projections for FY 2025 to FY 2035, depicts discretionary, entitlement, and interest spending of $6.750 trillion in FY 2024. Spending is projected to top $7 trillion in 2025 and exceed $10 trillion in 2033. The deficit stood at $1.832 trillion in 2024 and is expected to top $2 trillion by 2030 and remain well above that level. Total national debt now exceeds $36 trillion, up from almost $20 trillion when Donald Trump first assumed office in 2017. Interest payments alone for 2025 are projected to reach $1 trillion in 2026.
Regulations lack such precise quantification but should set off similar alarms. When the administrative state began its march over a century ago, few imagined the tangle of hundreds of thousands of rules and guidance documents it would produce and preserve. Even modest liberalizations during the Trump administration were reversed by Joe Biden, who changed the Office of Management and Budget’s mission away from oversight and toward the promotion of the administration’s regulatory initiatives.
Prior editions of Ten Thousand Commandments detailed Trump’s streamlining effort (2021) and Biden’s reversals. The reports outlined the latter’s pursuit of ambitious whole-of-government spending and regulatory initiatives spanning climate, equity, economic, and social matters, as well as an appetite for censorship and surveillance. This 2025 edition sets a new mark of $2.155 trillion in regulatory costs. While most previous estimates had the annual total cost of federal regulations below $2 trillion, those reports also explained why that figure was certainly an undercount.
Congress should be held accountable for such large regulatory actions. Cost–benefit analyses are few, not aggregated by the government, and merely self-reported by agencies. Delegation of lawmaking power to this unelected bureaucracy allows Congress to blame others for unpopular spending and rules. For that reason, first among the reforms outlined in the conclusion of this report is congressional approval of costly or controversial agency rules before they are considered binding.
Other reforms include regulatory sunsetting and budgeting; a regulatory reduction commission; and the limitation, streamlining, and inventorying of guidance documents. Annual regulatory transparency report cards could document progress.
Takeaways
- Federal regulation’s total compliance costs and economic effects are at least $2.155 trillion annually in Ten Thousand Commandments’ estimate, and almost certainly higher. Last year’s total was $2.117 trillion.
- An October 2023 National Association of Manufacturers (NAM) report models regulatory compliance at $3.079 trillion annually.
- US households pay on average $16,016 annually in a hidden regulatory tax, which consumes 16 percent of income and 21 percent of household expenses.
- These household outlays exceed expenditures on health care, food, transportation, entertainment, apparel, services, and savings. Only the costs of housing, which stand at $25,436 annually, exceed regulation.
- The higher NAM figure implies $22,883 per household, or 30 percent of the household expense budget.
- The regulatory tax of $2.155 trillion rivals individual income tax costs estimated at $2.176 trillion for 2023 and stands at nearly four times the corporate income tax of $419 billion.
- The NAM cost figure of $3.079 trillion annually would exceed the sum of both ($2.6 trillion).
- If it were a country, US regulation would be the world’s 8th-largest economy, ranking behind the Russian Federation and ahead of Canada.
- The 10.5 billion hours Washington says it took to complete federal paperwork in 2023, according to the Information Collection Budget, translate to the equivalent of 14,983 human lifetimes.
- Agencies issued 3,248 new final regulations in 2024. Trump’s total of 2,964 new final regulations in 2019 is the lowest on record.
- The Federal Register containing those rules surged to 106,109 pages, the highest tally on record and a 19 percent rise over 2023.
- Congress enacted 175 laws in calendar year 2024. Thus, agencies issued 19 rules for every law enacted by Congress.
- This Unconstitutionality Index—the ratio of regulations issued by agencies to laws passed by Congress and signed by the president—underlines how much agency lawmaking has replaced that of elected officials. The average ratio over the past 10 years is 29 rules for every law.
- Since the Federal Register first began itemizing final rules in 1976, 220,813 have been issued. Since 1993, when the first edition of Ten Thousand Commandments appeared, agencies have issued 123,723 final rules.
- A 2024 draft version of the White House Report to Congress on the Benefits and Costs of Federal Regulations covers fiscal year 2023. The report for fiscal year 2024 has not been released.
- A total of only 19 “major” rules had both benefits and costs quantified. These add $16.1 billion to the annual regulatory cost bill; another 10 rules with costs but not benefits quantified add another $1.94 billion to annual costs.
- A $2.155 trillion regulatory burden amounts to 7.3 percent of US gross domestic product (GDP), reported by the Commerce Department at $29.37 trillion in 2024. The NAM regulatory figure of $3.079 trillion implies 10 percent of GDP.
- Regulatory costs are equivalent to over 61 percent of the level of total 2022 corporate pretax profits of $3.523 trillion. The NAM figure would take that to over 80 percent.
- When regulatory costs of $2.155 trillion are combined with 2024 federal outlays of $6.750 trillion, the federal government’s share of the $29.37 trillion economy reaches 30 percent. State and local spending and regulation add to these costs.
- Until April 2023, a subset of each year’s 3,000-plus rules was labeled as economically significant, referring to annual economic effects of $100 million or more. Biden’s Executive Order 14094 (“Modernizing Regulatory Review”) eliminated that category and initiated a higher $200 million “Section 3(f)(1) Significant” category. In 2025, Trump revoked Biden’s order, restoring the $100 million threshold for upcoming years.
- In the year-end 2024 edition of the twice-yearly “Unified Agenda of Federal Regulatory and Deregulatory Actions,” 69 federal departments, agencies, and commissions present 3,331 regulatory actions then–currently flowing through the pipeline as follows:
- 2,233 rules in the active (prerule, proposed, final) phase
- 453 recently completed rules
- 645 long-term rules
- The five most active rule-producing executive branch entities in the Unified Agenda—the departments of the Interior, the Treasury, Transportation, Commerce, and Health and Human Services—account for 1,449 rules, or 44 percent of all rules in the pipeline. The five most active independent agencies account for another 303 rules.
- Of the 3,331 regulations in the fall 2024 Unified Agenda’s pipeline, 222 are Section 3(f)(1) Significant category rules (at least $200 million in economic impact), as follows:
- 126 rules in the active (prerule, proposed, final) phase
- 37 completed rules
- 59 long-term rules
- Despite his own higher $200 million threshold, high-significance rules in the Biden pipeline outnumber those during the Bush, Obama, and Trump years when the lower $100 million threshold applied.
- Major rules as defined in the Congressional Review Act left intact a $100 million threshold despite Biden’s executive order. The Government Accountability Office database contains 164 finalized major rules for 2024. Biden’s average of 126 easily exceeds Trump’s 86 and Obama’s 84.
- Final rules affecting small business appear to be mounting. Biden’s four years averaged 846 rules annually in the Federal Register affecting small business, compared with 694 and 701 for Obama and Trump, respectively.
- Of the 3,331 rules and regulations in the fall 2024 Unified Agenda pipeline, 647 affect small businesses; of those, 320 required an official “regulatory flexibility analysis.”
- Rules in the Unified Agenda pipeline affecting state governments stand at 424, while rules affecting local governments stand at 301.
- From the nation’s founding through Biden, presidents issued 15,661 executive orders. Biden’s 18 executive orders in 2024 were well below his peak of 77 in 2021. Biden’s presidential memoranda outstripped averages of recent predecessors.
- Public notices in the Federal Register always exceed 22,000 annually, with uncounted guidance documents and other proclamations having potential regulatory effect among them, whereas other guidance documents issued do not appear in the Federal Register at all. In 2024, public notices surged to 25,506. There have been 740,069 public notices since 1994 and over a million since the 1970s.