The Claim

Launched the largest deregulation initiative in U.S. history, delivering $5 trillion in savings.

The Claim, Unpacked

What is literally being asserted?

Two things: (1) that the Trump administration launched the largest deregulation initiative in American history, and (2) that this initiative delivered $5 trillion in savings.

What is being implied but not asserted?

That $5 trillion in actual, realized savings have been delivered to the American public. That deregulation is an unambiguous economic benefit. That “savings” flow to ordinary Americans. That “largest” is measured by some objective standard that accounts for historical comparisons. That the savings figure reflects a rigorous, independent accounting.

What is conspicuously absent?

The source of the $5 trillion figure — it comes from Casey Mulligan of the Committee to Unleash Prosperity, not from any government accounting office, and represents a projection of what Biden-era regulations “would have cost,” not realized savings. That the administration’s own OIRA reported $211.8 billion in FY2025 cost savings — roughly 4% of the claimed $5 trillion. That even the center-right American Action Forum found only $129.7 billion in net savings from final rules, with two single rules accounting for $139 billion of that total and all other actions producing a net regulatory cost of $9.4 billion. That the administration’s methodology explicitly assumes regulations have “no market benefits” — ignoring the health, safety, environmental, and consumer protections those regulations provided. That NYU’s Institute for Policy Integrity estimates $152.9 billion in annual net benefits at risk from the rollbacks, including 3,299 premature deaths annually. That during the first Trump term, 78% of challenged deregulatory actions were struck down in court. That Jimmy Carter’s deregulation of airlines, trucking, rail, and telecommunications in 1978-1980 — which dismantled entire regulatory agencies and restructured major sectors of the economy — arguably constitutes a larger deregulatory initiative by any structural measure.

Evidence Assessment

Established Facts

Executive Order 14192, signed January 31, 2025, established a 10-to-1 deregulation-to-regulation ratio and directed agencies to pursue aggressive deregulation. The order, titled “Unleashing Prosperity Through Deregulation,” directed agencies to identify at least 10 existing regulations for repeal when proposing any new regulation and required the total incremental cost of all new regulations in FY2025 to be “significantly less than zero.” This is the foundational document for the administration’s deregulatory agenda. By year-end, OIRA reported 646 deregulatory actions versus 5 regulatory actions — a 129-to-1 ratio. ¹

The $5 trillion figure originates from Casey Mulligan’s estimate of “true” Biden-era regulatory costs, not from any realized savings. The Council of Economic Advisers’ June 2025 report, “The Economic Benefits of Current Deregulatory Efforts,” derived the figure from Mulligan’s methodology for the Committee to Unleash Prosperity. Agencies self-reported $2.077 trillion in regulatory costs over Biden’s full term. Mulligan estimated the “true cost” at $5.792 trillion by applying multipliers (averaging 2.8x, and up to 17x for certain agencies), then adjusted to $5.02 trillion after actual reports came in 13.3% below forecast. The CEA acknowledged the calculation assumes “every dollar of regulatory cost reduces GDP by one dollar” and that regulations have “no market benefits.” ²

The administration’s own OIRA reported $211.8 billion in FY2025 deregulatory cost savings — roughly 4% of the claimed $5 trillion. This is the official figure from OMB’s Office of Information and Regulatory Affairs end-of-year statistical release. The American Action Forum independently tallied $129.7 billion in net savings from final rules. Critically, AAF found that two rules alone — the Beneficial Ownership Information reporting repeal ($84 billion) and the long-term care staffing standards repeal ($55.1 billion) — accounted for $139.1 billion. Without those two rules, all other 2025 regulatory actions produced a net cost of approximately $9.4 billion. ³

Strong Inferences

The administration institutionally dismantled the benefit-cost framework that had governed regulatory review since 1981. In October 2025, OIRA issued a memo reducing review time for deregulatory actions from 90 days to 28 days (14 days for repeals of “factually unlawful rules”) and listing deregulatory benefits that “do not need to be quantified,” including “increases in the scope of private freedom.” The Regulatory Review at the University of Pennsylvania noted this effectively instructs OIRA to “turn a blind eye” when analysis shows deregulation is costly — abandoning 36 years of bipartisan benefit-cost methodology. ⁴

