Week in Regulation

Another Up-and-Down Week

Continuing the trend from the week prior, the past week’s haul of regulations was all over the place. There were 11 rulemakings that contained some kind of quantified economic impact. A pair of rules from the Department of Labor (DOL) regarding employment standards for federal contractors brought the most substantial cost reductions. Meanwhile, proposed rules from the Department of Education (ED) and Internal Revenue Service (IRS) on higher education accreditation and Trump Accounts, respectively, involved sizable new administrative burdens. Overall, federal agencies published roughly $3.3 billion in total cost savings but added 4.1 million paperwork burden hours.

REGULATORY TOPLINES

  • Proposed Rules This Week: 38
  • Final Rules This Week: 43
  • 2026 Total Pages: 54,563
  • 2026 Final Rule Costs: -$1.1 trillion
  • 2026 Proposed Rule Costs: $50.4 billion

NOTABLE REGULATORY ACTIONS

The most significant deregulatory actions of the week were two final rules from DOL regarding “Rescission of Executive Order (EO) 11246 Implementing Regulations” and “Modifications to the Regulations Implementing Section 503 of the Rehabilitation Act of 1973, as Amended.” The former marks the finalization of a rulemaking stemming from a day-one Trump EO that plainly sought to revoke nondiscrimination standards for federal contractors established by EO 11246 back in 1965. Beyond the broader legal implications at hand, the regulatory cost-benefit impact is essentially the same as the proposed rule’s analysis: roughly $7 billion in total cost savings due to a nearly 10-million-hour reduction in required paperwork. The latter rule from DOL focuses on revising agency standards emanating from the titular statutory section:

Which prohibits covered Federal contractors and subcontractors (“contractors”) from discriminating against employees and applicants because of their disability status and also requires certain contractors to take “affirmative action” to employ and advance in employment qualified individuals with disabilities.

DOL expects that such changes will also eliminate reporting requirements for affected contractors. The agency estimates that the net reduction in annual paperwork will be roughly 1.6 million hours (with approximately $86 million in associated annual cost savings).

The most significant regulatory action of the week was the proposed rule from ED on “Accreditation, Innovation, and Modernization: The Secretary’s Recognition of Accrediting Agencies: Institutional Eligibility Under the Higher Education Act of 1965, as Amended, Student Assistance General Provisions.” The proposal seeks to make a series of changes to the regulatory provisions governing “accrediting agencies” that grant legitimacy to relevant institutions of higher education. ED expects the proposal to produce qualitative benefits in the form of increased flexibility for affected institutions and greater transparency for students, but also anticipates quantified compliance burdens of roughly 8.6 million hours of new paperwork and $494 million in associated costs each year.

The other notable burden-adding rulemaking of the week was the IRS proposed rule on “Guidance on Eligible Investments for Trump Accounts.” As the title suggests, the proposal seeks to “define terms related to eligible investments, provide rules for determining whether an investment fund is an eligible investment, and provide procedures for a trustee of a Trump account to ensure that a Trump account meets requirements concerning eligible investments.” As with any significant update to the tax treatment of relevant financial instruments, however, there will be substantial compliance requirements. IRS estimates that the administrative burdens involved in affected entities demonstrating compliance will add up to nearly 6.7 million hours of paperwork each year.

TRACKING TRUMP 2.0

In assessing 2026 rulemakings that include an EO 14192 determination, there have been 70 “deregulatory” rules with combined total savings of $1.1 trillion against 13 “regulatory” rules that involve roughly $45.9 billion in costs. Adding that to the total agencies produced during 2025 (at least from rules that had a clear “regulatory” or “deregulatory” designation), the Trump Administration has enacted $1.2 trillion in total cost reductions thus far under EO 14192. Rules for which agencies have claimed one of the EO’s exemptions have accounted for an additional $7.1 billion in costs so far in 2026.

CONGRESSIONAL REVIEW ACT (CRA)

The AAF CRA tracker provides a full survey of activity under the law thus far into this term. As of today, members of the 119th Congress have introduced CRA resolutions of disapproval addressing 147 “rules” that collectively involve $172 billion in estimated compliance costs. Of these, 23 have been passed into law, repealing a series of Biden Administration rules that had a combined $3 billion in associated compliance costs. The Trump Administration estimates that the repeal of a Biden-era rule on air pollutants yields an additional $936 million in savings. While the main window of CRA action has largely passed, there are still outstanding resolutions that could move legislatively. AAF will continue to monitor and update such developments as appropriate.

TOTAL BURDENS

Since the start of 2026, the federal government has published $1 trillion in total regulatory net cost savings (with $1.1 trillion in reductions from finalized rules) and 107.2 million hours of net annual paperwork increases (with 75.8 million hours coming from final rules).

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