At least on domestic policy, the administration has in a short period of time made a remarkable amount of progress on implementing the mandate’s recommendations. Of the more than 530 executive actions across 20 agencies that the document advises, 28 percent have already been undertaken or completed.
“A substantial plurality track very closely with specific recommendations in Project 2025,” Goodwin said, mentioning the executive orders on transgender rights as a particularly striking example. “In some cases, the language is almost lifted verbatim — or, in other cases, where the executive order itself accomplishes something that Project 2025 called for in general.”
Much like the Trump Administration’s attempt to “dismantle and disable the agency entirely,” the administration’s latest effort to prevent CFPB from enforcing vital consumer protections is unlawful.
Even after the Supreme Court’s shadow-docket decision, there remain ways to assert award-termination challenges in district court.
The justifications in Trump’s orders seem to be “pushing on a few doors to get around notice and comment procedures just to see which door, if any, the courts allow to open,” Reed Shaw, an attorney with the left-leaning Governing for Impact, told NOTUS.
“There are these three discrete exceptions to notice and comment requirements under the [Administrative Procedure Act] that the administration is now applying incredibly broadly to try to remove a bunch of subjects from notice and comment,” said John Lewis, also at Governing for Impact, pointing to similar recent actions by Health and Human Services and the State Department to circumvent public input requirements.
The report noted a corresponding push in at least 30 mostly Republican-controlled states to weaken workplace protections for children, and warned the second Trump administration would seek to escalate the rollback.