The Claim

Killed federal regulations at an astonishing 129-to-one rate — far topping the rate at which red tape was cut during President Trump’s first term.

The Claim, Unpacked

What is literally being asserted?

Two things: (1) that the administration “killed” 129 federal regulations for every one it created, and (2) that this ratio far exceeds the first-term deregulatory pace.

What is being implied but not asserted?

That 129 significant regulatory burdens were actually eliminated for each new one imposed. That the regulations “killed” were meaningful, binding rules with real economic impact. That the comparison to the first term is apples-to-apples — same methodology, same scope of what counts. That “killing” a regulation means it is permanently gone, not merely delayed, withdrawn from proposal, or replaced by guidance. That fewer regulations means a better outcome for Americans.

What is conspicuously absent?

How the 129-to-1 ratio is calculated — specifically, that it counts 646 “deregulatory actions” against only 5 “regulatory actions” as self-classified by agencies under a system where EO 14192 dramatically expanded what qualifies as “deregulatory” (including guidance withdrawals, memoranda, administrative orders) while exempting military, national security, homeland security, foreign affairs, and immigration-related regulations from the denominator. That the first-term claimed ratio of 5.5-to-1 was itself debunked by peer-reviewed research showing the ratio inverted to 2-to-1 regulatory when only significant rules were counted. That AAF found 2025’s deregulatory savings were dominated by two rules accounting for $139 billion, while all other actions produced a net cost of $9.4 billion. That CEI — a libertarian, pro-deregulation think tank — called the year-end numbers an “illusion” because guidance documents, procurement conditions, grant requirements, and other regulatory “dark matter” go uncounted. That during the first term, 78% of challenged deregulatory actions were struck down in court.

Overlap Analysis: Items 90 and 233

This claim overlaps substantially with item #90 (“Launched the largest deregulation initiative in U.S. history, delivering $5 trillion in savings”) and item #233 (“Slashed job-killing regulations to unleash innovation, lower costs, and put American workers first”). Item 90 established the broader deregulatory claim; item 233 is the general framing; this item adds the specific 129-to-1 ratio. The same OIRA year-end data, the same EO 14192 framework, and the same fundamental counting methodology underlie all three claims.

Evidence Assessment

Established Facts

OIRA reported 646 deregulatory actions and 5 regulatory actions in FY2025, yielding a 129-to-1 ratio. The White House Office of Management and Budget released end-of-year deregulatory statistics on December 31, 2025, reporting these figures. The 129-to-1 ratio dramatically exceeded EO 14192’s target of 10-to-1. OIRA claimed $211.8 billion in net cost savings from these actions. The bulk of deregulatory actions were at the Departments of Treasury, Veterans Affairs, Transportation, Agriculture, and Homeland Security. ¹

EO 14192 expanded the definition of “regulation” to include guidance documents, memoranda, administrative orders, and policy statements. The executive order defined rules and regulations as “an agency statement of general or particular applicability and future effect designed to implement, interpret, or prescribe law or policy,” explicitly including “without limitation, regulations, rules, memoranda, administrative orders, guidance documents, policy statements, and interagency agreements regardless of whether they are subject to the APA.” This means withdrawing a non-binding guidance document counts the same as repealing a final rule in the 129-to-1 tally. Simultaneously, the order exempted regulations pertaining to military, national security, homeland security, foreign affairs, and immigration from the ratio requirement — meaning new regulations in those categories do not count against the denominator. ²

The first-term claimed deregulatory ratio was 5.5-to-1, but peer-reviewed research found this dramatically overstated. OIRA reported 538 deregulatory actions versus 97 regulatory actions (FY2017-2020) for the 5.5-to-1 headline. However, Coglianese, Sarin, and Shapiro’s 2021 study “The Deregulation Deception” found the administration classified 71% of its actions as neither regulatory nor deregulatory (“exempt” or “other”). When only significant regulatory and deregulatory actions were compared, the ratio inverted to approximately 2-to-1 regulatory — meaning the first term produced twice as many significant regulations as it repealed. At the economically significant level, the ratio was roughly 1-to-1. ³

