Second Trump Administration Releases First Unified Agenda, Listing Upcoming Regulations

Second Trump Administration Releases First Unified Agenda, Listing Upcoming Regulations

Second Trump Administration Releases First Unified Agenda, Listing Upcoming Regulations

September 4, 2025 (IN12605)

On September 4, 2025, the second Trump Administration released the Spring 2025 Unified Agenda of Regulatory and Deregulatory Actions. The Unified Agenda, which is published twice a year, is a government-wide publication of rulemaking actions agencies are currently working on and expect to take in the coming months.

The Unified Agenda contains both regulatory actions (i.e., new regulations) and deregulatory actions (i.e., reductions in or elimination of current regulations). It also includes regulations that have been withdrawn since the most recent edition of the Unified Agenda—e.g., rules that the Biden Administration had been working on in late 2024, but the second Trump Administration no longer appears to be pursuing.

The Unified Agenda is compiled by the Regulatory Information Service Center (RISC) in coordination with the Office of Information and Regulatory Affairs (OIRA). OIRA is the entity within the Office of Management and Budget (OMB) that reviews federal agencies' regulations prior to when they are issued. OIRA is also responsible for implementing any broad regulatory reform agenda of the current President, such as President Trump's one-in, ten-out policy for regulations established in Executive Order 14192 (see memorandum M-25-20 for OIRA's guidance implementing that order).

Contents of the Unified Agenda

The Unified Agenda lists regulatory activities, by agency, in three categories:

"active" actions, including rules in the prerule stage (e.g., advance notices of proposed rulemaking that are expected to be issued in the next 12 months, or actions that include a review of current regulations); proposed rule stage (i.e., notices of proposed rulemaking that are expected to be issued in the next 12 months, or for which the closing date of the comment period is the next step); and final rule stage (i.e., final rules, interim final rules, or other final actions that are expected to be issued in the next 12 months);

"completed" actions (i.e., rules that have been completed or withdrawn since the last edition of the Unified Agenda); and

"long-term" actions (i.e., items under development that agencies do not expect to take action on in the next 12 months).

Reginfo.gov, which houses the Unified Agenda, contains an advanced search page, where users can search by data elements such as the issuing agency, whether the rule had previously been published in a Unified Agenda, and various indicators of the significance or priority of the regulation. Users may also search for specific terms. For each entry, the agency also provides a summary of the rule, an estimated timeline for completion, and a timetable containing any previous actions on the rule (such as a notice of proposed rulemaking).

Requirements for Publication of the Unified Agenda

The Unified Agenda helps agencies fulfill two transparency requirements:

Section 602 of the Regulatory Flexibility Act, which requires that all agencies publish semiannual regulatory agendas describing regulatory actions they are developing that may have a significant economic impact on a substantial number of small entities; and

Section 4 of Executive Order 12866 on "Regulatory Planning and Review," which requires that all federal rulemaking agencies "prepare an agenda of all regulations under development or review."

President Trump's Executive Order 14192, issued on January 31, 2025, also states that "Unless otherwise required by law, no regulation shall be issued by an agency if it was not included in the most recent version or update of the published Unified Regulatory Agenda as required under Executive Order 12866, as amended, or any successor order, unless the issuance of such regulation was approved in advance in writing by the Director."

Role of the Unified Agenda in Rulemaking

The Unified Agenda is primarily intended to increase transparency of federal agency rulemaking activities. Publication of an action in the Unified Agenda is not a binding commitment to take that action to fruition nor a necessary prerequisite for completing such action—some prospective regulatory actions listed in the Unified Agenda are never finalized, and rules are sometimes issued without prior notice in the Unified Agenda. However, as noted above, section 4(c) of Executive Order 14192 states that "Unless otherwise required by law, no regulation shall be issued by an agency if it was not included in the most recent version or update of the published Unified Regulatory Agenda as required under Executive Order 12866, as amended, or any successor order, unless the issuance of such regulation was approved in advance in writing by the Director."

The second Trump Administration also appears to be using the centralized planning aspect of the Unified Agenda as a means of implementing its one-in, ten-out deregulatory program. The RISC guidance to agencies on the Spring 2025 Unified Agenda stated that the Fall 2025 Unified Agenda will contain additional information about the cost allowances and other accounting matters related to that program, and agencies were to submit "cost estimates for all actions that are expected to be finalized by the end of FY2025" as part of their submissions for the Spring 2025 Agenda.