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).
Lee Zeldin, administrator of the US Environmental Protection Agency (EPA), from left, Linda McMahon, US education secretary, Robert F. Kennedy Jr., US secretary of Health and Human Services (HHS), Doug Burgum, US secretary of the interior, Marco Rubio, US secretary of state, US President Donald Trump, and Pete Hegseth, US secretary of defense, during a cabinet meeting at the White House in Washington, DC, US, on Tuesday, Aug. 26, 2025. Trump plans to name longtime aide Dan Scavino as the director of the White House personnel office, an influential role responsible for staffing positions throughout the administrations. Photographer: Aaron Schwartz/CNP/Bloomberg
© 2025 Bloomberg Finance LP
Often tardy, the Agenda has 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.
Record-Low Rulemaking—And The Sky Isn’t Falling
The Spring 2025 Agenda lists 3,816 rulemakings at various stages in the regulatory pipe—active, recently completed, and planned. The table just below breaks these down by levels of economic significance and compares them with Joe Biden’s Fall 2024 Agenda.
Spring 2025 Unified Agenda Entries by Rule Stage and Significance
Compiled by the author from reginfo.gov
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.
Unified Agenda Entries by Department, Agency and Commission, Spring 2025
Compiled by the author from Unified Agenda of Federal Regulations
243 High-Dollar “Economically Significant” Rules
As the chart at the beginning of this article shows, the 3,816 rules in the pipeline, 243 are “economically significant,” meaning they have at least $100 million in annual economic effect—typically added costs, but subtractions as well under Trump.
Biden had raised the threshold for high-significance rules to $200 million, eliminating the traditional “economically significant” designation. Trump has restored the $100 million benchmark, so none of Biden’s “Section 3(f)(1) Significant” $200 million rules appear here.
Other criteria, such as a rule’s raising novel legal issues also render it “major,” as shown, but cost or economic significance gets most of the attention. While the Biden and Trump high-dollar counts are comparable, their aims diverge. The Department of Energy, once a hub of costly efficiency mandates for appliances, machinery, and vehicles, is now easing many of them.
The Deconstruction Has Commenced
This Unified Agenda in part affirms that many “rules” under Trump are not new mandates at all, but rescissions, withdrawals, de-prioritizations, enforcement relaxations, and demotions. Even independent agencies, historically outside Office of Management and Budget (OMB) review, now assume new importance as Trump’s executive orders have pulled the the Federal Trade Commission, Federal Communications Commission and financial regulators like the CFTC into the deregulatory fold.
The deconstruction has commenced, and the upcoming Fall 2025 Agenda—free of Biden’s outgoing moves—will likely be even more reflective of Trump’s progress and plans.
Beyond Rules: The Shadow of Regulatory Dark Matter
Even as rule counts swell in pursuit of their own disappearance, agencies still churn out guidance documents, memos, FAQs, Dear Colleague letters, advisories and other sorts of regulatory dark matter that can evade notice-and-comment. So far, these are not incorporated into the Unified Agenda.
While Trump has not reissued his first-term executive order requiring guidance document portals, he did incorporate guidance into his one-in, ten-out directive and the “commence deconstruction” order. Some guidance recissions are reflected on the Department of Government Efficiency (DOGE) webpage. But unless Congress makes disclosure mandatory, Unrules risk becoming just a surface phenomenon while dark matter grows unchecked.
Improvements For The Next Agenda—And The Ones After That
During Trump’s first term, the Unified Agenda’s landing page featured a radio button for “Deregulatory” actions and other classifications, as seen in the image below.
Unified Agenda Search Page During First Trump Term, Featuring “Deregulatory” and Other Rule Classifications.
Reginfo.gov
That helpful disclosure disappeared under Biden, whose Agendas lacked any deregulatory component. Trump has yet to restore it, but there may be a reason: since guidance documents do not appear in the Agenda but can be used in the one-in, ten-out campaign, any ratio calculated solely from the Agenda would understate “rules-out.” Critics would then call the policy a failure.
Nevertheless, restoring this functionality in the Fall Agenda would help the public see regulatory and deregulatory activity side by side. This is where Congress should step in, since executive-order-based deregulation usually lasts only as long as the administration. Working with OMB Director Russell Vought, Congress should:
- Incorporate Deregulatory/Regulatory classifications for every rule in the Unified Agenda and Federal Register.
- Make agency guidance document portals permanent—such as the Guidance Out Of Darkness (GOOD) Act would do—and incorporate appropriate elements of their disclosure into the Agenda;
- Constrain agencies’ rulemaking to that disclosed in the Agenda;
- Codify elements of “deconstruction,” such as “one-in, one-out” and rule sunsetting.
Conclusion: A New Baseline
For decades, the Unified Agenda symbolized regulatory sprawl. Biden in particular, with his transformational Modernizing Regulatory Review directive, shifted OMB’s role from watchdog to promoter of a coercive progressive agenda.
The Spring 2025 Agenda marks a departure. Agencies that once boasted of new initiatives are shifting to the basics and forced to justify their existence.
The bureaucracy is sticky, though. The Agenda does not yet point the way to shutting down entire departments such as Education. And there remains plenty conventional as opposed to “signficant” rulemaking taking place. Agriculture Secretary Brook Rollins, for example, should consider what future progressive administrators might do with the lingering “equity” language in that department’s Statement of Regulatory Priorities accompanying the new Agenda.
Overall, however, the Trump Agenda may be remembered as the first official entry in a diary of disappearance—a chronicle of getting things undone—where a federal government doing less becomes the point. If Trump’s first months are any indication, we could be witnessing not just conventional deregulation but a new baseline: one where the absence of a constant barrage of new rules becomes normal. And if entire offices have nothing “Active” to regulate, shuttering departments and agencies altogether is no longer unthinkable.
Source: https://www.forbes.com/sites/waynecrews/2025/09/05/diary-of-deconstruction-trump-releases-unified-agenda-of-federal-regulations/
