EXECUTIVE SUMMARY

• The Trump Administration recently published the “2026 Regulatory Plan and the Unified Agenda of Federal Regulatory and Deregulatory Actions,” which contains more than 3,300 rulemaking actions it plans to undertake over the rest of the president’s term – the highest such total in a decade.
• A deeper analysis of this document’s overall trends confirms the expectation that, as the second year of this term unfolds, agency rulemakings are increasingly landing on the deregulatory side of the ledger with agencies such as the Departments of Transportation, Interior, and Labor each being among the most active in that regard.
• Under the administration’s “regulatory budget” framework, agencies have finalized roughly $1.1 trillion in total net savings thus far in fiscal year 2026 – much of which is attributable to a single rulemaking – with this latest Unified Agenda projecting that total to rise to $1.5 trillion by the end of September.

INTRODUCTION

On July 3, the Trump Administration finally posted the “2026 Regulatory Plan and the Unified Agenda [UA] of Federal Regulatory and Deregulatory Actions.” The document, typically released twice each year, “reports on the actions administrative agencies plan to issue in the near and long term.” This marks the first version of the report produced since the “Spring 2025” edition published in September 2025 – thus essentially making it the Fall 2025 and Spring 2026 editions combined into one. As such, it joins the Obama Administration’s December 2012 edition (also posted around a major holiday, no less) as the only other “one-year” UA release thus far. Despite these abnormal and inauspicious publication details, the contents of the report speak for themselves. The 2026 UA includes: the highest amount of planned rulemaking actions across any comparable UA over the past decade, a clear uptick in the relative share of deregulatory items, and an ambitious projected goal of $1.5 trillion in total net regulatory cost reductions for fiscal year (FY) 2026.

OVERALL UNIFIED AGENDA TRENDS

General Regulatory Volume

As with past American Action Forum (AAF) examinations of Unified Agendas, it is useful to get a sense of the overall volume of activity an administration has planned. The following table includes statistics on the volume of prospective actions included over the past decade of Spring UAs. “Active” items include those that agencies reasonably expect to act on within 12 months of the UA’s publication. “Long-Term” items are those that agencies expect to act on outside of that one-year window. The “Total Prospective” category is the sum of those two. “Major” items include rulemakings that agencies expect to meet the definition of a “major rule” under the Congressional Review Act. “Significant” items include those that carry the designation of either: a) “economically significant” as established under [Executive Order] EO 12866 (and/or the relevant designation as modified under EO 14094), or b) “other significant” items that the Office of Information and Regulatory Affairs defines as a “rulemaking that is not economically significant but is considered significant by the agency.” Further, “[t]his category includes rules that the agency anticipates will be reviewed under EO 12866 or rules that are a priority of the agency head.”

Trends in Rulemaking Volume Across Spring Unified Agendas
Year	2017	2018	2019	2020	2021	2022	2023	2024	2025	2026
Active Items	1731	2224	2597	2697	2551	2673	2617	2361	2102	2518
Long-Term Items	696	647	610	575	623	574	582	648	807	808
Total Prospective Items	2427	2871	3207	3272	3174	3247	3199	3009	2909	3326
“Major” Active Items	49	88	123	155	170	217	236	193	111	173
“Major” Long-Term Items	51	34	30	40	47	38	44	42	79	77
Total “Major” Items	100	122	153	195	217	255	280	235	190	250
“Significant” Active Items	429	707	919	974	945	1055	1042	892	753	1084
“Significant” Long-Term Items	299	222	218	218	262	263	284	275	306	321
Total “Significant” Items	728	929	1137	1192	1207	1318	1326	1167	1059	1405

With more than 3,300 prospective items apparently on deck, this UA is the most active one produced over the past decade. The number of significant actions also takes the top spot across that span. While the number of major items is not the highest over this window, it is very much in the mix of the peak seen during the middle of the Biden Administration. All told, this suggests an ambitious agenda from the administration, both over the coming year and for the remainder of the president’s term.

