Ledger updated 28 October 2026
The Mandate for Leadership runs about 900 pages and is organized agency by agency. This ledger follows what has been carried out, what is moving, and what has not started, one item at a time, each with a date and the document behind it.
Every status below names its vehicle: an executive order, a final rule, a statute, or a court ruling. Where a court has blocked or reversed an action, the ledger says so. Where an action people attach to Project 2025 does not appear in the Mandate, the ledger says that too.
Counts cover the 83 Mandate items on this ledger, not the whole document. Five related actions without a confirmed Mandate recommendation are listed separately and are not counted.
When each item landed
Where the items sit in the Mandate
Done or in effectPartly blocked or reversedIn motionNot started
From the order to the thing that stuck
Jan 2025Jul 2025Jan 2026Jul 2026Jan 2027
Order to a durable instrumentOrder to a court reversalOrder to the latest step, still moving or contested
WHAT THE TRACKERS COUNT
| Tracker | Counts | Of | Share | As of |
|---|---|---|---|---|
| Center for Progressive Reform, Project 2025 Executive Action Tracker | 283 | 532 | 53% | February 2026 |
| Project 2025 Tracker (crowd built) | 141 done, 70 moving | 321 | 44% done | its latest dated entry, 12 August 2026 |
| Reproductive Freedom for All | 24 done, 10 moving | 57 | 42% done | 14 July 2026 |
| Heritage Foundation, reported by Bloomberg Law | 53 percent adopted | not given | 53% | 23 June 2026 |
| This ledger | 49 done or in effect | 83 items it has verified | 59% | 28 October 2026 |
- Center for Progressive Reform, Project 2025 Executive Action Tracker: 283 of 532 recommended executive actions initiated or completed (53 percent), as of February 2026. The count covers executive actions at 20 domestic agencies and groups started and finished actions together. No later CPR count was found as of 21 October 2026.
- Project 2025 Tracker (crowd built): 141 completed and 70 in progress of 321 objectives, as of its latest dated entry, 12 August 2026. The count covers broader objectives across 34 agencies, including ones that need Congress. Its page counts in progress objectives as half and reports 55 percent overall.
- Reproductive Freedom for All: 24 completed and 10 in progress of 57 reproductive health actions, as of 14 July 2026. The count covers one policy area.
- Heritage Foundation, reported by Bloomberg Law: 53 percent adopted, no denominator given, as of 23 June 2026. The percentage matches CPR's February figure; Heritage gave no denominator or method.
WHAT COMES NEXT
Dated
- 30 October 2026 Reply comments due on the FCC's universal service administration notice, FCC 26 52, WC Docket No. 26 173 (91 FR 55826).
- 2 November 2026 Brief in opposition due in United States v. Talbott, S. Ct. No. 26 272 (docket, extension granted 25 September 2026).
- 3 November 2026 Midterm elections, run with the USPS mail ballot rule's key provisions enjoined and without the SAVE America Act.
- 3 November 2026 Trial set to begin in Shilling v. United States in Tacoma, W.D. Wash.; the Ninth Circuit appeal argued 20 October 2025 is to be reargued after supplemental briefing (Gender Justice League tracker; government's petition).
- 16 November 2026 Social Security Administration ends alternative work schedules for its staff.
- 30 November 2026 SAFE Vehicles Rule III (91 FR 61988) takes effect.
- 1 December 2026 Deadline for HUD to make FY2026 Continuum of Care awards under the reopened competition, with the First Circuit stay in place.
- 3 December 2026 Scheduled military execution of Nidal Hasan by Army firing squad at Fort Hood, approved by the President on 2 October 2026 and announced by the Army on 7 October 2026; a Defense Department matter outside the DOJ death row (Military Times, 7 October 2026, pointer).
- 11 December 2026 The continuing resolution, Pub. L. 119 103, signed 2 September 2026, expires; State and international organization funding stays near fiscal 2026 levels until then (CRS R48956).
- 31 December 2026 Deadline for states to have Medicaid work requirement systems in place; the 80 hour monthly requirement applies from 1 January 2027 in expansion states.
- 31 December 2026 EXIM general authority and the China and Transformational Exports Program expire unless Congress extends them.
- 4 January 2027 Joint status report due in NTEU v. Vought on whether the stay of the layoff plan review should continue, if no CFPB director is confirmed by 3 January 2027.
- 4 January 2027 Talbott trial set to begin in the District of Columbia (Gender Justice League tracker; The Advocate).
- 4 February 2027 Earliest close of the limitations period for individual IEEPA refund suits at the Court of International Trade.
- 17 March 2027 End of the Section 702 certifications the FISC approved on 17 March 2026; without reauthorization, collection would then stop.
- 1 April 2027 Deadline to apply for reinstatement under the 20 March 2026 memorandum extending EO 14184 guidance.
- 1 April 2027 Statutory deadline cited in the chapter for the Census Bureau to send 2030 census subjects to Congress, the first marker for the citizenship question the chapter calls for.
- 1 October 2027 State share of SNAP benefits begins (fiscal 2028), 0 to 15 percent by payment error rate; states with very high error rates may delay to fiscal 2029 or 2030. The earliest permitted Thrifty Food Plan reevaluation date, which must be cost neutral.
- 31 December 2028 Last date for Alaska and Hawaii good faith exemptions from the SNAP time limit.
- 31 December 2030 The CBDC ban in section 1101 of Pub. L. 119 101 expires unless extended.
Likely, not scheduled
- A summary judgment ruling in Massachusetts v. Oz. Heard 22 October 2026; states must begin the work requirement on 1 January 2027.
- A district court ruling in United States v. California. Judge Carter heard the restraining order request on 27 October 2026 after the Ninth Circuit dismissed the government's emergency appeal on 26 October; he said he would appoint a special master to review the list of about 20,000 voters.
- Third reconciliation bill after the midterms. The Speaker has said the SAVE America Act rides in it, and it is the only vehicle in sight for Medicaid financing changes; the Senate parliamentarian is the obstacle for both.
- Appeal of the IEEPA refund class. The government opposed certification and appealed the earlier tariff rulings.
- A Section 338 ruling. The 20 October suit is the first test of a 1930 provision not used in decades; a preliminary ruling in the trade court is the next marker.
- A Title IX proposed rule on gender identity. The Education Department said further changes to match the 2025 executive orders are planned.
- Removals at the remaining independent boards. Trump v. Slaughter removed the legal barrier; the Federal Reserve, which the Court set apart in 2025, is the next line to be tested.
- Fiscal 2027 appropriations fight over the rescinded 810 million. GAO called the withholding unlawful and Senator Collins said she would act; restoration or a suit are the two paths.
- Senate vote on Brian Johnson as CFPB director. Reported by the Banking Committee 13 to 11 on 17 September 2026; confirmation restarts district court review of the 556 person staffing plan.
- Final SEC rescission of the climate disclosure rules. Comments closed 3 August 2026; the SEC told the Eighth Circuit on 31 August 2026 the rulemaking was still underway.
- House vote on H.R. 10184. The Consumer Financial Protection Accountability and Reform Act of 2026, reported by Financial Services 28 to 21 on 16 September 2026, would move CFPB funding into annual appropriations.
- A D.C. Circuit ruling on the USAGM appeals. Briefing was ordered on 31 March 2026 in Nos. 26 5086 and 26 5087; the stay keeps 420 staff on leave until then.
- DOL final independent contractor rule. Under OIRA review since 28 September 2026 as economically significant; publication would end the 2024 rule for private litigation as well as enforcement.
- First NLRB decisions overruling Biden era precedents. GC 26 04 lists Miller Plastic, Lion Elastomers II, Cemex, Stericycle, McLaren Macomb and others; the three member Republican majority has sat since August 2026.
- DOL final joint employer rule. Comments on the April 2026 proposal closed 22 June 2026; no OIRA submission found.
- A public count of NSC staff. No primary source states the NSC staff size after the May 2025 cut; a figure would come from an EOP budget justification or official statement.
- Fiscal 2026 deregulation results. OIRA's count for the first full fiscal year under EO 14192, measured against agency cost allowances; the Unified Agenda projected 1.5 trillion dollars in savings.
- Fall 2026 Unified Agenda. The next agenda, including the independent agencies now inside OIRA review.
- Supreme Court decision on the Talbott petition. The government asks the Court to reverse the D.C. Circuit so discharges of currently serving transgender members can proceed.
- Fiscal 2027 Golden Dome funding. About 97 percent of the 17.5 billion dollar request depends on a second reconciliation bill, which Senator Thune said on 15 September 2026 would probably wait until after the elections.
- General officer cuts. The chapter's call to reduce the number of generals (page 104) is a candidate for a further row; not researched in this batch.
- A ruling on the motion to dismiss in Pacito v. Trump. Briefing closed 11 August 2026 in the W.D. Wash. challenge to the refugee suspension; IRAP's timeline shows no ruling as of this pass.
- Further international organization withdrawals. The 7 January 2026 memorandum says the President's review of further findings under EO 14199 is ongoing; no second memorandum was found as of 22 October 2026.
- A Ninth Circuit decision in AFGE v. Trump. The appeal of the vacated injunction against agency reorganizations, including State's, remains pending (AFSA tracker, 7 October 2026).
- Fiscal 2027 Intelligence Authorization Act. S. 4615 was reported 14 to 3 and placed on the Senate calendar 20 May 2026; H.R. 9624 was before the House committee on 20 July 2026. The Senate bill's title III would repeal the National Intelligence Management Council, the IC Chief Data Officer, and the Joint Intelligence Community Council and restructure the deputy DNI positions; it sets no ODNI headcount.
- Final SNAP administrative cost sharing rule. Comments on 91 FR 37837 closed 8 September 2026; the 25 percent federal share already applies by statute from 1 October 2026.
- Agricultural Act of 2026. Reported by the Senate Agriculture Committee 16 September 2026 after the House passed H.R. 7567 on 30 April 2026; NACo reports the Senate bill would delay the SNAP benefit cost share by one year and raise the maximum state share to 20 percent for error rates above 10 percent from fiscal 2031. Senate floor action is not expected before the November 2026 election.
- A ruling on the CP2 LNG export petition. Sierra Club and NRDC v. Wright, D.C. Cir. No. 26 1036, filed 17 February 2026 against DOE Order 5264 A and the NEPA categorical exclusion; no argument date found.
- Thakur v. Trump summary judgment. N.D. Cal. No. 3:25 cv 4737, hearing set for October 2026 over 13 DOE awards terminated on 1 October 2025, about 1.26 billion dollars, after DOE stipulated to political discrimination on 15 July 2026 (DOE Alumni Network pointer).
- Fiscal 2027 Energy and Water appropriation. House committee reported H.R. 9022 on 22 April 2026 with 1.850 billion dollars for the Critical Minerals and Energy Innovation office against a 1.122 billion request and 300 million for ARPA E (CRS R48944); no Senate committee action found.
- Final appliance standard rescissions. DOE's 2025 proposals to rescind 17 product standards and its July 2026 process rule are pending final action.
- Final mixed status verification rule. Under OIRA review since 17 September 2026 with a November 2026 agenda target; it would end indefinite prorated assistance for mixed status families.
- Final HUD work requirement and term limit rule. The regulatory agenda targeted September 2026 but the rule had not reached OIRA by 22 October 2026; agencies and owners would then choose whether to adopt it.
- First Circuit merits ruling on the FY2026 CoC notice. The stay panel found HUD likely to succeed on the notice and comment question; plaintiffs have moved for summary vacatur and remand.
- DOJ proposed rule on capital clemency petitions. Announced on 24 April 2026 for the coming weeks; it would bar capital inmates from filing clemency petitions until direct appeal and first collateral review are final. Not found in the Federal Register as of 22 October 2026.
- Rulings on remaining desegregation dismissal motions. DOJ said on 24 September 2026 that it is reviewing the remaining 1960s and 1970s cases case by case.
- Fourth Circuit decision on the FBI headquarters appeal. The Justice Department noticed its appeal of the 17 August 2026 judgment on 19 August 2026.
- First Circuit review of SAFE Vehicles Rule III. California and 26 other petitioners filed on 2 October 2026; briefing schedule not found.
- A ruling in California v. United States, N.D. Cal.. The motion to dismiss was argued on 19 February 2026 and taken under submission.
- D.C. Circuit appeal on the reclassified waivers. EPA appealed Judge Howell's 2 September 2026 injunction on 14 September 2026.
- A Federal Circuit ruling on the VA abortion rule. Minority Veterans of America's petition for review under 38 U.S.C. 502, Fed. Cir. No. 26 1861, was filed in May 2026; no later filings found.
- First Circuit decision in Rhode Island v. Trump. Argued 16 September 2026; would settle whether the vacatur and permanent injunction covering MBDA stand.
- Senate Banking Committee markup of S. 3772. Hearing held 26 March 2026; no markup found as of 22 October 2026.
- Year end vehicle for an EXIM extension. The continuing resolution runs through 11 December 2026 and the fiscal 2027 defense authorization is pending; neither has been reported to carry an EXIM extension (ELFA, October 2026).
- Senate action on a permanent CBDC ban. S. 1124, the Senate companion to H.R. 1919, sits in the Banking Committee.
- Final rule on monetary based size standards. SBA proposed on 22 August 2025 (90 FR 41168) to raise dollar based size standards for 263 industries; comments closed 21 October 2025 and no final rule has been found; the chapter's own ask is a medium sized business class created by Congress.
- More Delete, Delete, Delete repeals. The FCC issued seven direct final rules in GN Docket No. 25 133 between August 2025 and March 2026 and called the seventh the end of the first phase; none has been published since June 2026.
- Senate action on the FEC nominees. Confirming Stow and Woodson would restore a four member quorum; as of 17 October 2026 the Senate had not acted and the nominations lapse when the 119th Congress ends in January 2027.
- A proposed COPPA amendment on age verification. Promised in the FTC's 25 February 2026 policy statement; no date given and none published through 22 October 2026.
- One Agency Act (H.R. 384 and S. 1059). Would move FTC antitrust enforcement to the Justice Department, the chapter's other structural option; H.R. 384 (Rep. Cline) was introduced 14 January 2025 and S. 1059 (Sen. Lee) on 13 March 2025, both referred to the Judiciary Committees; no later action confirmed.
Dated items come from dockets, rules, and statutes. The likely items are the ledger's reading of stated plans and past behavior, not announcements, and each names its basis. When one of them lands it moves to the table above with a date and a document.
Changed since 2 October 2026
- Added: Chapter 15, Housing and Urban Development, three rows: Housing First ended in Continuum of Care grants (Partly blocked), and proposed rules on work requirements and term limits and on mixed status families (In motion).
- 22 October 2026: eighteen chapters added, 47 rows, each verified against the Mandate text and a primary document; the ledger now covers all thirty chapters.
- Added: Chapter 18, Department of Labor, four rows: the overtime threshold held at the 2019 level, the independent contractor rule at OIRA, the joint employer standard, and the NLRB general counsel's reversal list.
- Added: Chapter 8, Media Agencies, three rows: USAGM cut to its statutory minimum (Partly blocked), the Corporation for Public Broadcasting defunded and dissolved, and NPR and PBS noncommercial status (Not started).
- Added: Chapter 27, Financial Regulatory Agencies, four rows: the CFPB wind down (Partly blocked), SEC climate disclosure repeal (In motion), PCAOB reconstituted by the SEC, and the narrowed small business lending data rule.
- Added: the Department of Education repealed the 2024 Title IX rule and restored the 2020 regulations by final rule on 29 September 2026, counted as Done under the Education chapter.
- Added to Related: the 25 September pocket rescission of 810 million dollars, which GAO found unlawful on 29 September; the funds expired 30 September.
- Election: on 15 October the Justice Department sued California and Los Angeles County to set aside mail ballots cast by about 20,000 people the department calls likely noncitizens; on 26 October the Ninth Circuit dismissed its emergency appeal, 2 to 1, and the district court heard the request on 27 October.
- Federal unions: on 2 October a First Circuit panel stayed a ruling that the VA union contract ran past 8 August, and the VA told employees on 13 October the contract no longer applies.
- Tariffs: Customs opened phase three of IEEPA refunds on 6 October, the trade court certified a refund class on 8 October, and on 20 October the first suit against the Section 338 tariffs on Canadian goods was filed.
- USAID: GAO's 30 September report counts about 6,780 of 7,510 awards terminated, about 90 percent; the earlier 83 percent figure counted programs.
- Medicaid block grants moved from In motion to Not started: no bill or reconciliation instruction carries them.
- Corrected: ICE funding is Done; the Secure America Act was signed 10 June 2026. The DHS funding lapse ended 30 April 2026, not in March, and the fall 2025 shutdown lasted 43 days.
- Relabeled: federal control of election administration, Social Security restructuring, the SAVE America Act, and the removal power ruling now sit in their own section, because the ledger has not confirmed a Mandate recommendation for each.
- Moved up from Coming Next: civil service appeals and Section 1557 gender identity protections, both already in effect.
- Medicaid work requirements: Judge Stearns held the summary judgment hearing in Massachusetts v. Oz, the challenge by 23 states, the District of Columbia, and two governors, on 22 October; no ruling yet, so the row stays In motion.
- Watch: in the VA union case, AFGE asked the district court on 16 October for an indicative ruling to modify the injunction, and the Justice Department opposed an expedited schedule on 19 October.
DONE OR IN EFFECT
The latest 8 are shown; the rest open on request, or through any filter or chart mark.
The federal civilian workforce fell 10.3 percent in 2025, a net loss of about 238,000 jobs, with 348,219 separations in OPM data. GAO counts nearly 378,000 separations at 22 large agencies. The DOGE temporary organization ended on 4 July 2026 under EO 14158.
The Mandate said about p. 78
Reducing the number of federal employees seems an obvious way to reduce the overall expense of the civil service, and many prior Administrations have attempted to do just this.
What landed Beyond the text
Ch. 3 treats headcount cuts as hard and favors contractors; the administration used deferred resignations and reductions in force to cut about 238,000 jobs in a year, further than the chapter expected.
CostGAO found deferred resignations drove separations in the second half of 2025, alongside reductions in force at agencies including Education, HHS, and USAID.
OPM finalized the schedule on 6 February 2026, and on 3 June the President moved about 8,000 career positions into it, about 97 percent at GS 15 or above. Suits by NTEU in the District of Columbia and by PEER and other unions in Maryland are pending with no ruling.
The Mandate said about p. 81
It should be reinstated, but SES responsibility should come first.
What landed As written
Delivered as written: Schedule F was reinstated under a new name by executive order on day one and made final by OPM rule in 2026.
CostCRS says these employees appear to lose chapter 75 notice and appeal procedures, and the rule rescinds the 2024 appeal right for reclassified positions.
