January 20, 2025

Executive Order: Regulatory Freeze Pending Review

Holland & Knight Eyes on Washington Blog
Trump's 2025 Executive Orders: Updates and Summaries

Date Issued: Jan. 20, 2025

Executive Summary

This executive order issues a regulatory freeze on all executive departments and agencies to review pending and existing laws and regulations. The freeze mandates that unpublished rules be withdrawn and unenacted rules be delayed. During this postponement, the rules will be reviewed, and stakeholders will have the opportunity to provide comments on issues of fact, law and policy raised by the rules. The Office of Management and Budget (OMB), in addition to department and agency heads appointed by the president, will oversee the review process.

Policy Actions

  • Prohibits any rule from being proposed or issued, including sending a rule to the Office of the Federal Register (OFR), until a department or agency head appointed by the president reviews and approves the rule.
  • The director or acting director of OMB may exempt rules that are necessary to address emergencies.
  • Any rules that have yet not been published in the Federal Register must be withdrawn for review, and any rules that have been published but not enacted should be delayed for 60 days for review. During this period, a comment period may be opened for interested parties to engage in.
  • After postponement, if any rules raise substantial questions of fact, law or policy, they must be further reviewed in consultation with OMB.

Trump's 2025 Executive Orders: Updates and Summaries

Holland & Knight's Public Policy & Regulation Group is reviewing President Trump's 2025 Executive Orders and other actions. To read all Executive Order Updates and Summaries, visit our landing page.

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