Early in his first term, Donald Trump ordered agencies to eliminate at least two rules for every “significant” one added – rules generally carrying $100 million or more in annual economic effect. According to the administration’s own accounting detailed in the 2021 edition of Ten Thousand Commandments, 2017–2020 yielded a 2.5-to-1 ratio of deregulatory to regulatory actions (240 to 97), with an even higher ratio when rollbacks of lesser economic significance were included. The real centerpiece of the program, however, was an unprecedented freeze on net new regulatory costs—an executive-driven regulatory budget.
Trump 2.0 has doubled down. Executive Order 14,192, “Unleashing Prosperity Through Deregulation,” establishes a one-in, ten-out directive and demands that the total incremental cost of new rules be “significantly less than zero.” As of September 22, 1,879 final rules had been published in 2025, including 243 inherited from Biden, which is on pace for the lowest total ever. Furthermore, many of these are “unrules” that reduce rather than expand regulation.
As I describe in a new article at Forbes, the Spring 2025 “Unified Agenda of Federal Regulatory and Deregulatory Actions” suggests this new policy is on track to meet its specified goals. Over a dozen Biden-era rules have been overturned via the Congressional Review Act, and many more dozens of delays, rescissions, withdrawals, waivers, and rewrites are in the works.
Among 3,816 total rules in the active rulemaking pipeline portrayed in the Unified Agenda, 243 are deemed “economically significant,” with only 40 completed so far this year (these 243 are unrelated to the aforementioned 243 rules from Biden in 2025).
These 40 completed economically significant actions fall broadly into three buckets: deregulatory actions that relieve burdens (the centerpiece of the Trump program); regulatory measures that tighten standards, impose restrictions or raise fees; and rules that could be considered programmatic in nature, such as those applying to Social Security or Affordable Care Act implementation (though these should still be regarded as regulatory).
Examples of regulatory actions left intact by Trump include EPA limits on perchloroethylene and an FTC rule on live-event and lodging pricing. Programmatic items range from Affordable Care Act implementations to agricultural paperwork streamlining.
The economically significant deregulatory moves are what interest us, however. These include DOE rollbacks of appliance standards, FDA reversals of flavored-tobacco bans, EPA waivers of biofuel mandates, DOT relaxation of truck speed-limiter rules, FDIC withdrawal of brokered-deposit restrictions, the SEC retreat from new data-security requirements, and more.
All this is worthy of sustained applause. The administration is very likely to highlight more progress by the time the Fall edition of the Unified Agenda appears and argue that one-in, ten-out is uniquely successful.
There are storm clouds however, as we have repeatedly warned. Trump’s tariffs, subsidies, public private partnerships, equity stakes in private firms, antitrust and price regulation, pursuit of a sovereign wealth fund and other interventions don’t necessarily show up in either the Federal Register or the Unified Agenda. These constitute hyper-regulatory rule-equivalents that offset and derail deregulation, and expand the federal state on balance far more than a conventional rule termination can reduce it.
Whether Trump’s “unrule” revolution endures and bestows us with a government we can regard as smaller depends on honest bookkeeping and acknowledgement that government intervention and “regulation” comes in many forms apart from what gets conventionally tallied as such.
Permanence of deregulation also requires a cabinet that can change the president’s mind rather than puckering up for derriere during marathon televised cabinet meetings. It further depends upon a Congress reinforcing conventional regulatory streamlining while also forestalling the swamp things bubbling up outside the confines of notice and comment regulation.
That which can be check-boxed in the “one-in, ten-out” campaign appears to be getting cut. But outside those confines, the power of the federal state is growing.
For more, see:
“One-In, Ten-Out: Checking In On Trump’s Deregulation,” Forbes
