Experts Say Trump Inflated His Deregulation Numbers, but His Process Changes Are Here to Stay

Why It Matters

The new rulemaking framework concentrates authority in the White House, reduces regulatory certainty for businesses, and creates a lasting precedent for future administrations to curtail agency autonomy.

Key Takeaways

• Trump’s 10:1 directive yielded 129 deregulations per new rule.
• OIRA counted guidance and dead rules, inflating deregulation ratios.
• Federal Register pages fell to 61,600, lowest for a first year.
• CRA used to repeal 22 Biden rules and a Minnesota land order.
• Agencies now skip public comment, citing “good cause” exceptions.

Pulse Analysis

The Trump administration’s deregulation narrative hinges on a controversial accounting method. By expanding the definition of a "deregulatory action" to include guidance documents, policy letters and even defunct rules, the Office of Information and Regulatory Affairs reported a staggering 129 repeals for every new regulation. Critics at the George Washington University Regulatory Studies Center argue this approach skews the true impact, masking the fact that only a fraction of the counted actions would meet the traditional $100 million economic significance threshold. The inflated ratio has become a talking point for both supporters and detractors, shaping public perception of the administration’s regulatory legacy.

Beyond the numbers, the procedural overhaul reshapes how agencies operate. The 10:1 rule forces agencies to identify ten existing rules to eliminate before proposing a new one, effectively slowing the pace of new rulemaking. Coupled with a push to bypass the notice‑and‑comment process via the "good cause" exemption, agencies can repeal or modify rules with minimal public input. This centralization of decision‑making in the White House diminishes the role of subject‑matter experts within agencies, creating uncertainty for regulated industries that rely on predictable, transparent rulemaking cycles.

Politically, the administration has leveraged the Congressional Review Act to overturn not only recent Biden regulations but also a 2023 public‑land order protecting 225,500 acres in Minnesota. By interpreting the CRA to target older administrative actions, Republicans set a precedent that could be used by future presidents to retroactively dismantle longstanding policies. Analysts predict that the template established for accelerated deregulation—whether through sunset reviews or expanded CRA use—will persist, influencing the regulatory environment for years to come, regardless of which party holds the White House.