NextSuits in the District of Columbia and Maryland argue the rule exceeds the Civil Service Reform Act; no ruling yet, and the rule applies while they proceed.
OPM reference materialsCRS LSB11412Federal News Network, June 2026
GAO reports USAID terminated about 6,780 of its 7,510 awards, which carried $79.1 billion in obligations, and its staff fell from about 13,600 to 241 by April 2026. About $52.1 billion in surviving awards now sits at State, which GAO found had no documented guidance for its funding decisions.
The Mandate said p. 254
The next conservative Administration should scale back USAID's global footprint by, at a minimum, returning to the agency's 2019 pre-COVID-19 pandemic budget level.
What landed Beyond the text
Went beyond the recommendation: the chapter asked for a cut to 2019 levels and deradicalized programs; the agency was closed and about 90 percent of awards terminated.
CostA Lancet study projected more than 14 million additional deaths by 2030, including more than 4.5 million children under five, if the defunding continues. Food for Peace bought about $2 billion of American farm commodities a year.
The law is phasing in on its statutory schedule. Provisions effective 1 October 2026 ended Medicaid eligibility for some lawfully present immigrants and raised the state share of SNAP administration to 75 percent; work requirements begin no later than 1 January 2027.
The Mandate said p. 696
The corporate income tax rate should be reduced to 18 percent.
What landed Different route
Delivered differently: the law made the 2017 individual rates permanent and kept the corporate rate at 21 percent rather than the chapter's 18, while carrying the Medicaid and SNAP changes the HHS and USDA chapters asked for.
CostCBO estimates that, on average from 2026 to 2034, the law raises resources for the top tenth of households by about $13,600 a year and lowers them for the bottom tenth by about $1,200 a year, or 3.1 percent of income. It provides about $75 billion for ICE and ends credits for wind and solar projects placed in service after 2027 unless construction began by 4 July 2026.
The 30 April 2026 law that ended the DHS funding lapse left out ICE and Border Patrol, with no new limits on agents. Their money came six weeks later in the Secure America Act, passed 52 to 47 in the Senate and 214 to 212 in the House.
The Mandate said p. 143
Congress should fund ICE for at least 20,000 ERO officers and 5,000 Office of the Principal Legal Advisor (OPLA) attorneys.
What landed As written
Delivered through two statutes, the 2025 reconciliation law's enforcement money and the Secure America Act of June 2026; the ledger has not matched the appropriations to the chapter's 20,000 officer and 100,000 bed targets.
CostAbout $69.5 billion through fiscal 2029, including $38.5 billion for ICE, on top of the roughly $75 billion in the One Big Beautiful Bill Act. Congress attached no mask, warrant, or sensitive location limits to either.
HHS announced a reduction in force of about 10,000, with about 10,000 more leaving through early retirement and resignation, and separated most of the affected staff on 14 July 2025. A Rhode Island injunction of 1 July 2025 kept some CDC, FDA, and Head Start staff in place, and the states' suit continues after the court denied dismissal on 7 April 2026.
The Mandate said p. 452
The CDC should be split into two separate entities housing its two distinct functions.
What landed Partly
Delivered in part: the March 2025 reorganization cut about 20,000 HHS staff including CDC, with some positions held by a Rhode Island injunction; the formal two entity split of the CDC has not been enacted.
CostFDA, CDC, NIH, and CMS all lost staff. The Public Data Observatory estimated CDC working staff fell about 30 percent from March 2025 to May 2026, an outside estimate rather than an official count. CDC delayed its annual abortion surveillance report; HHS and former CDC officials dispute why.
HHS release, 27 March 2025HHS fact sheetCBS News Atlanta, 2 October 2026
Since 2 September 2026 the Merit Systems Protection Board no longer hears appeals of probationary firings, reductions in force, or suitability actions, and OPM decides reduction in force appeals instead. After Trump v. Slaughter the board stopped describing itself as independent.
The Mandate said p. 76
The EEOC's federal employee section should be transferred to the MSPB, and many of the OCS's investigatory functions should be returned to the OPM. The MSPB could then become the main reviewer of adverse actions, greatly simplifying the burdensome appeal process.
What landed Not in the Mandate
Delivered in the opposite direction: the chapter wanted the MSPB as the main reviewer; the 2026 rules moved appeals toward OPM instead.
CostA federal worker laid off in a reduction in force now appeals to the agency that runs the layoff policy.
MSPB rule, 12 August 2026OPM rule, 3 August 2026Federal News Network, July 2026
A federal court vacated the gender identity provisions of the 2024 Section 1557 rule, and HHS stopped enforcing them by notice on 2 June 2026. HHS says the rule's other protections, including disability, stay in force.
The Mandate said p. 495
HHS should restore Section 1557, Section 504, and other OCR regulations and fix guidance documents.
What landed As written
Delivered by a court and then by notice: Tennessee v. Kennedy vacated the gender identity provisions and HHS stopped enforcing them, which is what 'restore' meant in the chapter.
CostPatients have lost the federal rule that barred gender identity discrimination by health programs that take federal money. Separately, on about 23 September 2026 a Texas court vacated the Section 504 rule's community integration requirement, with HHS supporting the request.
HHS notice, 91 FR 32887HHS release, 1 June 2026Stateline, 2 October 2026
EPA rescinded its 2009 finding and every vehicle greenhouse gas standard that rested on it, effective 20 April 2026. Four petitions for review are pending in the D.C. Circuit, including one brought by 24 states.
The Mandate said p. 425
Establish a system, with an appropriate deadline, to update the 2009 endangerment finding.
What landed Beyond the text
Went beyond the recommendation: the chapter asked to update the finding; EPA rescinded it outright by final rule in April 2026.
NextConsolidated challenges by two dozen states, ten cities, and environmental groups are pending in the D.C. Circuit; a request to stay the repeal was denied, so it stays in force through briefing.
DHS rescinded the 2022 regulations and returned to case by case review under the totality of circumstances, in which officers may weigh any means tested benefit received on or after 18 September 2026, the rule's effective date.
The Mandate said p. 145
The regulatory agenda should include the immediate submission of notices of proposed rulemaking for the Trump Administration's public charge rule (including aspects from its original notice of proposed rulemaking), temporary work visa reform, employment authorization reform rules, asylum bars rule, and a third-country transit rule.
What landed As written
Delivered as written: DHS reissued the public charge rule, final in September 2026.
The Fish and Wildlife Service reinstated rules that make it easier to exclude land from critical habitat for economic or other impacts. The rule applies to designations finalized after 20 August 2026.
The Mandate said p. 524
Rescind the Biden rules and reinstate the Trump rules regarding: 1. BLM waste prevention; 2. The Endangered Species Act rules defining Critical Habitat and Critical Habitat Exclusions.
What landed As written
Delivered as written by the Fish and Wildlife Service final rule of August 2026.
FinCEN exempted every company created in the United States and every U.S. person from Corporate Transparency Act reporting, and will delete the data U.S. persons already filed. About 28,000 foreign companies still report.
The Mandate said p. 707
Congress should repeal the Corporate Transparency Act, and FinCEN should withdraw its poorly written and overbroad beneficial ownership reporting rule.
What landed Partly
Delivered by rule rather than repeal: Congress kept the Act, FinCEN exempted every U.S. company, which is the practical result the chapter wanted.
HHS terminated all but about a dozen Teen Pregnancy Prevention Program grants, worth about $66 million, months after Congress appropriated $101 million for the program.
The Mandate said p. 477
Both programs should ensure that there is better reporting of subgrantees and referral lists so that they do not promote abortion or high-risk sexual behavior among adolescents. CMS should ensure that Sexual Risk Avoidance (SRA) proponents receive these grants and are given every opportunity to prove their effectiveness.
What landed Beyond the text
Went beyond the recommendation: the chapter wanted the grants redirected to abstinence programs; HHS canceled them.
After the Court struck the IEEPA tariffs, a 10 percent Section 122 surcharge ran from 24 February to 24 July 2026. Section 301 duties of 10 or 12.5 percent on 60 economies have applied since 24 July, a 50 percent Section 338 tariff on listed Canadian goods since 19 August, and existing Section 232 duties remain.
The Mandate said p. 770
Instead, in order to uphold the principle of reciprocity, the U.S. raises its tariffs to mirror levels.
What landed Different route
Delivered through Sections 232, 301 and 338 after the IEEPA route failed. The trade chapter is a debate: Navarro's case for reciprocal tariffs sits beside Lassman's case for free trade, and the book takes no side.
CostThe Tax Foundation estimates about $820 per household in 2026 (10 September 2026); the Yale Budget Lab estimated about $1,100 a year under the law as of 24 July 2026, before the Canada tariff.
NextThe first suit against the Section 338 duties on Canadian goods was filed 20 October 2026; Section 338 had not been used in decades before this year, so whether it supports across the board duties is an open question.
On 29 September 2026 the Department of Education published a final rule, Recodification of Title IX Rules, that repeals the 2024 Title IX regulations and restores the 2020 text to the Code of Federal Regulations, effective on publication. The 2024 rule, which read sex discrimination to include gender identity, had been vacated by federal courts in January 2025, so schools have followed the 2020 procedures since then; the repeal makes that permanent in the regulations. The department says further Title IX changes to match the 2025 executive orders on gender are planned.
The Mandate said p. 333
Commence a new agency rulemaking process to rescind the current Administration's Title IX regulations; restore the Title IX regulations promulgated by then-Secretary Betsy DeVos on May 19, 2020; and define 'sex' under Title IX to mean only biological sex recognized at birth.
What landed As written
Delivered as written by the September 2026 final rule, with the definition of sex still to come in a further rulemaking the department says is planned.
CostStudents lose the regulatory text that treated gender identity harassment as sex discrimination, and schools return to the 2020 hearing and cross examination procedures for harassment complaints.
NextThe department says further Title IX changes to match the 2025 executive orders on gender are planned; expect a proposed rule rather than guidance, because the repeal itself went through notice and comment.
Final rule, public inspection, FR Doc. 2026 19929Inside Higher Ed, 29 September 2026
The House passed reconciliation text on 22 May 2025 that would have abolished the PCAOB and moved its functions into the SEC, but the Senate parliamentarian ruled on 19 June 2025 that it violated the Byrd rule and the provision was dropped from the enacted law. Chairman Erica Williams left in July 2025 at SEC Chairman Paul Atkins's request. The SEC approved on 22 January 2026 a PCAOB budget of $362.1 million, 9.4 percent below 2025, with board chair pay cut 52 percent and member pay 42 percent. The SEC appointed a new chairman, Demetrios Logothetis, and new members on 30 January 2026; they were sworn in on 10 February 2026. No bill to merge the PCAOB or FINRA into the SEC has advanced since.
The Mandate said p. 830
To reduce costs and improve transparency, due process, congressional oversight, and responsiveness, PCAOB and FINRA should be abolished, and their regulatory functions should be merged into the SEC.
What landed Partly
The merger the chapter asked for passed the House and was stripped in the Senate on procedural grounds; what landed is SEC control of a smaller, repopulated PCAOB. Nothing has been done about FINRA.
CostThe PCAOB is funded by an accounting support fee on issuers and broker dealers; the 2026 budget the SEC approved is 37.6 million dollars lower than 2025 (SEC, 22 January 2026).
NextSEC action on the PCAOB's QC 1000 amendments (comments closed 9 October 2026) and the board's final 2026 to 2030 strategic plan.
Atkins statement on PCAOB 2026 budget, 22 January 2026PCAOB release, new board sworn in, 10 February 2026Parliamentarian ruling on PCAOB provision (pointer: VitalLaw)
The CFPB proposed on 13 November 2025 to revise the 2023 rule implementing Dodd Frank section 1071, which had been enjoined and repeatedly delayed. The final rule, published 1 May 2026 and effective 30 June 2026, raises the lender threshold from 100 to 1,000 covered originations in each of two years, lowers the small business revenue ceiling from $5 million to $1 million, excludes merchant cash advances, agricultural loans, and loans of $1,000 or less, and drops several data points including pricing and denial reasons. Compliance begins 1 January 2028. The statute itself has not been repealed.
The Mandate said p. 839
Repeal Dodd–Frank Section 1071. This section, which relates to small-business data collection, imposes requirements on financial institutions’ lending to small firms, raises costs, and limits small businesses’ access to capital.
What landed Partly
The chapter asked Congress to repeal the section; the CFPB instead kept the statutory mandate and cut its reach by rule, by its own estimate still capturing 92 to 93 percent of depository small business loans.
NextData collection starts on 1 January 2028; a separate rulemaking on privacy and publication of the data is planned.
The Rescissions Act of 2025, signed 24 July 2025, cancelled about 1.1 billion dollars in advance appropriations for the Corporation for Public Broadcasting covering fiscal 2026 and 2027. CPB let most of its staff go at the end of September 2025, its board voted unanimously on 10 December 2025 to dissolve, and it announced the vote on 5 January 2026, with articles of dissolution to follow at the end of January. Separately, Judge Moss held on 31 March 2026 that EO 14290, which ordered agencies to stop funding NPR and PBS, is viewpoint discrimination that violates the First Amendment, and enjoined its enforcement; claims against CPB were dismissed as moot.
The Mandate said p. 247
The 47th President can just tell the Congress—through the budget he proposes and through personal contact—that he will not sign an appropriations spending bill that contains a penny for the CPB.
What landed As written
Delivered as written and more: Congress rescinded the advance appropriations the chapter singled out, and the corporation itself dissolved, which the chapter did not ask for.
CostLocal stations lost the federal share of their budgets, which CPB passed through as community service grants.
NextWhether the government appeals the NPR v. Trump judgment; the funding cut stands either way because Congress made it.
Pub. L. 119 28CPB release, 5 January 2026EO 14290, 90 FR 19415NPR v. Trump, No. 1:25 cv 1674, opinion of 31 March 2026
The Eastern District of Texas vacated the 2024 overtime rule nationwide on 15 November 2024 in Texas v. U.S. Department of Labor, and the Northern District of Texas vacated it again on 30 December 2024 in Flint Avenue v. DOL. The 2024 rule had raised the salary threshold to 43,888 dollars on 1 July 2024 and scheduled 58,656 dollars for January 2025; the Wage and Hour Division has enforced the 2019 levels since the vacatur. The Fifth Circuit dismissed the government's appeals on 5 May and 7 May 2026. On 15 May 2026 DOL published a technical amendment removing the 2024 text from the Code of Federal Regulations and restoring the 2019 rule: 684 dollars a week (35,568 dollars a year) and 107,432 dollars for highly compensated employees. The amendment says it does not foreclose future rulemaking on the salary level, and no new threshold proposal appears on the 2026 Wage and Hour Division agenda.
The Mandate said p. 592
DOL should maintain an overtime threshold that does not punish businesses in lower-cost regions (e.g., the southeast United States). The Trump-era threshold is high enough to capture most line workers in lower-cost regions.
What landed As written
The Trump era threshold the chapter endorsed is the law again; the courts struck the 2024 increase and the administration dropped the appeals and restored the 2019 text. The chapter's idea of automatic updates every five years has not been taken up.
CostSalaried workers earning between 35,568 and 43,888 dollars who gained overtime eligibility on 1 July 2024 lost it with the vacatur. DOL's amendment states it is not significant under EO 12866 and gives no cost estimate.
NextNone scheduled; any change to the threshold would need a new notice and comment rule, and none is on the current regulatory agenda.
DOL technical amendment, 91 FR 27833, 15 May 2026Pointer: Foley Hoag on the amendment and dropped appeals, May 2026
The Eastern District of Texas vacated the NLRB's 2023 joint employer rule on 8 March 2024 in Chamber of Commerce v. NLRB, No. 6:23 cv 553. On 27 February 2026 the Board published a final rule, without notice and comment under the good cause exception, removing the 2023 text and reinstating the 2020 rule at 29 CFR 103.40, which requires substantial direct and immediate control over essential terms of employment. On 23 April 2026 DOL proposed a joint employer rule for the FLSA, FMLA, and MSPA using a four factor test: hiring and firing, supervision of schedules or conditions to a substantial degree, setting pay, and keeping employment records. DOL comments closed 22 June 2026.
The Mandate said p. 591
DOL and NLRB should return to the long-standing approach to defining joint employers based on direct and immediate control.
What landed Partly
The NLRB now applies the direct and immediate control test the chapter asked for, first through the court vacatur and then by rule. DOL has only proposed its version, a four factor test close to its 2020 rule, and Congress has not passed the Save Local Business Act.
NextA DOL final joint employer rule under RIN 1235 AA48; no date is set.
NLRB final rule, FR Doc. 2026 03955 (public inspection copy)NLRB final rule, federalregister.govDOL NPRM, 91 FR 21878, 23 April 2026DOL Wage and Hour Division NPRM page
NSPM 1, signed 20 January 2025, set out a single NSC staff serving both the National Security Council and the Homeland Security Council; it has no provision on detailees. On 23 January 2025 about 160 NSC aides, mostly career detailees from State, the FBI, and the CIA, were told to stay home pending a staffing review, and many were sent back to their home agencies, according to the Associated Press. On 23 May 2025 Axios reported that President Trump and Secretary of State Marco Rubio, acting as National Security Adviser, were cutting the staff of about 350 by roughly half, to about 175, with those cut moved to other government posts. No primary document giving the current NSC staff count has been found.
The Mandate said p. 38
Special attention should be given to the use of detailees to staff the NSC. In recent years, the NSC’s staff size has been rightsized from its peak of 400 in 2015 down to 100–150 professional members. The next Administration should try to limit the number of detailees to ensure more direct presidential control.
What landed As written
The chapter asked the next administration to limit detailees and keep the staff near 100 to 150; detailees were sent home in the first week and the staff was halved in May 2025 to a reported 175. Chapter 2 makes the same recommendation in stronger terms, asking that all nonessential detailees go back on the first day (p. 52).
NSPM 1, Organization of the National Security Council and Subcommittees, DCPD 202500151Associated Press via Fortune, 23 January 2025 (pointer)Axios, 23 May 2025 (pointer)
EO 14215, signed 18 February 2025, amended EO 12866 so that independent regulatory agencies must submit significant proposed and final rules to OIRA before publication; it also told OMB to review those agencies' obligations and adjust their apportionments, required each to set up a White House Liaison, and made the President's and Attorney General's legal opinions controlling on all executive branch employees. The Federal Reserve is excluded for monetary policy and covered only for bank supervision and regulation. OMB memorandum M 25 24 of 17 April 2025 named 19 independent agencies plus the FEC and required full compliance by 21 April 2025. The FTC, for example, announced on 30 January 2026 that OIRA had found its planned rental housing fees ANPRM significant and that it had submitted the draft for review. A DNC suit against the legal interpretation section as applied to the FEC was dismissed for lack of standing on 3 June 2025.
