Fewer Rules, Fewer Agencies, And No Apocalypse

There was Hollywood’s The Day the Earth Stood Still. Now meet Washington’s Year the Regulation Stopped.

The end of July 2025 finds just 1,490 finalized regulations published in the Federal Register, which itself stands at 35,964 pages. A typical year concludes with a bit over 3,000 completed rules.

That’s a milestone: this first year of the second Trump administration is on track—just as we noted at mid-year—to deliver the lowest rule count ever recorded, even lower than the 2,964 issued by Trump in 2019. In the realm of these notice-and-comment rules, Trump is besting his past cross-agency birdies with eagles.

What is more, fully 243 of those final rules and 7,648 of the pages came from Biden in January, leaving Trump with a net of only 1,247 rules (and 28,316 pages).

This is no blip. Officials at the Environmental Protection Agency (EPA), the Department of Energy and more boasting of dramatic rollbacks of unnecessary regulations, staff cuts, office closures and contract terminations.

WASHINGTON, DC – JULY 08: EPA Administrator Lee Zeldin (L), accompanied by Director of National Intelligence Tulsi Gabbard (R), speaks during a cabinet meeting with U.S. President Donald Trump at the White House on July 08, 2025 in Washington, DC. Trump discussed a wide range of topics during the portion of the meeting that was open to members of the media. (Photo by Andrew Harnik/Getty Images)

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But the sub-3,000 rule trajectory is actually eclipsed by something even more noteworthy.

This unprecedented stall in regulatory activity isn’t just about fewer rules—it marks the rise of the “Unrule.” Many of the “rules” from the Trump administration aren’t new mandates at all, but rather delays, withdrawals, recissions and RIP declarations. Even the 945 proposed rules so far tend to be deregulatory. Where necessary, some rules are being rewritten with fresh public input. But more broadly, the era is defined by the defunding of programs and the shuttering of offices.

During Trump first term, operating under a “one-in, ten-out” policy, most “significant” regulatory actions (a label rooted in a Clinton-era executive order) were deregulatory in nature, as the chart here shows.

Now, Trump 2.0 has adopted a more aggressive version of one-in, ten-out, making the Unrule even more stark. For example, of the 1,490 rules issued so far, only 76 are “significant” final rules. And among those we find:

• numerous recissions;
• removals from inclusion as a regulatory priority in the (overdue) Spring 2025 “Unified Agenda of Federal Regulatory and Deregulatory Actions”;
• delays and postponements of effective dates;
• narrowing of reporting requirements;
• enforcement relaxations

Now, let me offer a galaxy-sized caveat: Trump retains many interventionist, anti-market, and outright swampy tendencies — on issues ranging from antitrust to AI to price regulation and tariffs. His economic management tends toward the transactional rather than a principled federal neglect, meaning the welcome mid-year rule drought cannot yet be presented as pure deregulation.

Still, what’s unfolding is rather astonishing. While conventional voices wail about chaos and disarray in the White House, it’s becoming clear that much regulation was never needed, was constitutionally suspect, and amounted to bureaucratic overreach. The so-called “chaos” is merely the old administrative state being tamed.

The Administrative Procedure Act (APA), long defended as the referee of the regulatory game and protector of the public, appears suspect. Under past administrations, agencies routinely invoked the APA’s “good cause” exception to issue final rules without public comment. But now, the same APA is being used to block Trump’s use of that very rationale to undo what was never legitimate lawmaking in the first place. In today’s regulatory state, repealing a rule often requires writing another one just to kill it. The backlash against the Unrule makes it plain who really benefits from the APA and the deep state. If lawmaking—including regulation—were left to Congress rather than delegated to unelected bureaucrats, we wouldn’t need an APA. That should be the goal.

In the meantime, the administration and Congress should formalize the concept of the Unrule in the Federal Register and Unified Agenda so that the public could search the documents electronically and readily isolate the deregulatory from the conventionally regulatory, unlike my crude roundup above. In the first Trump term, year-end reports from the White House Office of Management and Budget detailed the “Deregulatory” actions seen in the table above, but that transparency and disclosure vanished immediately under Biden–not that his administration had any deregulation to showcase.

As the administration and Congress de-scale the administrative state with Unrules and more, they must recognize that entrenched agencies have workarounds. They’ll lean on guidance documents, bulletins, policy memos, and other sub-regulatory decrees to regulatory less directly. These proclamations shape behavior, but conveniently avoid that vaunted APA’s notice-and-comment strictures. Several of Trump’s orders rightly target these documents, but he really should go further: reissue and strengthen his 2019 order requiring agencies to purge outdated guidance and post all current ones in searchable online portals – explicitly noting that they’re non-binding.

The key takeaway from Trump’s first six months is this: we no longer need to squint at the Federal Register to guess what’s regulatory and what’s deregulatory. The rise of the Unrule signals the need for Congress to formalize deregulatory policy alongside regulatory policy. We need better tools to disentangle binding rules from deregulatory actions – and from the vast ocean of sub-regulatory guidance.

It is a remarkable change to discover that many of the 1,485 rules issued so far this year aren’t substantive regulations in the traditional form of entailing burdensome compliance. They’re mop-up operations: delays, halts, and reversals. But such efforts can be temporary. They’re like putting yellow caution tape around the old red tape—until the next administration arrives to string it all back up.

The year 2025 has shown us something that 80 years of APA-era rulemaking tried to obscure: that life without constant new federal rules is not only possible—it might be preferable. It has offered at least a fleeting glimpse of life without constant federal micro-management. And guess what? The Earth still turns.

But agencies still exist, still get funded, and still issue guidance. So this moment must not be wasted. It’s time not only to eliminate unnecessary rules—but to begin phasing out the agencies that shouldn’t exist in the first place.

The rise of the Unrule presents a rare opportunity—not just for deregulation, but for rethinking the very concept of regulation.