NYU’s Institute for Policy Integrity estimates $152.9 billion in annual net benefits at risk from the administration’s deregulatory actions, including 3,299 premature deaths per year. The tracker, which uses the government’s own regulatory impact analyses, identifies $21.7 billion in monetized health benefits at risk, $118.7 billion in climate benefits at risk, and $16.6 billion in consumer savings at risk. Major contributors include light/medium-duty vehicle GHG standards ($98.9 billion in net benefits at risk), power plant GHG standards ($22.9 billion), and heavy-duty vehicle standards ($14 billion). The tracker also identifies 7,461 new child asthma cases and 3,922 hospital/ER admissions annually at risk. ⁵

Jimmy Carter’s deregulation of airlines, trucking, rail, and telecommunications in 1978-1980 dismantled entire regulatory agencies and restructured major sectors of the economy. The Airline Deregulation Act (1978) abolished the Civil Aeronautics Board. The Motor Carrier Act (1980) deregulated trucking entry, routes, and pricing. The Staggers Rail Act (1980) introduced competitive rail pricing. These reforms eliminated federal control over pricing and market entry across transportation — permanently restructuring industries that represented a substantial share of GDP. The Regulatory Review called Carter “The Great Deregulator,” noting his reforms “unleashed innovation and generated tens of billions of dollars in lasting benefits for consumers and society.” ⁶

The $5 trillion figure is a projection, not a realized savings amount, and no credible independent analysis supports it. The CEA’s own more specific tally reached $907 billion in identified potential savings from specific regulatory actions. OIRA’s official figure was $211.8 billion. AAF’s independent tally was $129.7 billion. The gap between $5 trillion (Mulligan projection), $907 billion (CEA-identified actions), $211.8 billion (OIRA-reported), and $129.7 billion (AAF independent) reveals a savings figure that shrinks by roughly an order of magnitude at each step from rhetoric to reality. The Mulligan methodology was criticized by Econbrowser’s Menzie Chinn as relying on “speculative additions beyond government estimates” from an economist who famously predicted no recession in September 2008. ⁷

The administration’s deregulatory “savings” represent costs shifted from regulated industries to the public, not net economic gains. When the EPA claimed $1.3 trillion in savings from repealing vehicle emission standards, FactCheck.org found the figure counted only compliance costs while ignoring fuel savings, health benefits, and avoided premature deaths. Using EPA’s own analysis with EIA fuel price projections, rescinding the standards would cost Americans $180 billion net. Yale economist Kenneth Gillingham said he could not “recall another rulemaking where the focus…was ONLY about the costs.” The administration’s one-sided accounting — counting industry compliance costs avoided as “savings” while ignoring public health and environmental benefits foregone — means the $5 trillion figure is not savings at all but a transfer of costs from regulated firms to the broader public. ⁸

The first Trump term’s deregulatory record suggests many second-term actions will not survive legal challenge. Brookings’ analysis found the first Trump administration was “successful” only 22% of the time when its regulatory or deregulatory actions were challenged in court — 58 victories versus 200 losses. The EPA was especially unsuccessful: all 12 tracked actions faced litigation with only 2 fully resolved. The Department of Interior saw 5 of 8 actions completely overturned. Many of the same types of actions are being attempted in the second term with similar legal vulnerabilities. The administration’s deregulatory count does not subtract actions that are subsequently overturned by courts. ⁹

What the Evidence Shows

The claim contains two sub-assertions, and neither holds up under scrutiny.

First, “the largest deregulation initiative in U.S. history.” By what measure? If we count administrative actions, the 646 deregulatory actions in FY2025 is a large number — but many are minor procedural changes, guidance withdrawals, or proposed rules that have not been finalized. If we measure by structural impact on the economy, Carter’s 1978-1980 deregulation of airlines, trucking, rail, and telecommunications — which abolished entire federal agencies and permanently eliminated government control over pricing and market entry in industries representing significant shares of GDP — is hard to top. The Trump administration’s deregulatory actions largely involve repealing rules that were themselves only a few years old, not dismantling decades-old regulatory regimes. The “largest” claim is by self-assessment, not by any independent standard.