The Mandate said p. 49
Regulatory analysis and OIRA review should also be required of the historically “independent” agencies as the Office of Legal Counsel has found is legally permissible.
What landed Beyond the text
Delivered as the chapter asked, by amending EO 12866; the order went further by reaching independent agencies' apportionments and legal positions and by placing White House Liaisons inside them. The GW Regulatory Studies Center counted 30 of 202 proposed rules from 14 independent agencies in the first year as significant and so reviewed by OIRA.
NextThe fall 2026 Unified Agenda, which will list the independent agencies' rules headed for OIRA review; the Court's 29 June 2026 Slaughter ruling, covered in the removal power row, removes the main legal argument against this control for agencies that exercise executive power.
EO 14215, 90 FR 10447OMB M 25 24, 17 April 2025FTC release, 30 January 2026DNC v. Trump, D.D.C. No. 25 587, opinion of 3 June 2025GW Regulatory Studies Center, 1 September 2026 (analysis)
EO 14192, signed 31 January 2025, requires an agency to identify at least ten existing regulations for repeal for each new one and required that the total incremental cost of new regulations in fiscal 2025 be significantly less than zero. The same order revoked the 2023 revision of OMB Circular A 4 and reinstated the 2003 version, and reinstated the 2018 Treasury and OMB agreement on review of tax regulations; EO 14148 of 20 January 2025 had already revoked EO 14094, the 2023 changes to EO 12866. OMB issued implementing guidance in M 25 20 on 26 March 2025, and M 25 36 of 21 October 2025 set a presumptive maximum of 28 days for OIRA review of deregulatory actions. OIRA reported 646 deregulatory actions against 5 significant regulatory actions in fiscal 2025, and the 2026 Unified Agenda, published 14 August 2026, projects 1.5 trillion dollars in savings for fiscal 2026.
The Mandate said p. 49
The next President should also reinstate the many executive orders signed by President Trump that were designed to make the regulatory process more just, efficient, and transparent. Executive Orders 13771, 9 13777, 10 13891, 11 13892, 12 13893, 13 13924 Section 6, 14 13979, 15 and 13980 16 should be revived (with modifications as needed).
What landed Beyond the text
The chapter asked to revive EO 13771, the two for one order and regulatory budget; EO 14192 brought it back at ten for one with a fiscal 2025 cost cap below zero. The same order delivered the chapter's asks to undo the 2023 Circular A 4 and keep OIRA review of Treasury tax rules.
CostOIRA reported 211.8 billion dollars in cost savings for fiscal 2025 (December 2025). The GW Regulatory Studies Center found on 18 March 2026 that 428 of the 646 actions were guidance or internal documents and that Treasury notices, none of them rulemakings, made up 61 percent of the savings.
NextOIRA's report of fiscal 2026 results against the agency cost allowances, now due after the fiscal year closed on 30 September 2026.
EO 14192, 90 FR 9065OMB M 25 20, 26 March 2025OMB M 25 36, 21 October 2025OIRA, Regulatory Reform Results for Fiscal Year 2025Unified Agenda introduction, 91 FR 52792, 14 August 2026EO 14148, 90 FR 8237GW Regulatory Studies Center, 18 March 2026 (analysis)
EO 14148, signed on inauguration day, 20 January 2025, revoked EO 14020 of 8 March 2021, which had established the White House Gender Policy Council. Section 3(b) of the same order directed the Domestic Policy Council and National Economic Council to review all federal actions taken under the revoked orders and to rescind, replace, or amend them. The order revoked the councils' founding orders without separate language on staff.
The Mandate said p. 62
The President should immediately revoke Executive Order 14020 41 and every policy, including subregulatory guidance documents, produced on behalf of or related to the establishment or promotion of the Gender Policy Council and its subsidiary issues.
What landed As written
Delivered on the first day as the chapter asked, with a directive to unwind actions taken under the revoked order. The chapter's companion ask, a Special Assistant to the President for life and family issues in the Domestic Policy Council, has not been confirmed.
EO 14183 of 27 January 2025 declared the military's readiness standards inconsistent with the medical, surgical, and mental health constraints of gender dysphoria, and a Pentagon policy memo of 26 February 2025 set out separation of members with that history, offering voluntary separation pay or involuntary separation. Judge Reyes enjoined the policy in Talbott, No. 1:25 cv 240 (D.D.C.), on 18 March 2025, and the D.C. Circuit stayed that injunction on 27 March 2025; on 6 May 2025 the Supreme Court stayed the Shilling injunction from the Western District of Washington, No. 2:25 cv 241, letting the policy take effect. On 1 June 2026 a divided D.C. Circuit affirmed the Talbott injunction for the currently serving named plaintiffs, finding the policy likely violates equal protection, and vacated it for plaintiffs seeking to enlist. The district court certified a class on 30 June 2026 of transgender people serving, formerly serving, or seeking accession on or after 28 January 2025, according to plaintiffs' counsel. The Justice Department petitioned for certiorari on 27 August 2026; the response is due 2 November 2026 after an extension granted on 25 September 2026. As of 9 October 2026 the D.C. Circuit had not issued its mandate, the government having asked that it be held while the petition is pending, so the affirmed injunction was not in force and separation proceedings against the named plaintiffs, including Talbott, were continuing, according to The Advocate. The Ninth Circuit appeal in Shilling, No. 25 2039, argued 20 October 2025, is to be reargued after supplemental briefing on West Virginia v. B.P.J., according to the government's petition.
The Mandate said p. 104
Reverse policies that allow transgender individuals to serve in the military. Gender dysphoria is incompatible with the demands of military service, and the use of public monies for transgender surgeries or to facilitate abortion for servicemembers should be ended.
What landed As written
The order and the Hegseth policy carry out the chapter's bar on service and the expulsion it called for on page 103, and both the accession bar and separations are in force. The D.C. Circuit has affirmed an injunction against discharging the currently serving Talbott plaintiffs, but that ruling awaits the court's mandate while the government seeks Supreme Court review.
NextThe respondents' brief in opposition is due 2 November 2026 in No. 26 272, followed by a Supreme Court decision on whether to take the case; trial is set for 3 November 2026 in Shilling and 4 January 2027 in Talbott.
EO 14183, 90 FR 8757Supreme Court order in No. 24A1030, 6 May 2025Talbott v. United States, D.C. Cir. No. 25 5087, opinion of 1 June 2026 (Justia copy)United States v. Talbott, S. Ct. No. 26 272, docketPetition for certiorari, 27 August 2026Class certification of 30 June 2026, GLAD Law (counsel for plaintiffs), pointerMandate not issued, separations continuing, The Advocate, 9 October 2026, pointerGender Justice League lawsuit tracker, 14 September 2026, pointer
EO 14184 of 27 January 2025 directed the services to reinstate, at their request, members involuntarily separated for refusing the COVID vaccine, with former rank, full back pay, and benefits. Defense Department guidance issued in 2025 gave involuntarily separated members back pay net of interim earnings and VA benefits and set an application deadline of 1 April 2026; on 24 April 2025 Secretary Hegseth ordered adverse actions removed and discharges upgraded. By memorandum of 20 March 2026, announced 23 March 2026, he extended the window to 1 April 2027 and cut the return service obligation from four years to two. A Pentagon official said in July 2026 that more than 230 former members had returned, out of nearly 8,000 involuntarily separated by the Pentagon's count (more than 8,700 on the department's reinstatement website); the Coast Guard reinstated 56 in February 2026.
The Mandate said p. 103
Reinstate servicemembers to active duty who were discharged for not receiving the COVID vaccine, restore their appropriate rank, and provide back pay.
What landed As written
The order offers exactly what the chapter asked: return to duty, rank, and back pay. Fewer than 3 percent of those separated had come back by July 2026.
CostBack pay covers base pay and housing and subsistence allowances, less civilian earnings and VA benefits received in the interim (Defense Department guidance, 2025); EO 14184 also provides for bonus payments. No department total has been published.
NextThe reinstatement window closes 1 April 2027; a National Academy of Public Administration review of the mandate is expected by the end of 2026.
EO 14184, 90 FR 8761Defense Department return guidance, 2025 (Air University copy)Defense Secretary orders additional remedies, 24 April 2025 (JBSA copy)Pentagon News, deadline extended to 1 April 2027, 23 March 2026 (Army copy)NGAUS, 24 March 2026, links the 20 March 2026 memorandum, pointerCoast Guard reinstates 56, DHS statement of 24 February 2026 via Spectrum News, pointerReturnee count, Military Times, 17 July 2026, pointer
EO 14185 of 27 January 2025 ordered the Secretary of Defense to abolish every DEI office in the department, including sub offices, programs, and initiatives, and to report on an internal review within 90 days. The department set up a task force under the Under Secretary for Personnel and Readiness in February 2025, which reported on 1 March 2025 that the services had certified they used no race or sex based goals. GAO found on 17 April 2025 that the 41 DEI positions left after cuts under section 1101 of the fiscal 2024 NDAA, down from 188, had all been abolished or restructured, with none scheduled to remain after April 2025. The department also rescinded two DEI instructions and disbanded the Defense Advisory Committee on Diversity and Inclusion.
The Mandate said p. 103
Eliminate Marxist indoctrination and divisive critical race theory programs and abolish newly established diversity, equity, and inclusion offices and staff.
What landed As written
Delivered as written; Congress had already cut most DEI positions in the fiscal 2024 NDAA, and the order finished the job by eliminating the rest.
CostGAO did not estimate costs or savings from the abolition (GAO 25 107397, 17 April 2025).
EO 14185, 90 FR 8763GAO 25 107397, DOD DEI workforce reductions, 17 April 2025
EO 14155 of 20 January 2025 gave notice of withdrawal from the World Health Organization, and HHS states the United States formally exited on 22 January 2026 after the one year notice period, ending funding, recalling U.S. personnel from Geneva and WHO country offices, and stopping participation in WHO committees and technical groups. EO 14199 of 4 February 2025 ordered the Secretary of State to review U.S. membership in all international organizations, conventions, and treaties. Acting on that review, a presidential memorandum of 7 January 2026 directed agencies to withdraw from 66 bodies, 31 of them UN entities and 35 outside the UN system, including the UN Framework Convention on Climate Change, the IPCC, UN Women, and the UN Population Fund; the memorandum says further review is ongoing. The fiscal 2027 request would cut Contributions to International Organizations to 292.42 million dollars, 78.9 percent below fiscal 2026, and the House bill passed 15 July 2026 bars funds for the WHO.
The Mandate said p. 191
The next Administration should direct the Secretary of State to initiate a comprehensive cost-benefit analysis of U.S. participation in all international organizations.
What landed As written
The chapter asked for a cost benefit review with withdrawal as an option and tighter limits on WHO funding pending changes in its policies; EO 14199 ordered the review and the January 2026 memorandum acted on it, while the WHO exit went past conditioning funds to leaving outright, as the first Trump administration had begun to do.
CostHHS put U.S. assessed WHO dues at about 111 million dollars a year and voluntary contributions at about 570 million dollars a year. WHO says the United States left about 260.6 million dollars in assessed fees for 2024 and 2025 unpaid (Health Policy Watch, January 2026); the State Department's 22 January 2026 statement says all U.S. funding has ceased and that WHO claims compensation is owed.
NextSenate action on the fiscal 2027 National Security, Department of State, and Related Programs bill, which decides whether the cuts to UN contributions and the WHO funding bar become law.
EO 14155, public inspection copy, FR Doc. 2025 01957EO 14199, 90 FR 9275HHS fact sheet on WHO withdrawal, January 2026Presidential memorandum of 7 January 2026, 91 FR 2281State Department joint statement on WHO termination, 22 January 2026CRS R48956, FY2027 NSRP budget, 13 October 2026 (EveryCRSReport copy)Unpaid WHO fees, Health Policy Watch, pointer
Secretary Rubio announced a department reorganization on 22 April 2025 that removed redundant offices and ended nonstatutory programs, and the department notified Congress of the plan on 29 May 2025. On 8 July 2025 the Supreme Court stayed the injunction in AFGE v. Trump, No. 3:25 cv 3698 (N.D. Cal.), that had blocked reorganization plans under EO 14210, and on 11 July 2025 State sent reduction in force notices to about 1,350 employees, 1,107 civil service and 246 Foreign Service. A preliminary injunction in AFGE v. OMB, No. 3:25 cv 8302 (N.D. Cal.), delayed the Foreign Service separations from December 2025 until 5 May 2026, when State finalized them for nearly 250 Foreign Service and about 30 civil service employees. CRS reports the reorganization cut 1,680 positions funded by Diplomatic Programs (1,506 civil service, 174 Foreign Service) through deferred resignations and reductions in force, and that Foreign Service and civil service staffing fell from 27,230 on board at 30 September 2024 to 25,398 on board at 31 October 2025.
The Mandate said p. 193
The next Administration should develop a complete hypothetical reorganization of the department—one which would tighten accountability to political leadership, reduce overhead, eliminate redundancy, waste fewer taxpayer resources, and recommend additional personnel-related changes for improvement of function.
What landed Beyond the text
The chapter asked for a planned reorganization and an assessment of which office closures need congressional approval; the department carried out the reorganization within months and paired it with layoffs, which the chapter did not specify.
CostNo cost estimate for the reductions was found. GAO reported on 30 September 2026 that State could not produce staffing data for the period it requested, so the full scope of its workforce reductions is unknown (GAO 26 108607).
NextA Ninth Circuit decision in the pending appeal in AFGE v. Trump; AFGE v. OMB is on hold through the end of 2026 under a settlement reached 25 September 2026 that leaves the State separations in place.
Building an America First State Department, 22 April 2025 (GlobalSecurity mirror of the State release)Next Steps on Building an America First State Department, 29 May 2025 (GlobalSecurity mirror of the State release)Trump v. AFGE, No. 24A1174, order of 8 July 2025GAO 26 108607, 30 September 2026CRS R48956, FY2027 NSRP budget, 13 October 2026 (EveryCRSReport copy)AFSA lawsuit tracker, updated 7 October 2026RIF notice counts, July 2025, Federal News Network, pointerSeparations finalized, 5 May 2026, Federal News Network, pointer
EO 14163 of 20 January 2025 suspended the entry of refugees except where the Secretaries of State and Homeland Security jointly find an admission in the national interest. The fiscal 2026 determination, signed 30 September 2025, set a ceiling of 7,500 allocated primarily to Afrikaners from South Africa under EO 14204. On 5 March 2026 the Ninth Circuit held in Pacito v. Trump that the suspension was within the President's authority under 8 U.S.C. 1182(f), reversed the injunctions requiring continued processing and overseas funding, and affirmed the injunction requiring services to refugees already admitted. The fiscal 2027 determination, signed 25 September 2026, sets a ceiling of 17,500, again primarily for Afrikaners. In the district court, plaintiffs filed an amended complaint on 16 June 2026 and the government's motion to dismiss was fully briefed on 11 August 2026.
The Mandate said p. 178
The federal government’s obligation to shift national security–essential screening and vetting resources to the forged border crisis will necessitate an indefinite curtailment of the number of USRAP refugee admissions.
What landed Beyond the text
The chapter asked for an indefinite curtailment of admissions while vetting resources went to the border; the administration suspended refugee entry outright and directed the remaining ceiling mainly to one national group, which the chapter does not mention.
NextA ruling on the government's motion to dismiss the amended complaint in Pacito v. Trump, No. 2:25 cv 255 (W.D. Wash.).
EO 14163, 90 FR 8459Presidential Determination for FY2027, 91 FR 63119Presidential Determination for FY2026, DCPD 202500975Pacito v. Trump, 9th Cir. No. 25 1313, opinion of 5 March 2026Pacito case timeline, IRAP (counsel for plaintiffs), pointer
A presidential memorandum of 24 January 2025 reinstated the Mexico City policy. On 27 January 2026 State published a final rule, Protecting Life in Foreign Assistance, without notice and comment, effective 26 February 2026 for new awards and existing awards amended to add funds. The rule extends the abortion restriction beyond global health aid to grants, cooperative agreements, and voluntary contributions across nonmilitary foreign assistance, and to U.S. NGOs, public international organizations, and, at State's discretion, foreign governments and parastatals, with flow down to subrecipients and a waiver for the Secretary. Two companion rules published the same day apply the same structure to gender ideology and to discriminatory equity ideology. GAO treated the rule as a major rule in its report of 17 February 2026.
The Mandate said p. 192
The U.S. government should not and cannot promote or fund abortion in international programs or multilateral organizations.
What landed As written
Delivered as written: the rule bars abortion promotion across foreign aid programs and reaches multilateral organizations, which earlier versions of the policy did not. The chapter's coalition building under the Geneva Consensus Declaration was not checked.
CostState estimated a one time familiarization cost of 16,035,000 dollars and annual training and monitoring costs of 114,052,700 dollars for about 2,500 recipients (91 FR 3319, 27 January 2026). KFF estimated on 28 January 2026 that about 39.8 billion dollars in fiscal 2024 obligations to prime recipients in 160 countries would fall under the expanded policy.
NextAny court challenge to the January 2026 rules; none had been confirmed as of this draft.
Presidential memorandum of 24 January 2025, The Mexico City Policy, 90 FR 8753Protecting Life in Foreign Assistance, final rule, 91 FR 3319GAO major rule report B 338066, 17 February 2026KFF funding analysis, 28 January 2026
On 20 August 2025 DNI Tulsi Gabbard announced ODNI 2.0, which set out to reduce the office by over 40 percent by the end of fiscal 2025. The accompanying fact sheet eliminated the External Research Council and the Strategic Futures Group, folded the core functions of the Foreign Malign Influence Center, the National Counterproliferation and Biosecurity Center, and the Cyber Threat Intelligence Integration Center into Mission Integration and the National Intelligence Council, sunset the National Intelligence University with its programs transferred to the National Defense University, and closed the Reston campus; it reported more than 500 staff already removed. Gabbard announced her resignation in May 2026, and on 2 June 2026 the President named Bill Pulte, director of the Federal Housing Finance Agency, acting DNI. Pulte ran further rounds of layoffs from June 2026 and on 28 July 2026 announced a fifth round he described as about a 30 percent staff reduction. The Senate confirmed Jay Clayton as DNI the same day, 51 to 47. Press accounts citing congressional aides put ODNI at little more than half of the roughly 2,000 employees it had in January 2025; ODNI has not published a headcount.
