Here at the Center, we were among the first to sound the alarm on precisely these risks that Project 2025 — and especially its nearly 1,000-page policy blueprint called Mandate for Leadership — posed. That’s why we joined our colleagues at Governing for Impact in setting up a comprehensive tracker for monitoring the Trump administration’s progress in implementing Project 2025’s recommendations for domestic policy executive actions covering 20 different agencies.
The Center for Progressive Reform, which compiled a list of all the executive branch policies proposed in the conservative playbook, found the Trump administration has attempted or completed 153 of the 532 policies tracked as of April 15.
Will Dobbs-Allsopp, policy director of Governing for Impact, and James Goodwin, policy director at the Center for Progressive Reform, have publicly tracked the executive actions suggested for 20 different agencies in Project 2025 as Trump has carried some of them out. Of the 532 proposals in the project that fall under these actions, Trump has already proposed, attempted or completed 153 of them – about 29%.
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.”
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.
“I think it’s a question that the administration has tried to dance around,” John Lewis, deputy legal director at policy think tank Governing for Impact, told The Hill. “Thus far, it seems to want to have it both ways.”
“The administration can’t have it both ways,” said Adam Grogg, a former deputy general counsel at OMB and now the legal director at Governing for Impact, a left-of-center think tank. “Either it’s an agency covered by FOIA with the authority to do what it’s doing, or it’s purely advising the president and can’t be directing agencies in the way it now is.”
TRANSITIONS — Governing For Impact is adding Adam Grogg, John Lewis and Elisabeth Mabus. Grogg will be legal director and previously was deputy general counsel at OMB. Lewis will be deputy legal director and previously was a trial attorney for DOJ’s Federal Programs Branch. Mabus will be director of strategic initiatives and previously was deputy legal counsel in the Colorado governor’s office.