Direction of Rulemaking Activity

Which way does that ambitious agenda point? The “EO 14192 Designation” section of each entry includes a series of potential categories. For this analysis, the most pertinent items are those the agencies have affirmatively declared to be either “regulatory,” “deregulatory,” or “exempt” for the purposes of EO 14192. The following charts illustrate the relevant share of these designations across the cohorts of “Completed Actions” (those “the agency has completed or withdrawn since publishing its last agenda”) and the aforementioned “Active Actions” and “Long-Term Actions.”

As the data show, among rules that have an explicitly stated EO 14192 category, roughly three-quarters of completed rules and rulemakings that agencies anticipate completing over the next year carry a “deregulatory” designation. Compared to the UA published last September, this represents a relative increase in the emphasis placed on deregulatory actions. This finding is not particularly surprising and indeed mirrors a trend seen during the first Trump term with “Year Two” being the most deregulatory in terms of final rules published (2018 was the only calendar year under the first Trump term where agencies reported overall net cost reductions.) The cohort of long-term actions also tilted marginally further in the deregulatory direction (with that category moving from 32 percent to 46 percent since last year) but clearly remains more mixed than the either completed or active item cohorts. AAF’s read this year is similar to last year’s: “These data suggest that the administration may have some sizable contingent of regulatory actions in mind but clearly wants to make sure it gets the deregulatory items out first.”

Most Active Agencies

Another aspect of EO 14192 implementation for which this UA can provide some insight is which agencies are most active in promulgating certain kinds of rulemakings. The following tables lay out the top 10 agencies in terms of UA entries categorized as “deregulatory,” “regulatory,” and “exempt,” respectively.

Agency	# of Deregulatory Actions
Department of Transportation (DOT)	230
Department of Interior (DOI)	171
Department of Labor (DOL)	102
Environmental Protection Agency (EPA)	99
Department of Health & Human Services (HHS)	95
Department of Energy (DOE)	85
Department of Treasury (TREAS)	83
Department of Veterans Affairs (VA)	75
Department of Agriculture (USDA)	70
Department of Commerce (DOC)	64

As in the most recent previous UA, DOT retains the top spot that it also held in the previous UA in terms of the agency with the most actions tagged as “deregulatory,” albeit with 55 fewer than in that prior edition. In fact, the top four here remain in the same order. USDA saw a fairly precipitous fall down to the 9^th place slot and HHS climbed into 5^th place in this ranking.

Agency	# of Regulatory Actions
HHS	42
DOT	41
TREAS	39
EPA	31
USDA	29
DOL	28
DOI	22
Department of War (DOW)	16
Federal Energy Regulatory Commission (FERC)	10
VA	10

While HHS finds its way into the top five deregulatory agencies, it narrowly holds onto its title of most regulatory agency as well. The most significant mover of the bunch is the Department of Treasury, moving into third place with 39 such actions compared to its prior total of only 13. Of those 39 actions, 25 carry a designation of “First Time Published in The Unified Agenda.” Many of these rulemakings implement aspects of the legislation known as the One Big Beautiful Bill Act – such as “Trump Accounts” or the tax implication for tipped workers – that will inherently involve some kind of new administrative compliance burden.

Agency	# of Exempt Actions
DOC	93
Department of Homeland Security (DHS)	45
HHS	29
Department of State	28
DOJ	22
Federal Communications Commission	17
DOL	15
USDA	14
DOW	13
Department of Housing and Urban Development	9

Finally, there is the leaderboard for actions designated as “exempt” from EO 14192 regulatory budget consideration. Like last year’s report, DOC is the surprise leader in the clubhouse. While some of that agency’s actions carry a justifiable national security aspect, there are others for which the connection to any exemption laid out in the EO seems murky. This leaves open the possibility that its outlier status is largely a function of certain rulemakings carrying a mistaken designation. The second-place agency here, DHS, makes far more sense given that many of its rules can cite either national security concerns or EO 14192’s unique provision exempting “regulations issued with respect to a…immigration-related function of the United States” from the EO’s regulatory budget considerations.