The Mandate said p. 204
Considerations like mismanagement of human resources, joint-duty assignments, and accelerated growth in senior personnel can cause a President to dictate to his incoming DNI a desire to slash redundant positions and expenditures while simultaneously giving the DNI the authority to drive necessary changes throughout the IC to deal with the nation’s most compelling threats, including those emanating from China.
What landed Beyond the text
The chapter asked for redundant positions to be cut and for a small, coordinating ODNI; the office was halved and several centers were folded in, which goes further than the text. The chapter also wanted a mandatory neutrality course at the National Intelligence University, which ODNI 2.0 closed.
CostODNI estimated savings of over 700 million dollars a year from its own reforms and about 1.3 billion dollars in annual recurring costs from related reductions across the Intelligence Community (ODNI 2.0 fact sheet, August 2025). No independent estimate was found.
NextFinal action on the fiscal 2027 Intelligence Authorization Act (S. 4615, reported by the Senate Intelligence Committee 14 to 3 and placed on the calendar 20 May 2026; H.R. 9624 in the House), which would repeal the National Intelligence Management Council and other ODNI positions, and any staffing decisions by DNI Clayton, who told the committee ODNI should stay lean.
ODNI News Release No. 24 25, 20 August 2025ODNI 2.0 fact sheetPulte fifth round of terminations, 28 July 2026 (Nextgov report, pointer)ODNI headcount and fourth round (Federal News Network report, pointer)Clayton confirmed 51 to 47, 28 July 2026 (Roll Call report, pointer)Pulte named acting DNI, Gabbard resignation (CBS News report, pointer)
Section 10102 of the 2025 reconciliation law, signed 4 July 2025, extended the SNAP time limit for adults without dependents to ages 18 to 64, narrowed the parent exception to children under 14, ended the exceptions for veterans, homeless people, and former foster youth, and limited area waivers to unemployment above 10 percent; FNS told states on 3 October 2025 to apply the new rules at once and to end jobs based waivers 30 days later. In Rhode Island State Council of Churches v. Rollins, D.R.I. No. 1:25 cv 569, the court on 31 October 2025 ordered USDA to honor the existing waivers, and FNA guidance of 26 February 2026 let the 18 terminated waivers run to their original end dates, the last on 30 June 2026; the plaintiffs stipulated to dismissal on 2 March 2026. Section 10101 requires any Thrifty Food Plan reevaluation, the next no earlier than 1 October 2027, to be cost neutral, and section 10103 limits the heat and eat utility allowance to households with an elderly or disabled member. Under section 10106 the federal share of administrative costs fell from 50 to 25 percent from fiscal 2027, which began 1 October 2026; the implementing rule, proposed 24 June 2026, closed for comment on 8 September 2026 and had not been finalized. Section 10105 makes states pay 0 to 15 percent of benefits from fiscal 2028 according to their payment error rates; USDA put the national rate for fiscal 2025 at 10.62 percent on 24 June 2026.
The Mandate said p. 299
Re-implement work requirements. The statutory language covering food stamps allows states to waive work requirements that otherwise apply to work-capable individuals—that is, adult beneficiaries between the ages 18 and 50 who are not disabled and do not have any children or other dependents in the home.
What landed Beyond the text
The chapter asked for the 2019 waiver limits back and a review of the 2021 Thrifty Food Plan increase; Congress went further on work rules, raising the age ceiling to 64 and setting a 10 percent waiver test, capped future plan growth without undoing the 2021 increase, and narrowed heat and eat as asked. The state cost share is not in the chapter, and broad based categorical eligibility was left unchanged.
CostCBO (11 August 2025) estimates the work requirement changes reduce participation by about 2.4 million people in an average month over 2025 to 2034 and that the state benefit match cuts federal spending by 41 billion dollars over 2028 to 2034. USDA's regulatory impact analysis (91 FR 37837, 24 June 2026) moves about 16.9 billion dollars in administrative costs from the federal government to states over fiscal 2027 to 2031, about 3.4 billion dollars a year.
NextA final administrative cost sharing rule after the comment period that closed 8 September 2026, then the state benefit match from 1 October 2027 based on each state's fiscal 2025 or 2026 error rate; the Senate farm bill reported 16 September 2026 would delay the benefit match by a year.
Pub. L. 119 21, GovInfoFNS information memorandum on SNAP provisions, 4 September 2025FNS ABAWD exceptions memorandum, 3 October 2025FNS ABAWD waivers memorandum, 3 October 2025FNA memorandum, terminated time limit waivers remain in effect through original expiration, 26 February 2026Rhode Island State Council of Churches v. Rollins, D.R.I. No. 1:25 cv 569, case timeline (Civil Rights Litigation Clearinghouse, pointer)Proposed rule, administrative cost sharing, 91 FR 37837Extension of comment period to 8 September 2026, 91 FR 53200FNA rule page with comment extension to 8 September 2026USDA release on fiscal 2025 payment error rates, 24 June 2026CBO, effects of Pub. L. 119 21 on SNAP, 11 August 2025Waiver litigation and February 2026 guidance (Ballotpedia News report, pointer)
EO 14154 of 20 January 2025 directed the Secretary of Energy to resume reviews of LNG export applications as expeditiously as possible, ending the review pause announced in January 2024. DOE issued a conditional non FTA authorization to Commonwealth LNG on 14 February 2025, and on 19 May 2025 published its response to comments on the 2024 LNG Export Study, concluding that exports are in the public interest. Final non FTA orders followed, including Venture Global CP2 (Order 5264 A, 21 October 2025, 3.96 Bcf a day through 2050), Corpus Christi Midscale 8 and 9 (Order 5391, 26 February 2026), and Southern LNG (Order 5404, 2 April 2026); DOE denied rehearing on CP2 in Order 5264 B on 26 March 2026. The CP2 order relied on NEPA categorical exclusion B5.7 and used only the study's economic and energy security findings. Sierra Club and NRDC petitioned the D.C. Circuit for review of the CP2 order and the categorical exclusion on 17 February 2026, No. 26 1036; no decision had issued as of 22 October 2026. DOE's 2026 listing shows export orders continuing through 19 October 2026.
The Mandate said p. 369
Eliminate political and climate-change interference in DOE approvals of liquefied natural gas (LNG) exports.
What landed As written
The approval side landed as written, by executive order and DOE orders, including reliance on the NEPA categorical exclusion the chapter asked to keep. The companion request that Congress amend the Natural Gas Act to treat NATO allies like free trade partners has not been enacted.
NextA D.C. Circuit ruling on the Sierra Club and NRDC petition in No. 26 1036.
EO 14154, 90 FR 8353DOE, 2024 LNG Export Study response to comments, 19 May 2025DOE/FECM Order No. 5264 A, CP2 LNG, 21 October 2025DOE/HGEO Order No. 5264 B, rehearing denied, 26 March 2026Petition for review, Sierra Club and NRDC v. Wright and DOE, D.C. Cir. No. 26 1036, filed 17 February 2026 (Earthjustice copy)DOE HGEO, listing of 2026 authorizations and ordersDOE release, Commonwealth LNG conditional approval, 14 February 2025Sierra Club release on the CP2 petition, 17 February 2026 (pointer)
DOE's realignment of 20 November 2025 removed the Office of Energy Efficiency and Renewable Energy, the Office of Clean Energy Demonstrations, and the Grid Deployment Office from the organization chart, moving most of their programs into a new Office of Critical Minerals and Energy Innovation, the Office of Electricity, and a Hydrocarbons and Geothermal Energy Office that replaced Fossil Energy and Carbon Management. The Loan Programs Office was renamed the Office of Energy Dominance Financing and kept its lending role. Congress then funded the fiscal 2026 accounts under their old names in Pub. L. 119 74, signed 23 January 2026: according to CRS, 1.950 billion dollars in new money for EERE plus 1.150 billion in redirected IIJA balances, zero for OCED, and 350 million for ARPA E. In October 2025 DOE terminated more than 300 awards worth about 7.56 billion dollars from these offices; in City of Saint Paul v. Wright, Judge Mehta held on 12 January 2026 that terminations sorted by whether a grantee's state voted for Trump in 2024 violated equal protection and vacated seven termination notices, declined a permanent injunction on 3 April 2026, and DOE did not appeal.
The Mandate said p. 379
Eliminate EERE. The next Administration should work with Congress to eliminate all of DOE's applied energy programs, including those in EERE (with the possible exception of those that are related to basic science for new energy technology).
What landed Partly
The offices the chapter named for elimination were dissolved or renamed administratively and OCED received no new money, but Congress kept funding EERE and ARPA E at reduced levels and did not repeal their authorities. The Loan Programs Office, which the chapter wanted sunset, survives under a new name.
CostCRS reports EERE new budget authority falling from 3.460 billion dollars in fiscal 2025 to 1.950 billion in fiscal 2026 (R48599, updated 25 March 2026). Grantees whose awards were terminated in October 2025 lost the remaining federal share unless reinstated by a court or by DOE.
NextSummary judgment in Thakur v. Trump (N.D. Cal. No. 3:25 cv 4737) over 13 terminated DOE awards, with a hearing set for October 2026, and the fiscal 2027 Energy and Water appropriation, which the House committee reported on 22 April 2026 with 1.850 billion dollars for the Critical Minerals and Energy Innovation office.
DOE, organizational realignment, 20 November 2025DOE organization chart, 20 November 2025Pub. L. 119 74CRS R48599, Energy and Water Development: FY2026 Appropriations (EveryCRSReport copy)City of Saint Paul v. Wright, D.D.C. No. 1:25 cv 3899, memorandum opinion of 3 April 2026 (recites the 12 January 2026 judgment)City of Saint Paul v. Wright docket timeline (Civil Rights Litigation Clearinghouse, pointer)E&E News on the 12 January 2026 ruling (pointer)DOE Alumni Network on the lapsed appeal deadline and Thakur schedule (pointer)Holland & Knight summary of the realignment (pointer)
EO 14164 of 20 January 2025 directed the Attorney General to pursue the death penalty for all crimes of a severity demanding its use. Attorney General Bondi's memorandum of 5 February 2025 lifted the 2021 moratorium on federal executions, told prosecutors to seek death for murders of law enforcement officers and capital crimes by people in the country illegally absent significant mitigating circumstances, and directed the Bureau of Prisons to help states carry out their own death sentences. On 24 April 2026 Acting Attorney General Todd Blanche readopted the single drug pentobarbital protocol, directed the Bureau of Prisons to add other methods such as the firing squad and to study a new or expanded execution facility, and released the report Restoring and Strengthening the Federal Death Penalty; the department said it had authorized seeking death against 44 defendants. Separately, on 17 March 2026 the department proposed a rule to speed certification of state capital counsel systems under chapter 154 of title 28. President Biden had commuted 37 of the 40 federal death sentences in December 2024, and the Bureau of Prisons lists no federal executions scheduled as of October 2026.
The Mandate said p. 554
The next conservative Administration should therefore do everything possible to obtain finality for the 44 prisoners currently on federal death row. It should also pursue the death penalty for applicable crimes—particularly heinous crimes involving violence and sexual abuse of children—until Congress says otherwise through legislation.
What landed Partly
The department is seeking death sentences again and has restored the execution protocol, as the chapter asked; finality for the existing death row has not come, since 37 of those sentences were commuted before the inauguration and no federal execution has been carried out. Adding the firing squad and other methods goes past the chapter's text.
NextPublication of the proposed rule on capital clemency petitions and the revised execution protocol the department announced on 24 April 2026; neither had appeared in the Federal Register as of 22 October 2026.
EO 14164, 90 FR 8463Attorney General memorandum, 5 February 2025DOJ release, 24 April 2026DOJ OLP report, Restoring and Strengthening the Federal Death Penalty, 24 April 2026DOJ release on the proposed chapter 154 certification rule, 17 March 2026Bureau of Prisons, federal execution information
On 21 May 2025 the Civil Rights Division moved to dismiss with prejudice its lawsuits against the Louisville and Minneapolis police departments, which sought court enforced consent decrees, and retracted findings of constitutional violations for Phoenix, Trenton, Memphis, Mount Vernon, Oklahoma City, and the Louisiana State Police. Judge Paul Magnuson of the District of Minnesota granted the dismissal with prejudice on 27 May 2025, writing that the court had grave misgivings about whether the proposed decree served the public interest, and Judge Benjamin Beaton of the Western District of Kentucky dismissed the Louisville case on 31 December 2025. EO 14281 of 23 April 2025 told agencies to review consent judgments resting on disparate impact theories within 90 days. On 24 September 2026 the department said it had ended more than 50 school desegregation cases dating to the 1960s and 1970s and is reviewing the rest case by case. An Attorney General memorandum of 5 February 2025 bars, with limited exceptions, settlement payments to third parties that were neither victims nor parties.
The Mandate said p. 558
Seek to terminate any unnecessary or outdated consent decree to which the United States is a party.
What landed As written
Delivered as written: the department dropped the pending police decrees, retracted the underlying findings, and is closing decades old desegregation decrees, and it reinstated the ban on third party settlement payments that the same list of recommendations asks for.
NextCourt rulings on the desegregation dismissal motions still pending, which a judge must approve case by case.
DOJ release, 21 May 2025D. Minn. No. 0:25 cv 48, order of 27 May 2025 (Doc. 64)W.D. Ky. No. 3:24 cv 722, unopposed motion to dismiss, 21 May 2025 (Doc. 93)DOJ release, 24 September 2026Attorney General memorandum on third party settlements, 5 February 2025EO 14281, 90 FR 17537Louisville dismissal, 31 December 2025 (AP via KSAT, pointer)Louisville dismissal, 31 December 2025 (WAVE 3, pointer)
EO 14281 of 23 April 2025 directed the Attorney General, using the coordinating authority of EO 12250, to repeal or amend every agency's Title VI regulations to the extent they contemplate disparate impact liability. The Justice Department's final rule, signed by Attorney General Bondi on 5 December 2025 and effective on publication on 10 December 2025, struck the effects standard and the affirmative action provisions from 28 CFR 42.104 without notice and comment, citing the grants exception in 5 U.S.C. 553(a)(2). Commerce (16 April 2026, 91 FR 20326), Interior (22 May 2026, 91 FR 30239), Transportation (11 June 2026, 91 FR 35424), Agriculture (17 June 2026, 91 FR 36511), Homeland Security (22 June 2026, 91 FR 36963), Labor (2 July 2026, 91 FR 40372), State (9 July 2026, 91 FR 42339), and Health and Human Services and Education (24 July 2026, 91 FR 46746 and 91 FR 46733) published matching rescissions, each effective on publication. On 9 June 2026 the Office of Legal Counsel advised the EEOC that its disparate impact interpretation of Title VII is unconstitutional. No court challenge to the DOJ rule or to EO 14281 was found through 22 October 2026.
The Mandate said p. 562
Ensure that the DOJ spearheads an initiative demonstrating the federal government’s commitment to nondiscrimination. The department should also lead a whole-of-government recommitment to nondiscrimination and should be working with all other federal agencies, boards, and commissions to ensure that they are both complying with constitutional and legal requirements and using their authorities and funding to prevent discrimination not only internally, but also at the state, local, and private-sector levels.
What landed Beyond the text
The department is leading a government wide change in how discrimination is defined, as the chapter asked it to lead; the chapter does not mention disparate impact, and removing effects liability from Title VI rules across agencies goes further than its text.
CostDOJ said the costs and benefits are hard to quantify and expects lower enforcement and compliance costs; it classed the rule as significant but not economically significant (90 FR 57141, December 2025).
NextFurther agency Title VI rescissions under DOJ coordination and any EEOC action on its Title VII guidelines following the June 2026 OLC opinion.
EO 14281, 90 FR 17537DOJ final rule, 90 FR 57141Commerce rescission, 91 FR 20326, 16 April 2026Interior rescission, 91 FR 30239, 22 May 2026Transportation rescission, 91 FR 35424, 11 June 2026Agriculture rescission, 91 FR 36511, 17 June 2026Homeland Security rescission, 91 FR 36963, 22 June 2026Labor rescission, 91 FR 40372, 2 July 2026State rescission, 91 FR 42339, 9 July 2026HHS rescission, 91 FR 46746, 24 July 2026Education rescission, 91 FR 46733, 24 July 2026OLC opinion to the EEOC, 9 June 2026Gibson Dunn DEI Task Force update, 11 August 2026 (pointer, reports no challenge to EO 14281)
On 12 June 2025 the President signed three Congressional Review Act resolutions disapproving the EPA waivers for California's Advanced Clean Cars II rule, which phases out sales of new gasoline cars by 2035 (H.J. Res. 88, Pub. L. 119 16), its Advanced Clean Trucks rule (H.J. Res. 87, Pub. L. 119 15), and its heavy duty Omnibus low NOx rule (H.J. Res. 89). GAO and the Senate parliamentarian had concluded the waivers were orders outside the Act. California and ten other states sued the same day in the Northern District of California; Judge Haywood Gilliam heard the government's motion to dismiss on 19 February 2026 and took it under submission, and no ruling has been found through 22 October 2026. Separately, when EPA moved in June 2026 to send four older waivers to Congress as rules, Judge Beryl Howell of the District of Columbia granted California a preliminary injunction and denied EPA's motion to dismiss on 2 September 2026, and EPA appealed to the D.C. Circuit on 14 September 2026.
The Mandate said p. 629
Revoke the special waiver granted to California by the Biden Administration. California has no valid basis under the Clean Air Act to claim an extraordinary or unique air quality impact from carbon dioxide emissions, and EPCA is clear that under no circumstances may a state agency regulate fuel economy in place of DOT. The federal government should therefore exercise its preemptive authority over CARB and take all steps necessary to invalidate any inconsistent fuel economy requirements imposed by CARB, including its ban on sales of internal combustion engines.
What landed Different route
The waiver behind California's 2035 sales ban was voided, as the chapter asked, but by Congress under the Congressional Review Act rather than by an executive revocation resting on EPCA preemption. The method is under challenge in two courts, and a judge has blocked EPA's attempt to extend it to older waivers.
NextJudge Gilliam's ruling on the motion to dismiss in the Northern District of California, and the D.C. Circuit appeal of the 2 September 2026 injunction.
