EXECUTIVE SUMMARY

• In fiscal year 2026, federal agencies published approximately $1.5 trillion in self-reported regulatory cost reductions under the Trump Administration’s updated regulatory budget program.
• While a vast majority of this sum comes from just three rules, agency rulemaking activity over the past fiscal year has been firmly on the deregulatory side of the ledger, bringing the overall Trump 2.0 cost savings total to nearly $1.6 trillion.
• As in President Trump’s first term, it is possible the administration’s deregulatory efforts have reached their apogee in the second year, with the most consequential rulemakings that are still under development potentially yielding sizable net costs.

INTRODUCTION

The Trump Administration’s regulatory budget – as established in this term under Executive Order (EO) 14192 – continues to be the lodestar of its executive branch policymaking efforts. While a regulatory budget is, of course, substantially different from a fiscal budget, the closing of the fiscal year provides an apt opportunity to assess the administration’s progress in conducting such an exercise. Over the course of fiscal year (FY) 2026, federal agencies published 152 final rules under EO 14192 whose combined estimated economic effects represented nearly $1.5 trillion in total net regulatory cost reductions – bringing the administration’s overall to-date total to nearly $1.6 trillion. Despite that massive sum, a cursory look at some of the most significant rules still on the horizon suggests that – much as in the first Trump term – the administration may see diminishing returns in its deregulatory efforts going forward.

EO 14192 IMPLEMENTATION DURING FY 2026

The table below includes the top-line count and cumulative costs or savings from rules that: A) agencies finalized in FY 2026 (Oct 1, 2025, through September 30, 2026), B) included quantified costs or savings estimates, and C) contained some explicit mention of the rule’s connection to the EO 14192 regulatory budget framework[1]. Please note that while the Trump Administration’s own FY 2025 accounting – and thus presumably any forthcoming FY 2026 update – includes a broad scope of items (such as guidance documents), this American Action Forum (AAF) analysis confines itself to this subset of rulemakings. Past iterations of AAF’s work on EO 14192 calculations can be found here, here, and here.

Federal agencies ended FY 2026 with 95 deregulatory rules against 15 regulatory actions, good for a roughly 6.3-to-1 ratio. In terms of the estimated economic impact of these rules, there has been a notable shift in the “deregulatory” total since AAF last examined the issue. The Department of Transportation’s latest change to fuel efficiency standards – which came in just under the wire on September 30 – and the Environmental Protection Agency’s (EPA) roll-back of carbon emissions standards for power plants combined to add roughly $378 billion to the “cost reductions” column. With that, total estimated net cost savings for FY 2026 under EO 14192 came in at just under $1.5 trillion.

Three rules (the two rules noted above and the EPA rule repealing the greenhouse gas “endangerment finding”) accounted for roughly 95 percent of that savings total. Even if one were to remove those three outliers from consideration though, the other 149 rules included in the sample add up to nearly $25 billion in total net savings – signifying the overall deregulatory trend for the fiscal year. Adding the roughly $82 billion in total net savings from applicable rules finalized during FY 2025 brings the overall to-date total net savings for the Trump Administration to $1.57 trillion.

EXPECTATIONS FOR FY 2027

With agencies now moving into FY 2027 – and the second half of this Trump term – it is reasonable to examine how the regulatory budget will look going forward. Consider, for instance, that in the first Trump term, the only calendar year that had overall net cost reductions was 2018. This came even as 2019 and 2020 had sizable deregulatory actions under the auspices of the previous EO 13771 regulatory budget framework (such savings were eclipsed by even more outsized costs from rules falling outside of that EO’s scope). The following table includes currently proposed rules one can expect agencies to finalize over the next year or so that have: A) currently estimated economic effects in the billions of dollars, and B) some clear EO 14192 designation under the categories included above.

From a sheer rule-count metric, this cohort of rules achieves a 15-to-1 ratio with 30 deregulatory actions against two regulatory ones. There is another handful of rules that fall into either the “Exempt” or “Not Applicable” categories. One of these exempt rules – the Department of Homeland Security rulemaking on “Employment Authorization Reform for Asylum Applicants” – proves to the most consequential, with its $144.3 billion in currently estimated costs decidedly overtaking the various deregulatory actions and yielding $45.5 billion in total net costs across the 37 forthcoming rulemakings included here.

Another resource in forecasting near-term significant rulemakings is the latest Unified Agenda. While most agencies’ entries include limited data, there are some instances where they identify and describe potential economic impacts. There are two deregulatory rules under development from Department of Health & Human Services and EPA, that could bring cost reductions that approach the billion-dollar threshold. Another action carrying a “regulatory” designation, however, may add a significant sum to that side of the ledger. The Food and Drug Administration’s planned rulemaking on “Transparency in Direct-to-Consumer Advertising” does not include a preliminary cost estimate but does state that: “To provide context for the magnitude of such potential costs, we note that, in 2023, the top ten pharmaceutical companies spent a combined $13.8 billion on the promotion of drugs directed at U.S. consumers and physicians.”

CONCLUSION

Regulatory policy over the past several years, whether it be under Biden or Trump, has entered the trillion-dollar realm. Indeed, much of the current administration’s rulemaking efforts have been focused primarily on dismantling the roughly $1.8 trillion in self-reported regulatory costs implemented by its predecessor. In terms of gross impact, the scale of this Trump regulatory budget program has been an order of magnitude greater than that seen during the first Trump term. A similar trendline to that first iteration looms large though. Despite the clear intention to remain in a deregulatory posture, agencies may have already exhausted their most significant cost-cutting rules while some substantial burden-adding items remain on the horizon.

[1] The “Exempt” category includes rules where the agency cited one of the exemptions explicitly mentioned in either the EO or its implementation guidance. The “Not Applicable” category includes rules where the agency mentioned EO 14192 but did not give a specific designation to the rule.