EO 14192 IMPLEMENTATION TO-DATE

The UA does not provide much in the way of a specific update on the administration’s progress in implementing EO 14192. One can expect that much like last year, a fuller accounting of the regulatory budget math will arrive sometime later this year – most likely sometime after the end of FY 2026 on September 30. Nevertheless, this UA’s publication provides an occasion to reassess what kind of progress the administration has made thus far in the quantified economic impacts of its deregulatory agenda. For the entire calendar year of 2025, the administration recorded roughly $140 billion in total net savings under the auspices of EO 14192. So far into 2026, such rules have netted out to $1.1 trillion in reduced regulatory costs – putting the overall to-date total from the Trump Administration at approximately $1.2 trillion in total net savings. The fiscal year, however, cuts across portions of each calendar year. The following table includes the relevant topline figures from October 1, 2025, through the end of last week (July 2, 2026).

FY 2026 Regulatory Budget Toplines Through July 2, 2026

EO 14192 Category	# of Rules	Costs (+)/Savings (-) ($M)
Deregulatory	70	-1,163,123.5
Regulatory	11	45,688.0
Exempt	11	9,339.9
Not Applicable	17	208.8
Net Total		-1,107,886.8

The current net total stands at just over $1.1 trillion in savings for the fiscal year thus far. Of course, the vast majority of that comes from the $1.09 trillion in estimated savings from EPA’s rule repealing the “endangerment finding” (and thus rolling back recent tailpipe emissions rules). Even if one removes that sizable portion, FY2026 still stands at roughly $18 billion on the net-savings side of the ledger. Additionally, the deregulatory-to-regulatory rule ratio currently stands at roughly 7-to-1 and thus falls short of the administration’s stated 10-to-1 goal. As AAF has previously noted though:

The main discrepancy between AAF’s figures here and those in the administration’s announcement is likely due to AAF’s analysis focusing on published rulemakings that contain some kind of measurable economic effect, whereas the administration’s appears to include less formalized actions (such as ending the “shoes-off” policy for airport screening) to which it ascribes an ad hoc estimate.

MAJOR RULES COMING SOON

In the UA’s introduction, the administration heralds that it will finalize “a record-setting $1.5 trillion in projected cost savings” over the course of FY 2026. With an estimated $1.1 trillion already logged thus far, it is worth looking at rules that could potentially help agencies achieve that goal over the next three months. The following table includes still-outstanding major rules that are slated – at least in their UA entry’s stated timeline – to be finalized through this September (and, where applicable, the cost or savings estimate provided in the proposed rule).