Pub. L. 119 16 (H.J. Res. 88), govinfoPub. L. 119 15 (H.J. Res. 87), govinfoWhite House statement on signing H.J. Res. 87, 88, and 89, 12 June 2025California v. United States, N.D. Cal. No. 4:25 cv 4966, docket summary (Civil Rights Litigation Clearinghouse)Courthouse News on the 19 February 2026 hearing before Judge Gilliam (pointer)California v. EPA, D.D.C. No. 1:26 cv 2185, memorandum opinion of 2 September 2026DTN on the EPA appeal of 14 September 2026 (pointer)
VA proposed on 4 August 2025 to restore the exclusion of abortion and abortion counseling from its medical benefits package and from CHAMPVA. The Justice Department's Office of Legal Counsel concluded on 18 December 2025 that section 106 of the Veterans Health Care Act of 1992 bars VA from providing abortions, withdrawing the part of its 2022 opinion that said otherwise. VA published the final rule without change on 31 December 2025, effective 30 January 2026; it removes the 2022 and 2024 exceptions for rape, incest, and the life or health of the veteran, keeps a CHAMPVA exception when a physician certifies the mother's life is endangered, and treats care for ectopic pregnancy and miscarriage as outside the exclusion. A Congressional Review Act resolution to overturn the rule, S.J. Res. 103, was discharged to the Senate calendar by petition on 12 February 2026; the White House threatened a veto on 25 March 2026, and the Senate rejected the motion to proceed 48 to 50 the same day. Minority Veterans of America petitioned the Federal Circuit for review under 38 U.S.C. 502 in a petition dated 15 May 2026 and docketed as No. 26 1861.
The Mandate said p. 644
Rescind all departmental clinical policy directives that are contrary to principles of conservative governance starting with abortion services and gender reassignment surgery.
What landed As written
The abortion half of the recommendation landed by rule, backed by a new OLC opinion that adopts the chapter's view that VA lacks legal authority. The gender reassignment half is not covered by this row.
CostVA's regulatory impact analysis did not monetize access delays or the cost of later gestation care, citing data limitations; veterans and CHAMPVA beneficiaries who sought these services bear the cost of obtaining them elsewhere.
NextBriefing and a decision on the Minority Veterans of America petition in the Federal Circuit, No. 26 1861.
VA final rule, 90 FR 61310, public inspection copy, 31 December 2025OLC, Reconsidering the Authority of the Department of Veterans Affairs to Provide Abortion Services, 18 December 2025VA 2024 rule being reversed, 89 FR 15451, 4 March 2024S.J. Res. 103, placed on the Senate calendar, govinfoStatement of Administration Policy on S.J. Res. 103, 25 March 2026Senate roll call vote 72, motion to proceed to S.J. Res. 103, 25 March 2026Minority Veterans of America v. Secretary of Veterans Affairs, Fed. Cir. petition for review dated 15 May 2026Americans United for Life litigation report listing Fed. Cir. No. 26 1861, 7 July 2026 (pointer)
This row maps to the Hazelton essay. On 2 February 2026 the EXIM board approved a long term direct loan of up to 10 billion dollars to Project Vault, which sets up the U.S. Strategic Critical Minerals Reserve as an independently governed public private partnership storing raw materials in facilities across the United States. Named manufacturers include Clarios, GE Vernova, Western Digital, and Boeing; named suppliers include Hartree Partners, Mercuria Americas, and Traxys. EXIM's release describes the goal as reducing dependence on foreign controlled supply chains and does not name China.
The Mandate said p. 727
The United States would be foolish to abandon this field of play, surrendering it to China and other nations, and to relinquish EXIM as a powerful tool in America's asymmetrical warfare toolbox.
What landed Beyond the text
The Hazelton essay argued for EXIM as a tool to counter China's export credit; the bank went further and financed a domestic stockpile of critical minerals, a use the essay does not describe.
CostEXIM's release states the structure delivers a net positive return for taxpayers; it gives no interest rate, maturity, or subsidy estimate.
NextWhether the reauthorization bill keeps the China and Transformational Exports Program and its default rate treatment, on which further critical minerals lending depends.
EXIM release, Project Vault loan approved, 2 February 2026EXIM fact sheet, Project Vault and the Strategic Critical Minerals Reserve
EO 14178 of 23 January 2025 barred agencies from any action to establish, issue, or promote a CBDC and ended any agency plans to create one. The House passed the standalone Anti CBDC Surveillance State Act, H.R. 1919, 219 to 210 on 17 July 2025; its Senate companion, S. 1124, was referred to the Banking Committee on 25 March 2025 and has not moved. Congress then attached a ban to the housing package H.R. 6644: the Senate passed it 89 to 10 on 12 March 2026, the House amended it 396 to 13 on 20 May 2026, the Senate concurred with a further amendment 85 to 5 on 22 June 2026, and the House agreed on 23 June 2026. The bill was presented to the President on 29 June 2026; he did not sign it, and it became law without signature on 11 July 2026 as Pub. L. 119 101. Section 1101 bars the Board of Governors and the Reserve Banks from issuing or creating a CBDC until 31 December 2030.
The Mandate said p. 741
Prevent the institution of a central bank digital currency (CBDC). A CBDC would provide unprecedented surveillance and potential control of financial transactions without providing added benefits available through existing technologies.
What landed As written
The chapter asked that a CBDC be prevented; an executive order and then a statute did so, though the statutory ban runs only through 2030 and the permanent standalone bill has not passed the Senate.
NextThe statutory ban lapses on 31 December 2030 unless Congress extends it or enacts the permanent ban in S. 1124.
EO 14178, 90 FR 8647Pub. L. 119 101, govinfoCRS, The 21st Century ROAD to Housing Act (P.L. 119 101), R49354House Financial Services Committee release, 11 July 2026S. 1124, Anti CBDC Surveillance State Act, introduced text, govinfoNational Mortgage Professional on the 20 May 2026 House vote, pointer
The Federal Reserve Board, the FDIC, and the OCC announced on 16 October 2025 that they were rescinding the interagency Principles for Climate Related Financial Risk Management for Large Financial Institutions, issued on 30 October 2023 at 88 FR 74183 for institutions with more than 100 billion dollars in assets. The OCC had withdrawn its participation on 31 March 2025. The agencies said existing safety and soundness standards already require institutions to manage all material risks and that separate climate principles could divert attention from other risks. The rescission notice was published at 90 FR 51756 on 18 November 2025 and states that the principles are rescinded as of that date.
The Mandate said p. 740
Focus any regulatory activities on maintaining bank capital adequacy. Elected officials must clamp down on the Fed’s incorporation of environmental, social, and governance factors into its mandate, including by amending its financial stability mandate.
What landed Different route
The Fed's climate supervision guidance is gone, which is the practice the chapter cites; the change came from the regulators themselves, and Congress has not amended the Fed's financial stability mandate as the chapter asked.
Rescission notice, 90 FR 51756, 18 November 2025Federal Reserve Board release, 16 October 2025Rescission notice, prepublication copy, FDIC
On 22 August 2025 the FOMC unanimously approved a revised Statement on Longer Run Goals and Monetary Policy Strategy at the close of its five year framework review. Chair Powell said the same day that the revision returned to flexible inflation targeting and eliminated the makeup strategy adopted in 2020, and removed the pledge to respond to shortfalls rather than deviations from maximum employment. The 2 percent longer run inflation goal was kept, and the statement still describes the dual mandate of maximum employment and stable prices.
The Mandate said p. 740
Have elected officials compel the Fed to specify its target range for inflation and inform the public of a concrete intended growth path. There should be no more “flexible average inflation targeting,” which amounts to ex post justification for bad policy.
What landed Different route
Flexible average inflation targeting is gone, as the chapter asked, but the FOMC dropped it on its own review; elected officials did not compel it, and the dual mandate the chapter would eliminate remains in statute.
NextThe FOMC plans its next framework review roughly five years out, around 2030.
FOMC release, 22 August 2025Statement on Longer Run Goals and Monetary Policy Strategy, 2025Powell speech, 22 August 2025
SBA proposed on 7 July 2025 and finalized on 2 January 2026, effective 2 February 2026, amendments to the Small Business Investment Company rules at 13 CFR part 107. The rule removes the subsidized leverage rules for section 301(d) licensees, the participating securities provisions, and the Early Stage SBIC licensing rules, and consolidates loan term rules. It adds definitions of critical minerals and critical technology and a project finance exception for critical mineral extraction and processing and designated critical technologies, citing EOs 14241, 14272, and 14192. A correction followed on 8 January 2026. Congress then passed H.R. 2066, the Investing in All of America Act of 2025: the House by voice vote on 1 December 2025, the Senate by unanimous consent on 15 April 2026, signed on 19 May 2026 as Pub. L. 119 92. The Act amends section 303(b)(2) of the Small Business Investment Act to raise the leverage cap for a single SBIC to 250 million dollars and for commonly controlled SBICs to 475 million dollars, lowers the leverage ratio from 300 to 200 percent of private capital, and excludes from the leverage limit investments made after enactment in small manufacturers, small businesses in low income or rural areas, and small businesses in covered technology categories, up to the lesser of 50 percent of private capital or 125 million dollars. It also counts college and university endowments as private capital.
The Mandate said p. 756
Reform the Small Business Investment Company (SBIC) program to refocus its support on small businesses rather than technology startups only.
What landed Partly
The rule opens SBIC financing to capital intensive critical minerals projects, and Pub. L. 119 92 gives SBICs extra leverage for investments in small manufacturers, which answers the chapter's call for Congress to make SBIC financing more favorable to capital intense investments and small manufacturers. The same exclusion also rewards critical technology investments, and neither measure limits the program's support for technology startups, so the chapter's refocusing away from them has not happened.
CostSBA estimates annualized net savings from the rule of about 42,000 dollars at a 7 percent discount rate, about 500 dollars per SBIC; its Regulatory Flexibility Act section gives a different figure of 74,793.60 dollars (SBA, 2 January 2026). No cost estimate for Pub. L. 119 92 was found.
NextSBA implementation of the leverage exclusion in Pub. L. 119 92; no rulemaking has been found.
Pub. L. 119 92, govinfoH.R. 2066, enrolled text, govinfoFinal rule, 91 FR 1, 2 January 2026Proposed rule, 90 FR 29794, 7 July 2025Correction, 91 FR 555, 8 January 2026Rep. Meuser release on the signing, 19 May 2026LegiScan action history for H.R. 2066, pointer
The Protecting Americans from Foreign Adversary Controlled Applications Act, signed 24 April 2024, barred TikTok in the United States after 19 January 2025 unless ByteDance divested it, and the Supreme Court upheld the law on 17 January 2025 in TikTok, Inc. v. Garland. On 20 January 2025 the President directed the Attorney General not to enforce the law, and extended that pause by later orders. EO 14352 of 25 September 2025 determined that a framework agreement would be a qualified divestiture once implemented, with ByteDance and its affiliates holding less than 20 percent, and paused enforcement for another 120 days. TikTok USDS Joint Venture LLC was established on 22 January 2026 and announced on 23 January 2026: Oracle, Silver Lake, and MGX hold 15 percent each, ByteDance keeps 19.9 percent, a seven member majority American board governs it, and the recommendation algorithm is to be retrained on U.S. data and hosted in Oracle's U.S. cloud. Senator Markey wrote on 29 May 2026 that ByteDance licenses the algorithm to the venture and asked for the license terms and the status of the source code review.
The Mandate said p. 851
If that inaction persists, or if the Administration allows TikTok to continue to operate in the U.S., a new Administration should ban the application on national security grounds.
What landed Different route
The chapter asked for a ban; the administration declined to enforce the ban Congress had passed and instead certified a sale that leaves ByteDance with 19.9 percent and a license to its algorithm. The end of majority Chinese ownership was reached through the divestiture route in the 2024 law.
NextCompletion of the review of ByteDance source code by the venture and Oracle, for which the venture has published no timeline.
Pub. L. 118 50, govinfoTikTok, Inc. v. Garland, No. 24 656, opinion of 17 January 2025EO 14166, 90 FR 8611EO 14352, 90 FR 47219EO 14352, Daily Comp. Pres. Docs. DCPD 202500957TikTok USDS Joint Venture announcement, 23 January 2026CBS News on the closing, 23 January 2026, pointerSen. Markey letter to TikTok USDS, 29 May 2026
The FTC announced on 23 June 2025, by a 2 to 0 vote with Commissioner Mark Meador recused, a proposed consent order clearing Omnicom's acquisition of Interpublic Group that bars the combined agency from directing advertising away from publishers on the basis of their political or ideological viewpoint; the analysis to aid public comment was published at 90 FR 27304 on 26 June 2025 under File No. 251 0049. After public comment the Commission voted 2 to 0 on 26 September 2025 to make a revised order final, allowing such steering only at the express and individualized direction of an advertiser customer. A related civil investigative demand of 20 May 2025 to Media Matters for America over advertiser departures from X was preliminarily enjoined on 15 August 2025 (D.D.C. No. 1:25 cv 1959). The FTC filed a notice withdrawing the demand on 20 April 2026 while its appeal (D.C. Cir. No. 25 5302) was pending; on 4 May 2026 the parties stipulated to dismissal of the district case and the court of appeals dismissed the appeal. Media Matters says the FTC agreed not to reissue a substantially similar demand.
The Mandate said p. 873
The FTC should set up an ESG/DEI collusion task force to investigate firms—particularly in private equity—to see if they are using the practice as a means to meet targets, fix prices, or reduce output.
What landed Different route
The chapter asked for a standing task force on collusion through ESG and DEI commitments; the FTC instead wrote a viewpoint neutrality condition into one merger order, and its investigation of an advertiser boycott group ended after a court enjoined it. No ESG/DEI task force has been found.
FTC release on final order, 26 September 2025FTC release on proposed order, 23 June 2025Analysis to aid public comment, 90 FR 27304, 26 June 2025Civil Rights Litigation Clearinghouse case summary, Media Matters v. FTC, pointerACLU of DC case page, Media Matters v. FTC, pointerWiggin and Dana on the 4 May 2026 settlement, pointerAmericans for Prosperity Foundation on the settlement, May 2026, pointer
PARTLY BLOCKED OR REVERSED
The exclusions apply widely since a Ninth Circuit panel vacated the preliminary injunction on 26 February 2026, and the D.C. Circuit has not ruled in NTEU's case. On 2 October a First Circuit panel stayed a 7 August ruling that the VA contract ran past 8 August, and the VA told employees on 13 October the contract no longer applies, while a judge again ordered the Bureau of Prisons to restore its union contracts.
The Mandate said about p. 81
All were revoked by the Biden Administration and should be reinstated by the next Administration, to include the immediate appointment of the FLRA General Counsel and reactivation of the Impasses Panel.
What landed Beyond the text
Went beyond the recommendation: the chapter asked to reinstate three 2018 orders on bargaining and official time; EO 14251 excluded most agencies from bargaining altogether, which is why the courts are still involved.
CostSenate Democrats say the two orders remove roughly two thirds of the federal workforce from collective bargaining; AFGE says the VA ended contract coverage for more than 300,000 employees in October 2026.
NextThe First Circuit appeal of the VA injunction is still being briefed, AFGE asked the district court on 16 October for an indicative ruling, and the D.C. Circuit has not ruled in the NTEU challenge to the order itself, so the order stays in force agency by agency until one of those courts reaches the merits.
Ninth Circuit, No. 25 4014Government Executive, 16 October 2026Federal News Network, October 2026
The Supreme Court held 6 to 3 on 20 February 2026 that IEEPA does not authorize tariffs. Customs opened phase three of refunds on 6 October, and on 8 October the Court of International Trade certified a refund class of importers.
The Mandate said p. 770
Instead, in order to uphold the principle of reciprocity, the U.S. raises its tariffs to mirror levels.
What landed Not in the Mandate
The vehicle was the administration's own: the Mandate never names IEEPA as a tariff authority, and the Supreme Court held that it is not one.
CostThe Penn Wharton estimate of a $22,000 lifetime loss for a middle income household modeled the April 2025 tariff package, most of which, the IEEPA tariffs, is no longer in force.
NextThe government is expected to appeal the 8 October class certification, the V.O.S. Selections class motion covering Brazilian and Indian goods is pending, and importers outside the class can sue individually until at least 4 February 2027. Refunds flow entry by entry as Customs liquidates.
Supreme Court docket, No. 24 1287National Law Review, 19 October 2026
A federal court vacated the February 2025 letter and the certification demand on 14 August 2025, and the department dropped its appeal on 21 January 2026. It now pursues the same reading of Title VI through individual investigations, including Cherry Creek School District on 8 June 2026.
The Mandate said p. 330
OCR should move to the Department of Justice. The federal government has an essential responsibility to enforce civil rights protections, but Washington should do so through the Department of Justice and federal courts.
What landed Beyond the text
Delivered by a different route and partly blocked: the chapter wanted civil rights enforcement moved to DOJ; the department used its own Office for Civil Rights to threaten funding over DEI, a court vacated the letter, and the same reading now runs through individual Title VI investigations.
CostDistricts under investigation can still lose federal funds, case by case.
Acting Director Russell Vought wrote to the Federal Reserve on 8 February 2025 that the bureau needed no further funds for fiscal 2025 and requested zero dollars; work was halted and in April 2025 the bureau moved to lay off about 1,480 employees. Judge Amy Berman Jackson enjoined mass terminations on 28 March 2025; a divided D.C. Circuit panel vacated the injunction on 15 August 2025, but the full court granted rehearing on 17 December 2025, heard argument on 24 February 2026, and on 19 June 2026 sent a revised plan keeping about 556 staff back to the district court, where the dispute is stayed until 60 days after a director is confirmed. After an Office of Legal Counsel opinion of 7 November 2025 read the Fed's "combined earnings" as profits, Vought said the bureau could not draw funds; three district courts rejected that reading (D.D.C., 30 December 2025; N.D. Cal., 13 March 2026; D. Or., 25 September 2026), and Vought requested 145 million dollars under protest on 9 January 2026. The 2025 reconciliation law, Pub. L. 119 21, lowered the bureau's funding cap from 12 to 6.5 percent of the Fed's 2009 operating expenses. Vought left the acting post on 1 August 2026 and Mark Paoletta took over; the nominee for director, Brian Johnson, told senators in July 2026 that eliminating the bureau was "not my intention" and was advanced by the Banking Committee 13 to 11 on 17 September 2026.
The Mandate said p. 839
Congress should abolish the CFPB and reverse Dodd–Frank Section 1061, thus returning the consumer protection function of the CFPB to banking regulators and the Federal Trade Commission.
What landed Partly
Congress cut the funding cap rather than abolishing the bureau, and the Supreme Court upheld its funding in May 2024, which removed the condition the chapter set for a presidential dissolution order. The administration pursued dissolution by layoffs and a zero funding request anyway; courts have blocked the mass layoffs and the funding cutoff, and the bureau's nominee says he will not seek to eliminate it.
CostThe Congressional Research Service (IN12578, 16 July 2025) put the cap at about 823 million dollars under the old formula and about 446 million dollars under the new one, at fiscal 2025 levels.
NextA Senate floor vote on the Johnson nomination, which starts the 60 day clock on the stayed district court review of the revised layoff plan.