Second, “delivering $5 trillion in savings.” This is the most misleading part of the claim. The $5 trillion is not a realized figure. It is not an official government estimate. It is a projection from Casey Mulligan at the Committee to Unleash Prosperity — an advocacy organization cofounded by Arthur Laffer and Stephen Moore — estimating what Biden-era regulations “would have cost” using a methodology that multiplies agency-reported costs by factors of 2.8x to 17x and explicitly assumes that regulations have zero market benefits. The administration’s own numbers tell a different story at every level: the CEA identified $907 billion in specific actions; OIRA reported $211.8 billion in realized FY2025 savings; and AAF independently tallied $129.7 billion in net final-rule savings, of which $139 billion came from just two rules. When you strip away the projections and advocacy math, the actual deregulatory savings are roughly 2.5% of the claimed figure.

But even the real savings figures are only half the ledger. The administration’s cost-savings methodology counts only the compliance costs that regulated industries no longer have to pay. It does not count the public health, environmental, and consumer protection benefits those regulations provided. NYU’s Policy Integrity tracker estimates $152.9 billion in annual net benefits at risk, including 3,299 premature deaths per year. FactCheck.org found that the EPA’s $1.3 trillion vehicle emissions “savings” claim actually represented a net cost to Americans of $180 billion when fuel savings and health benefits were included. The October 2025 OIRA memo institutionalized this one-sided accounting by explicitly exempting deregulatory benefits from quantification while accelerating review timelines to as little as 14 days. The administration is not just miscounting savings — it has redesigned the counting system to ensure it can never produce an unfavorable number.

The Bottom Line

The administration did pursue an aggressive deregulatory agenda in 2025 — that much is real. EO 14192 set an ambitious framework, and agencies completed hundreds of deregulatory actions. But calling it “the largest in U.S. history” ignores Carter’s structural transformation of entire economic sectors, and “delivering $5 trillion in savings” is a fantasy figure derived from an advocacy organization’s speculative methodology that the administration’s own agencies contradict at every level. The real figure — somewhere between $130-212 billion in reduced compliance costs for 2025 — comes with a price tag the claim never mentions: an estimated $152.9 billion in foregone annual public health and environmental benefits, including thousands of premature deaths. Deregulation is not free money. It is a transfer of costs from regulated industries to the broader public, and calling that transfer “savings” is the core deception of the claim.

Footnotes

1. Executive Order 14192, “Unleashing Prosperity Through Deregulation” (2025-01-31); Federal Register Vol. 90, No. 24 (2025-02-06); OIRA End of Year Deregulatory Stats (2025-12-31). ↩

2. Council of Economic Advisers, “The Economic Benefits of Current Deregulatory Efforts” (2025-06); Casey Mulligan, Committee to Unleash Prosperity. ↩

3. OIRA End of Year Deregulatory Stats (2025-12-31); American Action Forum, “2025: The Year in Regulation” (2026-01-15). ↩

4. OIRA Memo, “Streamlining the Review of Deregulatory Actions” (2025-10-21); Stuart Shapiro, “Another Blow to Regulatory Benefit-Cost Analysis,” The Regulatory Review (2025-12-10). ↩

5. Institute for Policy Integrity, NYU School of Law, “Tracking the Damages of Regulatory Rollbacks” (accessed 2026-03-18). ↩

6. Airline Deregulation Act, Pub. L. 95-901 (1978); Motor Carrier Act of 1980; Staggers Rail Act of 1980; Susan Dudley, “Jimmy Carter, The Great Deregulator,” The Regulatory Review (2023-03-06). ↩

7. Econbrowser (Menzie Chinn), “CEA Unleashed!” (2025-06-15); CEA June 2025 report; OIRA End of Year Stats; AAF “2025: The Year in Regulation.” ↩

8. FactCheck.org, “EPA’s Misleading Claim of $1.3 Trillion in Deregulatory ‘Savings’” (2026-03-10); Kenneth Gillingham (Yale); Jason Schwartz (NYU). ↩

9. Brookings Institution, “Examining Some of Trump’s Deregulation Efforts: Lessons from the Brookings Regulatory Tracker” (2025-10); Institute for Policy Integrity litigation data. ↩