AAF’s independent analysis found 2025’s net savings were concentrated in two rules, with all other actions producing net costs. The center-right American Action Forum found $129.7 billion in net regulatory cost savings for 2025 — substantially below OIRA’s $211.8 billion figure. Two rules dominated: the FinCEN Beneficial Ownership Information reporting repeal ($84 billion) and the long-term care staffing standards repeal ($55.1 billion). Without those two rules, all other 2025 actions produced approximately $9.4 billion in net regulatory costs. Only about 67 published rules explicitly discussed EO 14192 compliance; of these, 40 were deregulatory. ⁴

Total final rule output in 2025 fell to 2,441 — the lowest since Federal Register recordkeeping began in the mid-1970s. This was substantially below Biden’s 3,248 in 2024 and beat Trump’s own first-term record low of 2,964 in 2019. Of these, 155 were deemed “significant.” Only 40 economically significant deregulatory moves had been completed by year’s end, out of 243 such actions in the active pipeline. The low total reflects both genuine deregulatory intent and agency paralysis from the regulatory freeze imposed on January 20, 2025. ⁵

Strong Inferences

The 129-to-1 ratio is not comparable to the first-term 5.5-to-1 ratio. The second-term ratio uses EO 14192’s expanded definition that counts guidance withdrawals, memoranda, and policy statements as “deregulatory actions.” The first-term ratio operated under EO 13771’s narrower “2-for-1” framework, which focused on notice-and-comment rulemaking. The numerator has been broadened (more things count as deregulatory) while the denominator has been constrained (more exemptions for new regulations). The comparison is structurally rigged to show improvement even if substantive deregulatory output were identical. ⁶

Even pro-deregulation analysts say the headline ratio overstates actual regulatory reduction. The Competitive Enterprise Institute — a libertarian think tank that actively advocates for deregulation — described the year-end numbers as an “illusion,” noting that “guidance documents, procurement conditions, grant requirements, subsidies, and public-private partnerships are not counted in one-in, ten-out tallies” and that these instruments “function as rule equivalents — binding in practice, yet insulated from the transparency, cost analysis, and procedural discipline that formal rulemaking is supposed to entail.” CEI’s Wayne Crews argued the real challenge for 2026 is addressing this “regulatory dark matter” that the headline ratio ignores entirely. ⁷

The first-term deregulatory record suggests many second-term actions will not survive legal challenge. Brookings found the first Trump administration won only 22% of court challenges to its regulatory and deregulatory actions (58 victories vs. 200 losses). The EPA was especially unsuccessful. Many of the same types of actions — repealing regulations without adequate notice-and-comment, failing to justify departures from prior findings, ignoring statutory mandates — are being attempted again. The 129-to-1 ratio does not subtract actions subsequently overturned by courts, meaning the number represents intent rather than durable legal change. ⁸

The administration abandoned the benefit-cost framework that would reveal the full impact of deregulatory actions. In October 2025, OIRA issued Memo M-25-36 reducing deregulatory review from 90 days to 28 days (14 days for repeals of “factually unlawful rules”) and listing categories of deregulatory benefits that “do not need to be quantified,” including “increases in the scope of private freedom.” The Regulatory Review’s Stuart Shapiro called this “another blow to regulatory benefit-cost analysis,” noting it instructs OIRA to “turn a blind eye” when analysis shows deregulation is costly. NYU’s Institute for Policy Integrity estimates $152.9 billion in annual net benefits at risk from the rollbacks, including 3,299 premature deaths per year. ⁹

What the Evidence Shows

The 129-to-1 ratio is a real number from official OIRA data. In that narrow sense, the claim is true. But the ratio is engineered to be impressive through three compounding mechanisms that make it deeply misleading as a measure of actual regulatory reduction.

First, the numerator is inflated. EO 14192 expanded what counts as a “deregulatory action” to include guidance withdrawals, memoranda rescissions, administrative order changes, and policy statement revocations — many of which are far less consequential than repealing a final rule that went through notice-and-comment rulemaking. The 646 “deregulatory actions” include everything from withdrawing a non-binding FAQ document to repealing an economically significant regulation. They are not comparable units. When AAF looked only at published rulemakings with measurable economic effects, the picture narrowed dramatically: two rules accounted for the vast majority of actual cost savings, and without them, the remaining actions imposed net costs.

Second, the denominator is artificially suppressed. New regulations in military, national security, homeland security, foreign affairs, and immigration domains are exempt from the ratio requirement. The regulatory freeze imposed on January 20, 2025 delayed or suspended hundreds of pending rules, some of which will eventually need to be finalized. The 5 “regulatory actions” in the denominator reflects both genuine restraint and accounting choices about what gets classified as “regulatory.” The first-term “Deregulation Deception” research showed that 71% of actions were classified as neither regulatory nor deregulatory — and the same incentive to under-classify regulatory actions exists in the second term.