Pub. L. 119 21, sec. 30001CRS Insight IN12578, CFPB funding provisions (EveryCRSReport copy)NTEU v. Vought, D.D.C., opinion of 28 March 2025NTEU v. Vought, D.D.C., order of 30 December 2025 (counsel's copy)NTEU v. Vought, D.C. Cir. en banc order of 19 June 2026 (Troutman copy)New York v. Vought, D. Or., opinion and order of 25 September 2026 (Colorado AG copy)Rise Economy v. Vought, CFPB notice of appeal, 11 May 2026 (Orrick copy)Senate Banking vote on Johnson, 17 September 2026 (pointer: HousingWire)
EO 14238 of 14 March 2025 ordered USAGM cut to the minimum presence and function the law requires. Within days nearly all federal staff were on administrative leave, Voice of America stopped producing new content in every language, and the grants to Radio Free Europe/Radio Liberty, Radio Free Asia, and the Middle East Broadcasting Networks were terminated. Judge Lamberth held on 7 March 2026 that Kari Lake served unlawfully as acting chief executive and voided her actions, and on 17 March 2026 vacated the statutory minimum memorandum and ordered staff back to work. On 31 March 2026 the D.C. Circuit stayed the return to work order pending appeal. The State Department inspector general reported in September 2026 that 420 employees were still on paid leave at the end of July, with VOA and Radio Free Asia each broadcasting in seven languages. Under Secretary of State Sarah Rogers was nominated in March 2026 to run the agency while keeping her State post; the Foreign Relations Committee heard her on 30 July 2026.
The Mandate said p. 245
If the de facto aim of the agency simply remains to compete in foreign markets using anti-U.S. talking points that parrot America's adversaries' propaganda, then this represents an unacceptable burden to the U.S. taxpayer and a negative return on investment. In that case, the USAGM should be defunded and disestablished.
What landed Different route
The chapter put reform with congressional review first and defunding second; the administration went to the statutory minimum by executive order, and the courts have voided much of it while the appeal runs. Putting a State Department official over the agency follows the chapter's own idea of State supervision.
CostThe inspector general found USAGM did not weigh costs and benefits before the cuts (AUD AFA IB 26 25, September 2026). The Washington Post, using the inspector general's July figures, estimates about 1.6 million dollars a week in pay for staff kept on leave.
NextA D.C. Circuit ruling in the consolidated appeals, Nos. 26 5086 and 26 5087, and a Senate vote on the Rogers nomination.
EO 14238, 90 FR 13043Widakuswara v. Lake, D.D.C., March 2026 opinionD.C. Cir. order, 31 March 2026State OIG, AUD AFA IB 26 25Rogers testimony, SFRC, 30 July 2026
EO 14152 of 20 January 2025 directed the DNI to revoke any clearances held by the signers of the October 2020 letter on the Hunter Biden laptop and by John Bolton. A presidential memorandum of 21 March 2025 directed agency heads to revoke the clearances of Antony Blinken, Jake Sullivan, Lisa Monaco, Hillary Clinton, Kamala Harris, Liz Cheney, Adam Kinzinger, attorney Mark Zaid, and others, and those of Joseph Biden and his family. On 19 August 2025 DNI Gabbard revoked the clearances of 37 current and former officials, citing politicization of intelligence; House Intelligence Committee Democrats asked on 8 September 2025 for the evidence and process behind each one. On 23 December 2025 Judge Amir Ali preliminarily enjoined the government from giving effect to the revocation as to Zaid, finding he is likely to succeed on First Amendment retaliation and due process claims; the order covers Zaid alone and took effect 13 January 2026. The government noticed an appeal on 6 January 2026 (D.C. Cir. No. 26 5009), the court expedited briefing, and a panel of Chief Judge Srinivasan and Judges Pillard and Rao heard argument on 14 May 2026; no decision had issued as of 22 October 2026.
The Mandate said p. 213
The President should immediately revoke the security clearances of any former Directors, Deputy Directors, or other senior intelligence officials who discuss their work in the press or on social media without prior clearance from the current Director.
What landed Beyond the text
The chapter tied revocation to senior former officials who speak publicly without prepublication clearance; the orders reached the 2020 letter signers but also former cabinet officials, members of Congress, prosecutors, a private lawyer, and current officers, which goes beyond the text.
NextThe D.C. Circuit decision in No. 26 5009, and any further revocation lists from DNI Clayton.
EO 14152, 90 FR 8343Presidential memorandum, 21 March 2025, DCPD 202500388HPSCI minority letter to DNI on the 19 August 2025 memorandumZaid v. Executive Office of the President, D.D.C., opinion of 23 December 2025Amicus brief in D.C. Cir. No. 26 5009, filed 23 March 2026 (ACLU of DC copy, records the notice of appeal and argument date)Knight Institute case page, argued 14 May 2026, awaiting decision (pointer)37 clearances revoked (Axios report, pointer)
On 1 July 2025 the FBI and GSA picked the Ronald Reagan Building in Washington as the new FBI headquarters, dropping the Greenbelt, Maryland site GSA chose in 2023. The Senate Environment and Public Works Committee approved the GSA prospectus 10 to 9 on 29 October 2025. Maryland and Prince George's County sued in November 2025, and on 17 August 2026 Judge Theodore Chuang held that the agencies exceeded their authority under the appropriations acts, vacated the decision to abandon Greenbelt and the redirection of 555 million dollars, and barred steps or spending to advance the Reagan Building move. The Justice Department filed a notice of appeal on 19 August 2026. Separately, Director Kash Patel said in May 2025 that 1,500 headquarters employees would move outside the National Capital Region; that was reported in the press, and no primary order was found.
The Mandate said p. 551
Emphasize, fund, and reward field offices while shrinking headquarters staff. While the FBI has essential headquarters functions that must be fulfilled and should likely be fulfilled by a team in Washington, D.C., the next conservative Administration should make a priority of deploying, funding, and rewarding the work of the field offices to the greatest extent possible.
What landed Not in the Mandate
The chapter asked for fewer headquarters staff and more field resources and said nothing about the headquarters building; the administration's main documented step was a building move, which a court has stopped, and no primary order shifting headquarters staff to the field was found.
CostThe GSA prospectus put the Reagan Building project at 844 million dollars in previously appropriated headquarters consolidation funds, with a further 555 million dollars of FBI funds for preconstruction, construction, and fit out, about 1.4 billion dollars in all (GSA prospectus PDC FBIHQ DC25, fiscal 2025). The FBI said the move would avoid more than 300 million dollars in deferred maintenance at the Hoover Building (FBI release, 1 July 2025).
NextThe Fourth Circuit appeal of the 17 August 2026 judgment, noticed on 19 August 2026.
FBI release, 1 July 2025GSA prospectus PDC FBIHQ DC25, fiscal 2025 (copy hosted by Government Executive)D. Md. No. 8:25 cv 3644, ECF 32, 17 August 2026Maryland Attorney General statement, 17 August 2026Maryland Matters on the ruling, 17 August 2026 (pointer)Maryland Matters on the notice of appeal, 21 August 2026 (pointer)Senate EPW vote, 29 October 2025 (Government Executive, pointer)Patel 1,500 employee statement (Nextgov, pointer)
EO 14238 of 14 March 2025 listed the Minority Business Development Agency among seven entities whose non statutory components and functions were to be eliminated to the maximum extent consistent with law, with each head reporting to OMB within seven days. Twenty one states sued in the District of Rhode Island on 4 April 2025 over the order's application to MBDA, the Institute of Museum and Library Services, and the Federal Mediation and Conciliation Service. Chief Judge John McConnell granted a preliminary injunction on 6 May 2025, and the First Circuit denied a stay on 11 September 2025. On 21 November 2025 the district court granted summary judgment to the states, vacated the agencies' actions, and permanently enjoined implementation of the order at MBDA, IMLS, FMCS, and the Interagency Council on Homelessness; it also noted that reduction in force notices sent to MBDA staff during the autumn 2025 shutdown were rescinded after the 12 November 2025 appropriations law nullified them. The government noticed an appeal on 19 January 2026, IMLS was dismissed from the appeal on 6 April 2026, and the First Circuit heard argument on 16 September 2026 with no decision found through 22 October 2026. The Minority Business Development Act of 2021 makes MBDA a permanent agency, so its statutory core cannot be removed by executive order.
The Mandate said p. 684
As such, a conservative Administration is best served by approaching MBDA as a tool to be leveraged in the fight to deliver economic opportunity to all Americans and to produce an economy centered on equal opportunity, free markets, innovation, and growth.
What landed Not in the Mandate
The chapter acknowledged conservative objections to MBDA but recommended keeping it and redirecting it toward policy analysis and oversight of its business centers; the administration instead ordered it reduced to the legal minimum, which a district court has vacated and permanently enjoined while the government's appeal is pending.
NextThe First Circuit's decision on the appeal of the 21 November 2025 judgment, argued 16 September 2026.
EO 14238, 90 FR 13043D.R.I. No. 1:25 cv 128, memorandum and order granting preliminary injunction, 6 May 2025 (Rhode Island Attorney General copy)First Circuit No. 25 1477, order denying stay pending appeal, 11 September 2025 (Rhode Island Attorney General copy)D.R.I. No. 1:25 cv 128, memorandum and order on summary judgment, 21 November 2025 (Doc. 99), govinfoOregon Department of Justice litigation tracker, updated 16 September 2026 (pointer for the appeal chronology)Civil Rights Litigation Clearinghouse case summary
EO 14321 of 24 July 2025 directed HUD and HHS to end support for housing first policies and to condition assistance on treatment for people with substance use disorder or serious mental illness. HUD's FY2025 Continuum of Care notices of November and December 2025 capped Tier 1 renewals at 30 percent of annual renewal demand; Judge McElroy granted preliminary relief in December 2025, the First Circuit refused a stay on 1 April 2026, and on 29 June 2026 the court set both notices aside as arbitrary and capricious, so FY2025 renewals went out noncompetitively under the appropriations act. The FY2026 notice of 1 June 2026 offered 4.04 billion dollars with Tier 1 at 60 percent and a 1.3 billion dollar set aside for new transitional housing and supportive services only projects; the court vacated it on 7 August 2026 for skipping notice and comment, and on 16 September 2026 the First Circuit stayed that judgment pending appeal, finding HUD likely to succeed. HUD reopened the competition with applications due 30 September 2026 and published a notice of research on 11 September 2026 defending the shift away from permanent supportive housing, with comments closed 13 October 2026.
The Mandate said p. 516
HUD should implement administrative changes in regulation and guidance and seek statutory authority to end all Housing First directives of Continuum of Care (CoC) grantees and contract homelessness providers in addition to establishing restrictions on local Housing First policies where HUD grant funds are used.
What landed As written
HUD has used the annual funding notices, not a change to the CoC regulation or a new statute, to move money from permanent housing to transitional housing and services, which is the shift the chapter's note 38 describes. The FY2025 version was vacated; the FY2026 version is running under an appellate stay.
CostThe National Alliance to End Homelessness, as plaintiff, projects about 97,000 people in CoC funded housing could lose it under the FY2026 notice (allegation recited in the 7 August 2026 opinion); no HUD estimate found.
NextHUD must announce FY2026 CoC awards by 1 December 2026 while the First Circuit merits appeal in Nos. 26 1922 and 26 1923 continues.
EO 14321, 90 FR 35817HUD notice of withdrawal of the November 2025 NOFO, D.R.I. No. 1:25 cv 626, ECF 41, 8 December 20251st Cir. Nos. 26 1217 and 26 1218, stay denied, 1 April 2026Washington v. HUD, D.R.I., memorandum and order vacating the 2025 NOFOs, 29 June 2026HUD release on the FY2026 CoC NOFO, 1 June 2026Washington v. HUD, D.R.I. No. 1:26 cv 439, memorandum and order vacating the 2026 NOFO, 7 August 20261st Cir. Nos. 26 1922 and 26 1923, stay pending appeal, 16 September 2026 (Justia copy)HUD notice of research, 91 FR 57901, 11 September 2026HUD CoC program competition pageCRS Insight IN12709 on the FY2026 competition (EveryCRSReport copy)
IN MOTION
CMS published its interim final rule on 3 June 2026, effective 31 July. States must start the 80 hour monthly requirement no later than 1 January 2027, and Nebraska began removals on 1 August. A challenge by 23 states, the District of Columbia, and two governors lost its bid for a preliminary injunction on 29 July. On 22 October Judge Stearns held the hearing on the states' motion for partial summary judgment and the government's cross motion; no ruling has been entered.
The Mandate said p. 468
Add work requirements and match Medicaid benefits to beneficiary needs.
What landed Beyond the text
Delivered by statute in the 2025 reconciliation law and by CMS rule in June 2026; in force from January 2027 unless the states' challenge succeeds.
NextJudge Stearns heard the cross motions for summary judgment in Massachusetts v. Oz on 22 October 2026; no ruling has been published, and one is likely before year end because the states must start the requirement by 1 January 2027.
91 FR 33348CMS fact sheetMassachusetts v. Oz trackerD. Mass. docket, hearing held 22 October
Under agreements announced 16 June, HHS now runs special education programs and Justice works with Education on civil rights enforcement, while Education says it keeps its statutory authority; nearly all special education staff began working at HHS on 10 September. The Senate education committee advanced S. 5046, which would bar moving four offices out of Education, 13 to 9, on 30 July; it has not reached the floor.
The Mandate said p. 349
Federal lawmakers should move IDEA oversight and implementation to the U.S. Department of Health and Human Services.
What landed As written
Delivered by interagency agreement rather than by Congress: IDEA administration is moving to HHS and civil rights complaints to DOJ under agreements signed in June 2026.
CostFamilies filing disability or discrimination complaints now deal with HHS or Justice staff, while funding still flows through Education.
NextFiscal 2026 IDEA grants stay in the Education Department's system and later allocations move to the HHS grant system, so the next visible step is the fiscal 2027 allocation. No court has been asked to stop the agreements.
ed.gov, 16 June 2026ed.gov agreements listHigher Ed Dive, 30 July 2026
Both bills would end the department on 31 December 2026. Neither has had a floor vote, and the Senate would need 60 votes.
The Mandate said p. 319
Federal education policy should be limited and, ultimately, the federal Department of Education should be eliminated.
What landed As written
Not delivered: the bills have not moved and need 60 Senate votes; the functions are being moved out by agreement instead.
NextH.R. 899 and S. 1148 have had no committee action and need 60 Senate votes; nothing is scheduled. The functions are moving out by agreement instead, which is the path the ledger expects to continue.
CMS's Medicare director said in March 2026 that the agency is studying default enrollment. There is no rule, model, or request for information yet, and H.R. 3467, which would auto enroll beneficiaries from 2028, has had no committee action.
The Mandate said p. 465
Make Medicare Advantage the default enrollment option.
What landed As written
Not delivered: a CMS study and a House bill, no rule and no markup.
NextH.R. 3467 has not moved and CMS has only a study, so this stays In motion on paper only until a bill is marked up or CMS proposes a rule.
The SEC adopted climate disclosure rules on 6 March 2024 (89 FR 21668) and stayed them on 4 April 2024 while challenges were consolidated in the Eighth Circuit. On 27 March 2025 the Commission voted to stop defending the rules, and on 12 September 2025 the court held the case in abeyance until the SEC reconsiders the rules by notice and comment or resumes its defense. The SEC proposed on 29 May 2026 to rescind the rules in full, mainly on the ground that they exceed its statutory authority; the proposal was published on 3 June 2026 and comments closed on 3 August 2026. No final rescission had been adopted as of October 2026, and the 2024 rules remain stayed.
The Mandate said p. 832
Prohibit the SEC from requiring issuer disclosure of social, ideological, political, or “human capital” information that is not material to investors’ financial, economic, or pecuniary risks or returns. The proposed SEC climate change rule, which would quadruple the costs of being a public company, is particularly problematic.
What landed Different route
The chapter asked Congress to bar such disclosure mandates; Congress has not acted, and the SEC itself abandoned the rule in court and proposed its repeal on materiality and statutory authority grounds.
CostThe SEC's proposal estimates annualized savings to registrants of about $4.9 billion a year over ten years from rescission (Release 33 11421, May 2026).
NextA Commission vote on a final rescission rule, after which the Eighth Circuit case would be dismissed or revived.
Proposed rescission, 91 FR 33296SEC press release 2026 49, 29 May 2026SEC press release 2025 58, 27 March 20252024 final rule, 89 FR 21668
On 1 May 2025 the Wage and Hour Division told its investigators in Field Assistance Bulletin 2025 1 to stop applying the 2024 independent contractor rule in enforcement and to use the 2008 Fact Sheet 13 and the 2019 opinion letter analysis instead; the 2024 rule still governed private lawsuits. DOL proposed on 27 February 2026 to rescind the 2024 rule and replace it with a modified version of the January 2021 rule, with control and opportunity for profit or loss as core factors, and to apply the same test under the FMLA and the Migrant and Seasonal Agricultural Worker Protection Act. Comments closed 28 April 2026 with 16,522 received. OIRA received the final rule for review on 28 September 2026, listed as economically significant, and it was still listed as pending review on reginfo.gov on 22 October 2026.
The Mandate said p. 591
NLRB and DOL should return to their 2019 and 2021 independent contractor rules that provided much-needed clarity for workers and employers.
What landed Partly
The DOL half is close to final and tracks the 2021 rule the chapter named, with some factors trimmed. No NLRB decision has yet restored the 2019 SuperShuttle standard, which the Board overruled in Atlanta Opera in 2023.
NextOIRA clearance and publication of the final rule in the Federal Register, followed by its effective date.
Field Assistance Bulletin 2025 1, 1 May 2025NPRM, 91 FR 9932, 27 February 2026OIRA pending review, RIN 1235 AA46, received 28 September 20262024 rule, 89 FR 1638, 10 January 2024
President Trump removed Board member Gwynne Wilcox on 27 January 2025, leaving the NLRB without a quorum for most of 2025. The Senate confirmed James Murphy and Scott Mayer as members and Crystal Carey as general counsel in December 2025, restoring the quorum, and confirmed James Macy and reconfirmed David Prouty on 7 August 2026, giving the Board a Republican majority of three of four sitting members. The D.C. Circuit held on 5 December 2025 that the NLRB's removal protection is unconstitutional, and the Supreme Court denied Wilcox's petition for review on 19 October 2026. General Counsel Carey's memo GC 26 04 of 26 August 2026 lists fifteen precedents to overrule or reconsider, including Miller Plastic Products, the 2023 decision that replaced Alstate Maintenance, Lion Elastomers, Cemex, Stericycle, and McLaren Macomb. No Board decision overruling any of them had issued as of 21 October 2026.
