For all its bluster about canceling a record number of regulations across the federal government, the Trump administration has only erased a handful of big-ticket rules more than a year into his second term, according to a review by Bloomberg Law.
The White House has repeatedly claimed historic results on cutting red tape, ranging from President
On the surface, the White House’s claims are backed by some impressive statistics: the Office of Management and Budget reported that the administration finalized 646 deregulatory actions that saved about $211.8 billion through the end of October and far outpaced Trump’s target of cutting 10 existing regulations for every new one.
But a closer look at the numbers shows that, with a few notable exceptions, the final actions are relatively minor and will only affect small groups of citizens or companies. A Bloomberg Law analysis found that at least 17 of the administration’s deregulatory actions through March 18 were classified as economically significant by the Office of Information and Regulatory Affairs, meaning they’re expected to affect the economy by at least $100 million—far from the broad, economy-rattling overhaul Trump has promised.
Of the 646 “unrules” listed by OMB, Bloomberg Law found that 407—or 63%—don’t appear to be documented in a subsequent Unified Agenda or Federal Register. That’s usually a sign the actions are too minor to warrant documentation, said Amit Narang, a regulatory specialist and consultant for the Coalition for Sensible Safeguards.
“The rhetoric doesn’t match the reality,” Narang said. “Virtually all of them are extremely minor and technical actions that no one has even heard of.”
Supporters of Trump’s deregulatory agenda say the administration has plenty to crow about, given how time-consuming it can be to rescind rules.
“Critics ignore the fact that it typically takes 18 to 24 months for major regulatory actions,” said Andrew Wheeler, who led the Environmental Protection Agency during Trump’s first term. Thus, the Trump administration’s deregulatory performance thus far “is a major accomplishment,” he said.
Big-Ticket Items
Regulatory experts say the administration’s biggest swing is the EPA’s withdrawal of the greenhouse gas endangerment finding, one of the economically significant unrules finalized after the OMB’s 2025 report was published. That rescission—which is being challenged in court by a coalition of more than three dozen states and localities—dismantles the legal basis the EPA has used to regulate six gases widely understood to contribute to climate change.
The EPA called the unwinding “the single largest deregulatory action in U.S. history,” saying it will save Americans more than $1.3 trillion.
“If it holds up in court, it will lead to specific deregulatory actions that will be very significant for the economy and the environment,” said Stuart Shapiro, a public policy professor at Rutgers University, pointing to the ending of fuel economy standards for cars and emissions rules for power plants.
Separately, the Department of the Treasury removed a requirement for US companies and citizens to report beneficial ownership information to the Financial Crimes Enforcement Network.
The March 2025 interim final rule rolled back a Biden-era bid to stop illegal financial transactions using shell companies. FinCEN estimated the transparency rule would cost companies $6.9 billion over five years for initial reports and $2 billion for updated reports—making up the bulk of the deregulatory savings OMB touted in its year-end report.
But many of the other economically significant actions appear far more narrowly targeted.
For example, three major unwindings at the Department of Energy have softened energy conservation standards for commercial refrigerators, consumer water heaters, and walk-in coolers—meaning they matter primarily to appliance makers and grocery stores, restaurants, and homeowners who happen to be in the market for those types of equipment. Three other major actions come from the US Department of Health and Human Services, including one to remove a health equity-related criterion from a scoring methodology used to calculate nursing home bonus payments and another streamlining reporting requirement at inpatient rehabilitation facilities.
The list of 17 major unrules also includes actions from the Commodity Futures Trading Commission, Labor Department, and Department of Veterans Affairs.
“This is not a huge success from a deregulatory standpoint,” said Cary Coglianese, an administrative law professor at the University of Pennsylvania.
43-to-1
Apart from the 17 major unrules, most of the administration’s other deregulatory actons are smaller in scope.
Some examples of the 407 undocumented actions touted by OMB include the Agriculture Department’s removal of provisions for sampling and testing pumped bacon, the Department of Homeland Security’s cancellation of rules governing how drilling units can be towed, and the Interior Department’s withdrawal of a handbook on how to make permitting decisions in national wildlife refuges.
Mark Paoletta, general counsel of OMB, performing the duties of Office of Information and Regulatory Affairs administrator, said in an email that “during the first year, President Trump’s team implemented 646 de-regulatory actions, including the removal of radical, DEI, unpopular, destructive, and costly policies inflicted on the American people by the failed Biden-Harris administration. Many of these awful Biden-Harris policies were imposed through sub-regulatory guidance, and that’s how we removed them. That’s a victory for the American people whether or not it is published in Federal Register.”
“Under President Trump’s leadership, we have achieved historic regulatory savings of over $211 billion,” Paoletta said. “And the best is yet to come, as the rescission of the radical Obama Administration’s endangerment finding will save more than a trillion dollars.”
Indeed, some of the lesser, undocumented moves, while not bearing significant economic benefits, do peel away red tape in ways Trump has touted. One prominent example is the Department of Homeland Security’s elimination of the “shoe off policy” at airport security checkpoints.
Those actions helped drive the White House’s claim that the administration has cut 43 rules for every new one issued, nearly five times the president’s stated target.
OMB Director Russ Vought, during a December White House meeting, reported a ratio of 48 to one, adding that the true rate is “actually much higher than that, but I made my team redo the threshold a little bit because it sounds so unbelievable.”
Former EPA administrator Wheeler said critics who deride the significance of removing guidance are ignoring the scope of the “modern regulatory state,” which he said issues thousands of guidance documents annually, many of which should have followed the full rulemaking process.
“Each guidance document and regulation impacts someone,” said Wheeler, who is now a partner and head of federal affairs at Holland & Hart LLP. “Reductions of unnecessary regulations and guidance documents benefit jobs and the economy.”
Too Soon to Say?
Coglianese said the administration’s overhyping of its regulatory record echoes the overpromises and underdelivery of Trump’s first term. In a 2020 academic paper Coglianese co-wrote with Shapiro and Natasha Sarin of Yale Law School, the scholars found that Trump also failed to meet his deregulatory expectations throughout his entire first term.
“Politically, it surely matters less to the president what he has in fact accomplished by way of deregulation than what his base thinks he has accomplished,” Coglianese said. “The president’s political goals can be advanced as much by appearance as by reality.”
Still, others say it’s too soon to pass judgment on Trump’s second-term performance.
Even if the numbers are underwhelming, the administration has already put a big dent in the regulatory state, often by simply refusing to enforce rules on the books, said Katie Tracy, senior regulatory policy advocate at Public Citizen.
To Clyde Wayne Crews, a regulatory studies fellow at the Competitive Enterprise Institute, a strict accounting of how many deregulatory actions have been finalized doesn’t tell the whole story.
“Year one has largely been about freezing the pipeline and setting up replacements—and under the Administrative Procedure Act, that takes time,” Crews said.
The Trump administration does have several other economically significant deregulatory actions under development. One proposal from the Labor Department would roll back anti-discrimination protections from apprenticeship programs. Another would undo an Obama-era restriction on home care agencies exempting workers from minimum wage and overtime requirements, while the Treasury Department wants to reduce the number of banks covered by risk oversight protocols developed in response to the 2008 financial crisis.
Another hurdle is that modern regulation is embedded deep within spending programs and grant conditions, such as the Biden-era infrastructure law, which authorized more than $1 billion in federal investments.
“While some significant deregulatory actions have indeed happened, and more are clearly in the pipeline, the real test is whether the administration is willing to confront that deeper fusion of spending and regulation, not just the visible rule count,” Crews said.
— With assistance from
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