Third, the comparison to the first term is not apples-to-apples. The 5.5-to-1 first-term figure used a different executive order (EO 13771), a different definition of what counts, and a narrower scope. Peer-reviewed research showed that even the 5.5-to-1 figure was misleading — at the level of significant rules, the first term actually produced more regulations than it repealed. Claiming the second-term ratio “far tops” the first term compares two numbers generated by different methodologies, both of which overstate actual deregulatory output.

The Bottom Line

The 129-to-1 ratio is accurately reported from OIRA’s end-of-year data, and the administration did pursue a genuinely aggressive deregulatory agenda in 2025. The total rule count was the lowest since the 1970s. These are real facts that should be acknowledged. But the ratio is a manufactured metric, not an organic measure of regulatory reduction. It was produced by expanding what counts as “deregulatory” (guidance withdrawals, memoranda), shrinking what counts as “regulatory” (broad exemptions), and comparing the result to a first-term ratio that was itself debunked by peer-reviewed research. When independent analysts look at actual published rules with measurable economic impact, 2025’s deregulatory savings came from two rules, and everything else was a net cost. When pro-deregulation think tanks call the numbers an “illusion,” and when the administration has simultaneously dismantled the benefit-cost framework that would reveal the full picture, the headline ratio tells you more about how the administration counts than about what the administration accomplished.

Footnotes

1. White House OMB, “OIRA Releases End of Year Deregulatory Stats” (2025-12-31). https://www.whitehouse.gov/briefings-statements/2025/12/32750/ ↩

2. Executive Order 14192, “Unleashing Prosperity Through Deregulation,” Federal Register Vol. 90, No. 24 (2025-02-06). https://www.federalregister.gov/documents/2025/02/06/2025-02345/unleashing-prosperity-through-deregulation ↩

3. Coglianese, Sarin, and Shapiro, “The Deregulation Deception,” University of Pennsylvania Law School (2021). https://scholarship.law.upenn.edu/faculty_scholarship/2229/ ; Coglianese, “Will Trump 2.0 Deregulate More than Trump 1.0?” The Regulatory Review (2025-01-20). https://www.theregreview.org/2025/01/20/coglianese-will-trump-2-0-deregulate-more-than-trump-1-0/ ↩

4. American Action Forum, “2025: The Year in Regulation” (2026-01-15). https://www.americanactionforum.org/insight/2025-the-year-in-regulation/ ↩

5. CEI, “Trump Slashed Rulemaking in 2025. The Hard Part Starts in 2026” (2026-01-10). https://cei.org/blog/trump-slashed-rulemaking-in-2025-the-hard-part-starts-in-2026/ ; CEI, “A Provisional Look at the Trump 2.0 Deregulation Record.” https://cei.org/blog/a-provisional-look-at-the-trump-2-0-deregulation-record/ ↩

6. EO 14192 (2025-02-06) vs. EO 13771 (2017-01-30); Coglianese et al. (2021). ↩

7. CEI, “Deregulation’s Year-End Illusion” (~2025-12-20). https://cei.org/blog/deregulations-year-end-illusion/ ↩

8. Brookings, “Examining Some of Trump’s Deregulation Efforts: Lessons from the Brookings Regulatory Tracker” (2025-10). https://www.brookings.edu/articles/examining-some-of-trumps-deregulation-efforts-lessons-from-the-brookings-regulatory-tracker/ ↩

9. OIRA Memo M-25-36, “Streamlining the Review of Deregulatory Actions” (2025-10-21). https://www.whitehouse.gov/wp-content/uploads/2025/10/M-25-36-Streamlining-the-Review-of-Deregulatory-Actions.pdf ; Shapiro, “Another Blow to Regulatory Benefit-Cost Analysis,” The Regulatory Review (2025-12-10). https://www.theregreview.org/2025/12/10/shapiro-another-blow-to-regulatory-benefit-cost-analysis/ ; NYU Institute for Policy Integrity, “Tracking the Damages of Regulatory Rollbacks” (updated 2026-02-13). https://policyintegrity.org/tracking-regulatory-rollbacks ↩