The Mandate said p. 601
The NLRB should return to the 2019 Alstate Maintenance interpretation of what does and does not constitute protected concerted activity, including listing eight instances of lawful actions by employers.
What landed As written
The general counsel has asked for the reversal the chapter wanted, and the Board now has the votes and the removal question is settled, but no decision has restored Alstate. The chapter's companion call to expand 10(j) injunctions does not appear in the memo.
NextThe first Board decision from the new majority on a targeted precedent; Valley Radiology, No. 10 CA 324512, fully briefed on McLaren Macomb, is the nearest candidate.
NLRB GC 26 04, 26 August 2026 (memo text, Jackson Lewis copy)Supreme Court docket No. 26 5, Wilcox v. TrumpPointer: Davis Wright Tremaine summary of GC 26 04, 3 September 2026Pointer: Ogletree on D.C. Cir. Nos. 25 5037 and 25 5057, 5 December 2025Pointer: HR Dive on December 2025 confirmationsPointer: NLRB Edge on the August 2026 majority, 10 August 2026
EO 14186 of 27 January 2025 ordered a homeland missile defense architecture against ballistic, hypersonic, and advanced cruise missile attack from peer, near peer, and rogue adversaries, including proliferated space based interceptors capable of boost phase intercept, with a reference architecture and plan due in 60 days. Section 20003 of the One Big Beautiful Bill Act of 4 July 2025 provided 24.4 billion dollars for integrated air and missile defense, including 5.6 billion dollars for space based and boost phase intercept capabilities, which CRS and the armed services committees describe as the start of the program the Pentagon named Golden Dome under Gen. Michael Guetlein. The Space Force announced on 24 April 2026 other transaction agreements worth up to 3.2 billion dollars with 12 firms for space based interceptor prototypes, and Guetlein said on 11 August 2026 that all 12 had passed ground tests; flight tests begin in 2027. The fiscal 2027 request seeks 17.5 billion dollars, about 97 percent of it through a second reconciliation bill, and Guetlein said on 12 August 2026 that if lawmakers do not resolve the funding there is no Golden Dome.
The Mandate said p. 127
Invest in future advanced missile defense technologies like directed energy or space-based missile defense that could defend against more numerous missile threats.
What landed As written
The order adopts the chapter's space based defense and its call on the same page to defend the homeland against Russian and Chinese missiles; the program is funded through fiscal 2026 and its fiscal 2027 money is unresolved.
CostGuetlein put the program at 185 billion dollars over 10 years in March 2026. CBO estimated on 12 May 2026 that a system meeting the order's requirements would cost about 1.2 trillion dollars in 2026 dollars to develop, deploy, and operate over 20 years, with the space based interceptor layer about 70 percent of acquisition costs and 60 percent of total costs.
NextFiscal 2027 appropriations or a second reconciliation bill, which Senate Majority Leader Thune said on 15 September 2026 would probably wait until after the 3 November 2026 elections.
EO 14186, 90 FR 8767CBO, Potential Costs of a National Missile Defense System, 12 May 2026CRS IN12576, Golden Dome funding in Pub. L. 119 21, 10 July 2025 (EveryCRSReport copy)EO 14186, The Iron Dome for America, 27 January 2025 (White House)DefenseScoop, 12 space based interceptor awards, 24 April 2026, pointerDefenseScoop, Guetlein on fiscal 2027 funding, 12 August 2026, pointerArms Control Today, October 2026, pointer
Section 702, last reauthorized in April 2024 for two years, was extended to 30 April 2026 by Pub. L. 119 84, signed 18 April 2026. On 29 April the House passed a three year reauthorization 235 to 191, and on 30 April both chambers passed S. 4465, a further extension to 12 June 2026, signed the same day as Pub. L. 119 87. After the White House named Bill Pulte acting DNI, the House on 11 June failed to pass a further short extension, H.R. 9238, under suspension of the rules, 198 to 218, and title VII of FISA expired at the end of 12 June 2026. Collection continues under Foreign Intelligence Surveillance Court certifications approved on 17 March 2026 that run to 17 March 2027. At a Senate Judiciary hearing on 15 September 2026, Senator Cornyn noted the authority had been expired about three months and FBI Director Patel said losing the collection would cause "a lot of problems". No reauthorization vote had been held as of 16 October 2026.
The Mandate said p. 215
While this authority may lapse if Congress does not resolve the issue by the end of 2023, Section 702 should be understood as an essential tool in the fight against terrorism, malicious cyber actors, and Chinese espionage.
What landed Partly
The chapter treated Section 702 as essential and left reform to Congress after the PCLOB report; the administration sought renewal, but the statute has lapsed and collection continues only on existing court certifications.
NextA reauthorization vote before the current certifications run out on 17 March 2027; press reports in October 2026 describe an attempt to attach reauthorization to the defense bill.
Pub. L. 119 84, extension to 30 April 2026Pub. L. 119 87, extension to 12 June 2026House Republican Cloakroom vote sheet, H.R. 9238 failed 198 to 218, 11 June 2026Rep. Himes statement on House passage, 235 to 191, 29 April 2026Sen. Grassley floor remarks, 8 June 2026Sen. Cornyn release on Patel testimony, 15 September 2026Brennan Center one pager on the 17 March 2027 certification date (pointer)Brennan Center explainer, updated 16 October 2026, no reauthorization vote yet (pointer)Lapse and certifications (CBS News report, pointer)
On 24 March 2025 DOE withdrew four pending standards (electric motors, ceiling fans, dehumidifiers, external power supplies) and postponed three other rules. Joint resolutions signed on 9 May 2025 disapproved the standards for consumer gas fired instantaneous water heaters (H.J.Res. 20, Pub. L. 119 6) and walk in coolers and freezers (H.J.Res. 24, Pub. L. 119 7), which DOE withdrew at 90 FR 21390 and 90 FR 21391 on 20 May 2025, and the 2024 certification and labeling rule (H.J.Res. 42, Pub. L. 119 8), which DOE removed by a rule signed 4 September 2025. From May 2025 DOE proposed rescinding standards for 17 products, beginning with battery chargers at 90 FR 20868; none had been finalized as of September 2026. A proposed process rule adding economic thresholds for future standards, 91 FR 42034 of 7 July 2026, closed for comment on 21 August 2026. On 8 June 2026 the Supreme Court granted, vacated, and remanded the D.C. Circuit decision upholding the 2023 furnace and commercial water heater standards in American Gas Association v. DOE, No. 25 879, in light of the Solicitor General's changed position. On 11 August 2026 the Fifth Circuit in Mississippi v. DOE, No. 24 60529, set aside the February 2024 direct final rule on conventional cooking products, holding that DOE should have withdrawn it after adverse comments led by Nebraska and 22 other states, and remanded to DOE.
The Mandate said p. 379
The next Administration should work with Congress to modify or repeal the law mandating energy efficiency standards.
What landed Partly
Congress used the Congressional Review Act on a handful of new rules and DOE withdrew pending ones, but the statute mandating standards is unchanged; Sen. Lee's Energy Efficiency Reform Act of 6 August 2026 would void two 2023 rules and has no cosponsors.
CostDOE estimated in May 2025 that its package of 47 deregulatory actions would save 11 billion dollars; the Appliance Standards Awareness Project estimated 43 billion dollars in higher consumer utility costs from the same actions (both figures as reported by the Daily Caller, 8 September 2026).
NextA final DOE process rule or the first final rescission of an existing standard, which advocates have said they will challenge under the Energy Policy and Conservation Act's anti backsliding clause, and the D.C. Circuit's reconsideration of the furnace and commercial water heater standards on remand.
Pub. L. 119 6, H.J.Res. 20, gas fired instantaneous water heatersPub. L. 119 7, H.J.Res. 24, walk in coolers and freezers90 FR 21390, gas instantaneous water heaters, withdrawal90 FR 21391, walk in coolers and freezers, withdrawalDOE final rule implementing Pub. L. 119 8, signed 4 September 202590 FR 20868, proposed rescission of battery charger standards, 16 May 2025Proposed process rule, 91 FR 42034, 7 July 2026Comment period extended to 21 August 2026, 91 FR 47155Supreme Court order list of 8 June 2026, No. 25 879 granted, vacated, and remandedMississippi v. Department of Energy, 5th Cir. No. 24 60529, opinion of 11 August 2026Utility Dive on the 24 March 2025 withdrawals (pointer)Daily Caller status report, 8 September 2026 (pointer)
Secretary Duffy's memorandum of 28 January 2025 directed NHTSA to review all fuel economy standards for model year 2022 and later. On 11 June 2025 NHTSA issued an interpretive rule stating it may not consider electric vehicles, the electric operation of plug in hybrids, or credit trading when setting standards. Section 40006 of Pub. L. 119 21, signed 4 July 2025, set the CAFE civil penalty in 49 U.S.C. 32912(b) to zero dollars for model years not yet assessed, which NHTSA applies from model year 2022. NHTSA proposed the SAFE Vehicles Rule III on 5 December 2025, Administrator Jonathan Morrison signed the final rule on 25 September 2026, and it was published on 30 September 2026 at 91 FR 61988 with an effective date of 30 November 2026. The final standards rise from an estimated 31.8 mpg required fleet average for model year 2022 to 34.9 mpg for model year 2031, and credit trading between manufacturers ends for credits earned in model year 2028 and later. On 2 October 2026 California, 19 other states, Massachusetts, the District of Columbia, and five cities and counties petitioned the First Circuit to review the rule. A separate interpretive rule of 31 August 2026 narrowed NHTSA's heavy duty fuel efficiency program to vehicles only.
The Mandate said p. 628
Reduce proposed fuel economy levels. The Administration should consider returning to the minimum average fuel economy levels specified by Congress for model year 2020 vehicles: levels aimed at achieving a fleet-wide average of 35 miles per gallon. Consideration should be given to maintaining the standards at those levels for the near term in order to promote the objectives laid out by Congress.
What landed As written
The final standards stay below the 35 mpg level the chapter named through model year 2031 and drop electric vehicles and credits from the feasibility analysis, which the chapter also criticized. Zeroing civil penalties by statute went further than the chapter asked and removes the financial consequence of missing any standard.
CostNHTSA estimates the final standards lower average up front vehicle cost by about 1,289 dollars per vehicle in model year 2031 and yield net benefits of 41.8 billion dollars at a 3 percent discount rate and 36.3 billion dollars at 7 percent over model years 1985 to 2031, with fuel savings and other benefits reduced by 95.8 billion dollars at 3 percent (final rule, 91 FR 61988, 30 September 2026).
NextThe rule's effective date of 30 November 2026 and the First Circuit's handling of the states' petition for review.
SAFE Vehicles Rule III final rule, 91 FR 61988, 30 September 2026NHTSA interpretive rule, 90 FR 24518, 11 June 2025SAFE Vehicles Rule III proposed rule, 90 FR 56438, 5 December 2025SAFE Vehicles Rule III final rule, prepublication copy signed 25 September 2026California et al. v. NHTSA, First Circuit petition for review, 2 October 202649 U.S.C. 32912 with the Pub. L. 119 21 sec. 40006 amendment note (Cornell LII)NHTSA heavy duty interpretive rule, 91 FR 55788, 31 August 2026
This row maps to the Hazelton essay, which argues for keeping the bank as a tool against China. Senators Kevin Cramer and Mark Warner introduced S. 3772 on 4 February 2026; it changes the bank's general authority date in section 7 of the Export Import Bank Act of 1945 from 2026 to 2036, moves the section 6(a)(2) exposure authority date from 2027 to 2037, and extends the China and Transformational Exports Program in section 2(l)(3)(C) to 2036, and it was referred to the Senate Banking Committee. EXIM Chairman John Jovanovic, whose confirmation EXIM announced on 19 September 2025, testified to the Senate Banking Committee on 26 March 2026 asking Congress to reauthorize the bank and the China program, which he called mission critical, and to ease the default rate cap. Representatives Michael Lawler and Josh Gottheimer introduced H.R. 10165 on 27 August 2026; it shortens from 120 to 60 days the wait before a temporary board can act when the board lacks a quorum and makes that arrangement standing, and it does not renew the charter. No committee vote or floor vote on a reauthorization bill has been found through 22 October 2026, and the charter expires on 31 December 2026.
The Mandate said p. 726
To ignore these changes and leave the United States without its own export financing weapon is to resign the United States to a reduced role in world geopolitical affairs and accept fewer jobs and lower standards of living for many Americans.
What landed As written
The Hazelton essay asked that the bank be kept as an export financing weapon against China; the administration and a bipartisan Senate bill seek a ten year extension of the bank and its China program, which has not yet passed.
CostEXIM reported on 26 March 2026 that it has returned 9.7 billion dollars to the Treasury since 1992 and has more than 71 billion dollars in active transactions; no CBO score of S. 3772 has been found.
NextCommittee action on S. 3772, or an extension attached to the year end continuing resolution or the fiscal 2027 defense authorization, before the charter lapses on 31 December 2026.
S. 3772 as introduced, govinfoS. 3772 text, Senator Warner's officeSenate Banking Committee hearing, Export Import Bank Reauthorization, 26 March 2026EXIM release, chairman's Senate testimony, 26 March 2026EXIM release, Jovanovic confirmed, 19 September 2025H.R. 10165 bill record (Quiver Quantitative, pointer)National Association of Manufacturers on H.R. 10165, 10 September 2026 (pointer)ELFA, legislative outlook, October 2026 (pointer, charter still set to expire 31 December)
The FCC opened the Delete, Delete, Delete docket by public notice DA 25 219 on 12 March 2025, asking for comment on rules to eliminate. It has since repealed rules mainly by direct final rule, which takes effect unless significant adverse comment arrives: FCC 25 51 (adopted 7 August 2025, 71 provisions), FCC 25 68 (adopted 30 September 2025, 89 wireline provisions, published 16 April 2026, effective 15 June 2026), FCC 25 77 (28 October 2025, about 396 provisions), FCC 25 80 (20 November 2025, about 21 provisions), FCC 25 85 (18 December 2025, 36 provisions, 91 FR 3067), and FCC 26 15 (26 March 2026, 18 provisions including the broadcast incentive auction rules, published 22 June 2026, effective 21 August 2026). On 30 January 2026 the FCC withdrew 11 maritime and related sections from FCC 25 77 after significant adverse comment. The FCC described FCC 26 15 as its seventh direct final rule and said that with it the Commission will have eliminated about 1,274 rule provisions, 149,566 words, and more than 338 CFR pages. No withdrawal notice for FCC 26 15 appeared in the Federal Register through 22 October 2026, and no further direct final rule in the docket has been published since; later docket items are ordinary rulemakings, such as the broadband data collection rules of 24 June 2026.
The Mandate said p. 857
The FCC should engage in a serious top-to-bottom review of its regulations and take steps to rescind any that are overly cumbersome or outdated.
What landed As written
The review the chapter asked for is running as a standing docket with repeals in batches. The rules repealed so far are mostly obsolete or unused provisions; the media ownership rules and universal service requirements the chapter named are not among them.
NextFurther direct final rules or orders in GN Docket No. 25 133; the FCC described FCC 26 15 as closing the first phase of the docket, with licensing reform and paperwork reduction to follow.
FCC document page, DA 25 219, In Re: Delete, Delete, DeleteFCC 25 51, 90 FR 40536, 20 August 2025FCC 25 77, 90 FR 57698, 12 December 2025FCC 25 80, 91 FR 1400, 14 January 2026FCC 25 85, 91 FR 3067, 26 January 2026Partial withdrawal, 91 FR 4018, 30 January 2026FCC 25 68, 91 FR 20372, 16 April 2026FCC 26 15, 91 FR 37043, 22 June 2026FCC fact sheet for the seventh direct final rule, 5 March 2026
The FEC has lacked the four member quorum it needs to open investigations, issue advisory opinions, or make rules since 1 May 2025, after Commissioner Allen Dickerson left at the end of his term on 30 April 2025; Sean Cooksey had resigned earlier in 2025 and the President removed Ellen Weintraub in February 2025. Commissioner James Trainor resigned on 3 October 2025, leaving two Democrats, Chair Shana Broussard and Dara Lindenbaum. On 11 February 2026 the Senate received the nominations of Republicans Ashley Stow (PN806 10, term to 30 April 2029) and Andrew Woodson (PN806 11, term to 30 April 2031), whom congressional Republicans had recommended in July 2025; both were referred to the Committee on Rules and Administration. In a 6 April 2026 filing the FEC told the district court it cannot authorize investigations or defend the merits of a delay suit without a quorum. As of 17 September 2026 the Rules Committee had scheduled no hearing on either nominee, and as of 17 October 2026 the Senate had not acted on them.
The Mandate said p. 865
The President should prioritize nominations to the FEC once commissioners reach the end of their terms and should be assisted by legislative language either eliminating or limiting overstays to a reasonable period of time to permit the vetting, nomination, and confirmation of successors.
What landed Partly
The chapter asked for prompt nominations as terms ran out and for limits on holdovers; the nominations came about nine months after the quorum lapsed and remain unconfirmed, and no holdover legislation has been found. Removing a sitting Democratic commissioner was not among the chapter's recommendations.
CostEnforcement matters are held without action; the Washington Sun reported in February 2026 that some are nearing the five year statute of limitations. No estimate of the backlog was found.
NextA Senate Rules Committee hearing on the Stow and Woodson nominations; committee vice chair Alex Padilla said in September 2026 it was not clear one would come before the election, and the nominations lapse if the 119th Congress ends without action.
Senate Rules Committee nominations page, PN806 10 and PN806 11FEC notice of lack of quorum, D.D.C. No. 1:26 cv 336, 6 April 2026Ashurst Perkins Coie on the nominations, pointerWashington Sun, 17 September 2026, no Rules Committee hearing, pointerWashington Sun, 23 February 2026, Weintraub removal and backlog, pointerElection Law Blog, 17 October 2026, Senate has not acted, pointer
On 20 February 2025 the FTC opened a public inquiry into technology platforms that ban, shadow ban, demonetize, or otherwise restrict users for their speech or affiliations, asking whether those practices are unfair or deceptive acts or unfair methods of competition; comments closed on 21 May 2025. On 26 March 2026 Chairman Andrew Ferguson sent warning letters to the chief executives of PayPal, Stripe, Visa, and Mastercard stating that denying customers financial services over their political or religious views may violate the FTC Act where it conflicts with a company's terms of service or customers' reasonable expectations, and could lead to investigation and enforcement. The letters cite EO 14331 of 7 August 2025, Guaranteeing Fair Banking for All Americans, which assigns the FTC no task of its own. No FTC complaint, order, or staff report arising from either step has been found through October 2026.