RIN	Agency	Title	Projected Month	Costs (+)/Savings (-) From Proposed Rule ($ M)
0560-AI84	USDA	Supplemental Disaster Assistance Programs, Marketing Assistance Loans, and Sugar Provisions	July
0560-AI88	USDA	Assistance for Specialty Crop Farmers	July
0910-AI72	HHS	Use of Salt Substitutes to Reduce the Sodium Content in Standardized Foods	July
0938-AV64	HHS/IRS/DOL	Transparency in Coverage (CMS-9882)	July	18.3
1615-AD06*	DHS	Public Charge Ground of Inadmissibility	July
1652-AA80	DHS/DOT	Normalizing Unmanned Aircraft Systems Beyond Visual Line of Sight Operations	July	2.5
1653-AA95*	DHS	Establishing a Fixed Time Period of Admission and an Extension of Stay Procedure for Nonimmigrant Academic Students, Exchange Visitors, and Representatives of Foreign Information Media	July	2800
1205-AC25	DOL	Rescission of Final Rule: Improving Protections for Workers in Temporary Agricultural Employment in the United States	July	-10.2
1218-AD36	DOL	Removal of 1910 Subpart U (COVID-19 in Healthcare Settings)	July	-22.7
1235-AA49	DOL	Increasing the Minimum Wage for Federal Contractors; Rescission of Regulations	July
1250-AA17	DOL	Rescission of Executive Order 11246 Implementing Regulations	July	-7000
1557-AF35	TREAS/FDIC	Unsafe or Unsound Practices, Matters Requiring Attention	July
1557-AF41*	TREAS	Regulations on Implementing the GENIUS Act for Entities Subject to OCC Jurisdiction	July	-1.7
2050-AH42	EPA	Hazardous and Solid Waste Management System: Disposal of Coal Combustion Residuals From Electric Utilities; Revision of an Alternative Closure Requirement Deadline	July	-117.6
2060-AW55	EPA	Carbon Pollution Standards Repeal	July	-9600
2060-AW76	EPA	Reconsideration of the Greenhouse Gas Reporting Program	July	-2000
2070-AK85	EPA	N-Methylpyrrolidone (NMP); Regulation under the Toxic Substances Control Act (TSCA)	July	4200
2070-AL29	EPA	Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS) Data Reporting and Recordkeeping under the Toxic Substances Control Act (TSCA); Revision to Regulation	July	-814.7
7100-AG96	TREAS/FRS/FDIC	Regulatory Capital Rule: Modifications to the Enhanced Supplementary Leverage Ratio Standards for U.S. Global Systemically Important Bank Holding Companies, and more. (Docket No. R-1876)	July
0945-AA00	HHS	HIPAA Privacy Rule: Changes to Support Coordinated Care and Individual Engagement and Reduce Regulatory Burdens	August	-8100
1205-AC21	DOL	Prohibiting Illegal Discrimination in Registered Apprenticeship Programs	August	-738.9
2900-AQ82	VA	Schedule for Rating Disabilities: Mental Disorders	August
2900-AR10	VA	Updating VA Adjudication Regulations for Disability or Death Benefit Claims Related to Exposure to Certain Herbicide Agents	August
2900-AR75	VA	Updating VA Adjudication Regulations for Disability or Death Benefit Claims Based on Toxic Exposure	August
1615-AC67*	DHS	Procedures for Credible Fear Screening and Consideration of Asylum, Withholding of Removal, and CAT Protection Claims by Asylum Officers	September
1615-AC93*	DHS	U.S. Citizenship and Immigration Services Employment-Based Immigrant Visa, Fifth Preference (EB-5) Fee Rule	September	29.6
1670-AA04*	DHS	Cyber Incident Reporting for Critical Infrastructure Act (CIRCIA) Reporting Requirements	September	1300
1210-AC21	DOL	Exemption for Certain Automatic Portability Transactions	September	8.5
2127-AM76	DOT	Corporate Average Fuel Economy [CAFE] Standards Amendment	September	-219500
9000-AO34*	FAR	Federal Acquisition Regulation (FAR); FAR Case 2021-017, Cyber Threat and Incident Reporting and Information Sharing	September	7200

*Denotes rulemakings that can claim some exemption from EO 14192 consideration.

Assuming the final version of these rulemakings largely follow their proposed versions, this cohort of rules would bring approximately $236 billion in additional net savings (exclusive of the handful that claim an exemption). Much of this total is, of course, attached to the latest rulemaking on Corporate Average Fuel Economy, or CAFE, standards and its nearly $220 billion in projected savings. Adding this $236 billion total to that produced by agencies thus far into FY 2026 would yield a grand total of $1.34 trillion – still roughly $160 billion short of the administration’s apparent goal for the fiscal year.

While that is not an insignificant deficit, it is hardly inconceivable for the administration to close it in the coming months. For instance, there are 127 rulemakings scheduled for this remaining three-month window “where the major determination has not been made.” If enough of those carry savings estimates somewhere close to the billion-dollar threshold, then agencies could close the gap that way. Additionally, as mentioned earlier, the administration has made clear it is willing to attribute agency actions outside of the usual rulemaking context toward its regulatory budget math. To the extent the administration can ascribe some measurable economic impact to those actions, they may factor in as well. As such, that projection of $1.5 trillion in cost reductions remains within the realm of possibility.

CONCLUSION

Despite their relative obscurity, UA reports provide a uniquely comprehensive look at a given administration’s policymaking positions. The publication circumstances of this edition – both in the delayed release and its posting the day before the nation’s 250^th Independence Day without a major announcement by senior administration officials or the president – suggest that the Trump deregulatory agenda has taken something of a back seat as a rhetorical and political priority. The actual content of the report belies that conclusion as a policy matter, however, as this UA makes clear that agencies remain active both in terms of the scope and degree of regulatory rollbacks for the foreseeable future.