Chapter 6: A note on rule reviews at OMB
Rule reviews at OMB are a useful variable to examine alongside costs, page counts, rule counts, and guidance documents, among others. Figure 17 depicts 449 rule reviews that OMB conducted during calendar year 2025, broken down by stage and economic significance. Total reviews are down from 554 in 2024. There were 503 total reviews in Biden’s first year and 669 in the final year of Trump’s first term.
There were 98 economically significant rules among the 449 rules reviewed in 2025. Under Biden, economically significant rules had yielded to the higher-threshold Section 3(f)(1) Significant (S3F1) rules. There were 172 S3F1 rule reviews in 2024. Of the thousands of notices issued, OMB reviewed 58 during calendar year 2025, down from 64 in 2024.
Figure 17 also presents the number of days OMB took to review significant and nonsignificant rules and regulations, a process that typically takes roughly two and a half months. During the pre-EO 12866 years of 1991-1993, rule review times were shorter than today despite considerably higher rule counts. Appendix H provides a history of the numbers of rules and notices reviewed annually, broken down by type and average review time from 1991 through 2025.