The Mandate said p. 874
This type of behavior can rise to the level of an unfair trade practice when the business is (1) publicly traded; (2) highly regulated; (3) enjoys legal privileges; (4) enjoys market power; and (5) appears to engage in its own political or social agenda that is unrelated to any conceivable branding concerns.
What landed Partly
The FTC has taken up both targets the chapter named, banks and internet platforms, under the FTC Act; its theory rests on terms of service and customer expectations rather than the chapter's five factor test, and so far it has produced an inquiry and letters, not a case.
NextAn FTC complaint or staff report from the censorship docket or the payment company letters; none is scheduled.
FTC release, 20 February 2025FTC request for public comments page, Docket FTC 2025 0023FTC release, 26 March 2026Warning letter, PayPalWarning letter, StripeWarning letter, VisaWarning letter, MastercardEO 14331, Daily Comp. Pres. Docs. DCPD 202500835
HUD announced the proposal on 27 February 2026 and published it on 2 March 2026, with comments closing 1 May 2026. It would let public housing agencies and Section 8 project based owners opt in to work requirements of up to 40 hours a week for work eligible adults aged 18 to 61, and to term limits of at least two years for nonelderly, nondisabled families, in public housing, Housing Choice Vouchers, Project Based Vouchers, and Project Based Rental Assistance. People with disabilities, pregnant people, caretakers of children under six, and students are excluded from the work rule; HUD VASH and certain youth vouchers are excluded from term limits, and families get at least three months' notice. The regulatory agenda targeted a final rule for September 2026; no final rule had appeared in the Federal Register as of mid October 2026.
The Mandate said p. 509
Where admissible in regulatory action, HUD should implement reforms reducing the implicit anti-marriage bias in housing assistance programs, strengthen work and work-readiness requirements, implement maximum term limits for residents in PBRA and TBRA programs, and end Housing First policies so that the department prioritizes mental health and substance abuse issues before jumping to permanent interventions in homelessness.
What landed As written
The proposal covers both PBRA and voucher (TBRA) households and pairs work requirements with term limits, as the chapter asked, but leaves adoption to each agency and owner; it is not yet final, and the chapter's legislative track has no vehicle.
CostHUD's regulatory impact analysis (February 2026) estimates annualized costs of 2.7 million to 55.3 million dollars and transfers of 65.3 million to 265 million dollars a year, with tenant earnings rising 125 million to 501 million dollars a year.
NextPublication of the final rule, which the regulatory agenda had set for September 2026.
Proposed rule, 91 FR 10016, 2 March 2026HUD regulatory impact analysis, FR 6520 P 01HUD release No. 26 018, 27 February 2026Unified Agenda entry, RIN 2501 AE15
HUD published the proposed rule Housing and Community Development Act of 1980: Verification of Eligible Status on 20 February 2026, under the same title as the 2019 proposal the chapter cites. It would require verification of citizenship or eligible immigration status for every applicant and recipient regardless of age, ending the exemption for people 62 and older, remove the option to decline to contend eligible status, make prorated assistance for mixed status families temporary while remaining members are verified, and move verification to the DHS SAVE system. Comments closed 21 April 2026 with 16,238 received. No final rule had appeared in the Federal Register as of mid October 2026.
The Mandate said p. 509
The Office of the Secretary should recommence proposed regulation put forward under the Trump Administration that would prohibit noncitizens, including all mixed-status families, from living in all federally assisted housing.
What landed As written
HUD recommenced the rule as the chapter asked and went further on verification by covering tenants 62 and older; it remains a proposal.
CostHUD estimates one time paperwork costs of about 1.27 million dollars for existing residents and states the main effect is to transfer assistance from mixed status families to fully eligible households; the preamble gives no count of families affected and places totals in the docket analysis.
NextA final rule; none was on the Federal Register through mid October 2026.
NOT STARTED
The Mandate asks CMS to let states set time limits on Medicaid eligibility. No bill, rule, or state waiver to do so has been found as of 21 October 2026.
The Mandate said p. 468
Add targeted time limits or lifetime caps on benefits to disincentivize permanent dependence.
What landed As written
Not delivered and no vehicle; the 2025 reconciliation law chose work requirements instead.
NextNo vehicle and no date. This would need a statute, and the 2025 reconciliation law chose work requirements instead.
No bill or reconciliation instruction carries them. The fiscal 2027 budget resolution the House adopted on 22 July instructs no committee that handles Medicaid.
The Mandate said p. 466
This system should include a more balanced or blended match rate, block grants, aggregate caps, or per capita caps.
What landed As written
Not delivered and no vehicle; nothing published for the planned third reconciliation bill includes Medicaid financing.
NextNo bill, budget resolution, or reconciliation instruction carries caps. The Speaker's planned third reconciliation bill is the only vehicle in sight, and nothing published for it includes Medicaid financing.
FCC Chairman Brendan Carr opened an Enforcement Bureau inquiry into underwriting announcements on NPR and PBS member stations by letter of 29 January 2025. No order, rulemaking, or license action reclassifying public stations out of the noncommercial educational category has been found in FCC records through October 2026.
The Mandate said p. 248
The next President should instruct the FCC to exclude the stations affiliated with PBS and NPR from the NCE denomination and the privileges that come with it.
What landed As written
Nothing yet; the underwriting inquiry tests the same commercial practices the chapter cites but cannot by itself change a station's status.
NextAny Enforcement Bureau action from the underwriting inquiry, or a notice proposing changes to the reserved band or NCE eligibility.
No bill, executive order, or reorganization plan transferring SNAP, WIC, or the school meal programs to the Department of Health and Human Services has been found; neither the House passed farm bill, H.R. 7567, nor the Senate committee's Agricultural Act of 2026 contains one. USDA instead announced on 30 April 2026 that the Food and Nutrition Service would become the Food and Nutrition Administration inside USDA, with regional offices replaced by hubs and program staff moved out of Washington: SNAP to Indianapolis, child nutrition to Dallas, supplemental nutrition and safety programs to Kansas City, research to Raleigh, and emergency management to Denver, with the administrator and a small office kept in Washington. USDA described its 25 February 2026 decision to return the South Building and Braddock Place to the General Services Administration as the start of its department wide reorganization plan. FNA guidance and Federal Register documents carry the new name from mid 2026.
The Mandate said p. 298
Move the USDA food and nutrition programs to the Department of Health and Human Services.
What landed As written
Nothing toward a transfer; the nutrition programs stay at USDA under a renamed agency with most staff moved to field hubs. The chapter also proposed eliminating the Food and Nutrition Service once the programs moved, and the agency instead continues under a new name.
NextNone scheduled; a transfer to HHS would need legislation.
USDA release 0062.26, 30 April 2026USDA release 0037.26, 25 February 2026CRS R48918, the 2026 farm bill compared with current law (EveryCRSReport copy)
This row maps to the de Rugy essay, which calls for abolishing the bank. No bill, budget proposal, or executive action to close the bank has been found through 22 October 2026; the administration's EXIM chairman asked Congress on 26 March 2026 to reauthorize it, and EXIM's fiscal 2027 budget justification of 25 March 2026 requests 149.7 million dollars in administrative expenses, up from 125.0 million dollars in fiscal 2026, and refers to the coming reauthorization process. If Congress does not act, the bank's authority to approve new transactions lapses on 31 December 2026 under current law.
The Mandate said p. 718
The Bank should be abolished.
What landed As written
Nothing toward abolition; the administration is pursuing the opposite course set out in the Hazelton essay. Verdict As written follows ledger precedent for Not started rows and describes the de Rugy recommendation still on the table.
NextThe 31 December 2026 charter expiration; a lapse would halt new financing without abolishing the bank.
EXIM release, chairman's Senate testimony, 26 March 2026EXIM fiscal 2027 congressional budget justification, 25 March 2026
The Supreme Court held 6 to 3 on 27 June 2025 in FCC v. Consumers' Research that the universal service contribution scheme does not violate the nondelegation doctrine, leaving the fund and its carrier funded base in place. The Lowering Broadband Costs for Consumers Act of 2025 (S. 1651, Senators Mullin, Kelly, Crapo, and Cramer, introduced 7 May 2025 and referred to the Commerce Committee; H.R. 4032, Representative Feenstra, introduced 17 June 2025 and referred to Energy and Commerce) would direct the FCC to collect contributions from edge providers and broadband providers; no committee or floor action has been found. On 6 August 2026 the FCC adopted a notice of proposed rulemaking on how the fund is administered (FCC 26 52, WC Docket No. 26 173), which Chairman Carr described as part of a top to bottom review of the fund; it proposes no change to who contributes.
The Mandate said p. 850
To put the FCC’s universal service program on a stable footing, Congress should require Big Tech companies to start contributing an appropriate amount.
What landed As written
Nothing yet; the bills that would bring edge providers into the base have not moved, and the FCC's review so far concerns administration costs and USAC rather than the contribution base. The recommendation remains on the table as written.
CostCarriers pass the charge to telephone customers; the FCC's Office of Managing Director proposed a contribution factor of 42.0 percent of interstate and international telecommunications revenue for the fourth quarter of 2026 (public notice of September 2026, as reported by Benton and JSI).
NextReply comments on FCC 26 52 are due 30 October 2026.
FCC v. Consumers' Research, No. 24 354, opinion of 27 June 2025S. 1651, introduced text, govinfoH.R. 4032, bill status, govinfoFCC 26 52, Maximizing Efficiencies in Universal Service AdministrationCarr proposes comprehensive review of universal service, 16 July 2026FCC 26 52, 91 FR 55826, 31 August 2026Benton summary of the proposed 4Q2026 contribution factor, pointerJSI on the proposed 4Q2026 factor, pointer
The chapter asks the FCC to adopt an interpretive order tracking the July 2020 NTIA petition for rulemaking. Chairman Carr said at a Justice Department event in early April 2025 that the FCC could act on Section 230 and on transparency in moderation decisions, and trade press on 14 April 2025 reported an advisory opinion was expected. No FCC order, declaratory ruling, advisory opinion, or notice of proposed rulemaking interpreting Section 230 has been found in the Federal Register or FCC records through October 2026.
The Mandate said p. 847
The FCC should issue an order that interprets Section 230 in a way that eliminates the expansive, non-textual immunities that courts have read into the statute.
What landed As written
Nothing yet; the chairman who wrote the chapter has described the authority but the Commission has issued no Section 230 interpretation. The recommendation remains on the table as written.
NextAny FCC declaratory ruling or notice on Section 230 placed on an open meeting agenda.
NTIA petition for rulemaking on Section 230, 27 July 2020Communications Daily, 14 April 2025 (pointer)
No FTC proceeding treating platform contracts with minors made without parental consent as an unfair practice has been found through October 2026. The agency's children's work runs through COPPA: amendments adopted in January 2025 and published on 22 April 2025 took effect on 23 June 2025, with compliance required by 22 April 2026. On 25 February 2026 the Commission voted 2 to 0 for a policy statement saying it will not bring COPPA cases against general and mixed audience operators that collect data only to determine a user's age, if they meet six conditions, and that it intends to review the COPPA Rule to address age verification. COPPA still covers only children under 13, the limit the chapter criticized.
The Mandate said p. 875
The FTC can and should institute unfair trade practices proceedings against entities that enter into contracts with children without parental consent.
What landed As written
Not delivered: the chapter wanted unfairness cases reaching contracts with all minors; the FTC has stayed within COPPA's under 13 scope and is encouraging age verification, which the chapter's dissenting contributors warned would increase data collection. The verdict describes the recommendation still on the table.
NextA proposed COPPA amendment on age verification, which the February 2026 statement announced without a date.
COPPA Rule amendments, 90 FR 16918FTC release, 25 February 2026Enforcement policy statement on age verification
RELATED, NOT IN THE MANDATE
The Court held 6 to 3 that the FTC's for cause removal protection violates the separation of powers and overruled Humphrey's Executor, except for agencies that exercise no executive power. The same day, in Trump v. Cook, it left in place the injunction keeping Federal Reserve Governor Lisa Cook in office while her case continues. The Mandate argues throughout for presidential control of the executive branch, but this ledger has not confirmed a specific recommendation, so the ruling is listed here.
CostMembers of multimember agencies that exercise executive power, starting with the FTC, now serve at the President's pleasure. The Federal Reserve was treated separately.
ORM reporting: The Quorum Came Back in January. The Court Took the Lock Off in June.
NextWith Humphrey's Executor overruled, removals at the remaining boards (NLRB, FTC, FEC, MSPB) can proceed without the old litigation risk, and the Federal Reserve, which the Court set apart in 2025, is the next line to be tested.
The House passed it 218 to 213 on 11 February 2026. The Senate has turned it down repeatedly, most recently the voter ID amendment on 8 August, and a White House official said on 31 August that the reconciliation talks carrying it are probably going to come after the election.
NextThe Speaker has said the House will pass it again inside a third reconciliation bill; the Senate lacked the votes in August and the parliamentarian objected last time, so passage before the 3 November 2026 midterms is unlikely and the ledger expects the next attempt after the election.
Democracy Docket, 23 April 2026Roll Call, 7 August 2026Daily Signal, 31 August 2026
A June 2026 ruling against EO 14399 was stayed by the Supreme Court on 24 August, but two later injunctions, in Massachusetts on 4 September and in the District of Columbia on 13 September, block the Postal Service mail ballot rule. On 14 September the Court refused the government's request to lift the Massachusetts order, so the rule cannot be used for the November 2026 election. In the Justice Department's suit over mail ballots sent to about 20,000 California voters it calls likely noncitizens, the Ninth Circuit dismissed the government's emergency appeal for lack of jurisdiction on 26 October 2026, 2 to 1, holding that the district court's short delay was not a denial it could review.
NextThe 3 November 2026 midterms will run with the USPS rule's key provisions blocked by the 4 September injunction, which the Supreme Court declined to lift on 14 September, while the First Circuit appeal is pending. In the California suit, United States v. California, C.D. Cal. No. 2:26 cv 12025, Judge Carter heard the restraining order request on 27 October after the Ninth Circuit sent the case back; his ruling, and the special master he said he would appoint to review the government's list, come next.
EO 14399Order in No. 26A305, 14 September 2026Votebeat, 15 September 2026Notice of appeal, 22 October 2026Amended briefing order, 23 October 2026Ninth Circuit order, No. 26 7070, 26 October 2026
SSA cut staff from about 57,000 to about 49,500 by May 2026, announced a plan to cut its regional offices from ten to four, and moved more than 1,500 staff to phone service. On 5 October 2026 it announced alternative work schedules end on 16 November.
NextAlternative work schedules end 16 November 2026; the plan to cut ten regional offices to four has no published date, and Senate Democrats' July letter on field office closures is unanswered.
SSA release, 28 February 2025Government Executive, 28 July 2026
On 25 September 2026 the President sent Congress a special message proposing rescissions from 11 appropriation accounts, all expiring 30 September, and OMB withheld the money while the 45 day clock ran past the end of the fiscal year, the second time this administration has used the maneuver after 4.9 billion dollars in foreign aid in 2025. On 29 September GAO found in B 338788 that the Impoundment Control Act does not let the President withhold the appropriations past the end of fiscal 2026. The largest item was 567 million dollars for the HHS refugee assistance program; the accounts also sit in Homeland Security, Education, Justice, Treasury, Commerce, and Housing and Urban Development. Senator Collins said she would work with colleagues to address it, and no suit had been filed by 21 October.
CostMoney Congress appropriated for refugee assistance, housing, education, and justice grants in fiscal 2026 expired unspent.
NextThe money is gone, so the live questions are whether Congress restores it in fiscal 2027 appropriations and whether anyone sues; GAO's finding gives a plaintiff its argument, and the 2025 foreign aid case reached the Supreme Court on an emergency application, which is the likely path again.
GAO, B 338788, 29 September 2026Ballotpedia News, 15 October 2026Roll Call, 29 September 2026
RESOURCES AND FURTHER READING
LEGAL CHALLENGE TRACKERS
- ACLU: Project 2025 Explained and Litigation Hub Active ACLU litigation against second term executive actions, organized by issue area.
- Democracy Docket Election law litigation, including the SAVE America Act, voting rights cases, and challenges to election administration changes.
- Protect Democracy Separation of powers litigation: Schedule F, independent agency cases, and DOGE related suits, with Supreme Court case monitoring.
ECONOMIC IMPACT
- Tax Policy Center: Tariff Tracker Distributional analysis of tariff costs by income level, updated as tariff policy changes.
- Penn Wharton Budget Model: Economic Effects of Trump Tariffs Projects a 22,000 dollar lifetime loss for a middle income household under April 2025 tariff levels.
- Center on Budget and Policy Priorities Analysis of Medicaid, SNAP, and safety net restructuring for low income families.
- Georgetown Center for Children and Families Medicaid changes translated into coverage loss numbers for children and families.
PRIMARY SOURCES
- Mandate for Leadership: The Conservative Promise The full document, published 2022, organized by agency.
- Federal Register: executive orders, 2025 to present Every order as published, numbered and dated, with the legal authority cited.
- Congress.gov Bill text, vote records, and amendment history for the 119th Congress.
- Ballotpedia: administration actions 2025 to 2026 Chronological reference for executive actions, confirmations, and legislative milestones.
CIVIC ACTION TOOLS
- 5Calls Guided scripts for calling your representatives on specific issues. Two minutes a call.
- Touch Advocacy Text based advocacy tool for contacting representatives.
- Congressional Switchboard: 202 224 3121 Ask for your senator or representative by name. Staff tally every call on every issue.
- White House Comment Line: 202 456 1111 Direct line to the executive office for comment on any active policy.
- USA.gov: Find Your Representatives Start here if you do not know who represents you at the federal, state, and local level.
If you know of a tracker, litigation hub, or primary source that belongs here, write to press@ourrevolution.media.
HOW THIS LEDGER WORKS
An item enters the ledger when it maps to a recommendation in the Mandate for Leadership, 2023 edition. Its chapter is shown where the mapping is confirmed. Actions often linked to Project 2025 that the Mandate does not recommend are kept in their own section and left out of the counts.
Each status rests on a dated vehicle: an executive order, a Federal Register rule, a statute, a court order, or an agency announcement. Done means carried out; In effect means in force and still applying; Partly blocked means a court has stopped part of it; Reversed means a court or Congress undid it; In motion means a vehicle exists and is moving; Not started means no vehicle yet.
Sources are primary where one exists: the Federal Register, court dockets and opinions, congress.gov, GAO, CBO, and agency releases. Reporting is linked where no primary document is public. Cost figures name their estimator and date.
The ledger is reviewed every two weeks and whenever a tracked case or rule moves. Corrections go to letters@ourrevolution.media and are logged in the change box above.