Diary Of Deconstruction: Trump Releases Unified Agenda Of Federal Regulations
As the leaves begin to fall, the Trump administration has at last released Spring 2025 edition of the semiannual “Unified Agenda of Federal Regulatory and Deregulatory Actions” (the Agenda).
Often tardy, the Agenda has for decades surveyed recently completed and forthcoming mandates and priorities from dozens of federal departments and agencies.
While this first Agenda of Trump’s second term overlaps with fading regulatory ambitions from the Biden era, it unmistakably documents the rise of “the Unrule.”
During his tenure, the Biden administration used the Agenda to showcase “whole-of-government” pursuits on climate, equity, ESG, and the so-called “care economy”— essentially a broad progressive custodial state at odds with individualism and limited government.
By contrast, the new Agenda reflects Trump’s order to “to commence the deconstruction of the overbearing and burdensome administrative state.”
While the Agenda’s departmental and agency preambles tend toward boilerplate bureaucratese, press releases accompanying the rollout—such as those from Securities and Exchange Commissioner Paul Atkins and Commodity Futures Trading Commission (CFTC) Acting Chair Caroline D. Pham are more reflective of the streamlining campaign, invoking “overreach” and the need to “rightsize.”
Although Trump harbors contradictory industrial policy impulses that tear holes in any streamlining drive, this new Agenda features what is already notable—a thinning conventional rulemaking docket along with rescissions, delays and rewrites. Agencies have been closing offices, shrinking reporting burdens and even trimming staff and it’s starting to show.
Marking a shift from “whole-of-government” to “one-in, ten-out” as the guiding ethos, this “Spring” Agenda opens a new season.
Paradoxically, Trump’s Agenda tally is the highest since Spring 2021. But that partly reflects the quirky need under the Administrative Procedure Act (APA) to write a new rule to replace an old one, artificially inflating the “regulatory” count. Rule counts are not rising: as of today, the Federal Register depicts 1,760 finalized rules, on track for about 2,590 at year-end. That would be the lowest ever recorded—with many deregulatory in nature..
Active Rulemakings (Pre-Rule, Proposed and Final): 2,098 of 3,816
“Active” rulemaking actions include pre-rule documents and proposed and final rules anticipated or prioritized for the near future. The count of 2,098 is down from Biden’s 2,233 in Fall 2024 (and from 2,361 in Spring 2024).
Rules may stew for years across Agenda editions before completion. In this Spring 2025 edition, 864 active elements appear for the first time (compared with 275 and 405 newcomers in Fall and Spring 2024, respectively). This partly reflects the rise of the Unrule, wherein conventional notice-and-comment regulation of the additive variety has ceased, but reversals and rollbacks add to the “rule” count.
Completed Actions: 911 of 3,816
Completed actions are those finalized since the prior Agenda, typically covering the previous six months. The tally of 911 marks a jump from 453 in Fall 2024, and even surpasses Spring 2024’s 689, when Biden was churning out rules at a rapid pace. A glance at the Unified Agenda website shows dozens of these are streamlining-oriented, including:
- 19 “removal of” entries
- 16 “extension” entries
- 33 “administrative updates”
- 14 “standards updates”
Notably, 183 completed actions appear in the Agenda for the first time, compared with 45 in Fall 2024. This dents the notion that the Agenda primarily serves a predictive function; it often announces what’s already done. Such “unforeseen” completions are unsurprising now, since Trump’s executive orders prioritize speed and encourage use of the APA’s “good cause” exemption to remove rules, in contrast to its traditional use for adding them. This high pace of completions will likely continue in the forthcoming Fall Agenda.
Long-Term Actions: 807 of 3,816
Longer-term priority rulemakings—those anticipated beyond a 12-month horizon—rose under Trump to 807, compared with Biden’s Fall tally of 645. The Department of the Interior alone accounts for 172. Overall, 110 of these long-term actions appear in the Agenda for the first time, signaling deregulation as far as the eye can see.
A Complete Breakdown Of The 3,816 Rules In The Unified Agenda
A handful of executive departments account for the greatest number of the rules—and now perhaps, Unrules—in the pipeline. The Departments of the Treasury, Interior, Transportation, Commerce along with the Environmental Protection Agency comprise the top five with 1,762 rules among them, accounting for 46 percent of the total. The Department of Health and Human Services is sixth place with 190 rules in the pipeline. Among independent agencies, the Federal Communications Commission leads with 134 rules (some of them part of what it calls a “Delete, Delete, Delete” campaign. Just below appears agency detail on which Agencies are responsible for the 3,816 rules currently in the pipeline.
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