Saturday, September 6, 2025

Review – Spring 2025 Unified Agenda – DHS Rulemakings

Thursday the Trump Administration published their Fall 2024 Unified Agenda. The Unified Agenda lays out the major regulatory measures that the Administration is considering taking action on over the next year. The listing of a rulemaking or the estimated action dates associated with a rulemaking are aspirational at best and no guarantee of agency action, especially since there will be a change in Administration in January. There are 45 rulemakings listed for DHS with 28 rulemakings on the Long-Term Action list for the Department. There are now 98 DHS rulemakings on the Inactive Actions list.

DHS Active Rulemakings

The DHS portion of the Spring 2025 Unified Agenda lists 45 rulemakings, only one of which would be covered here in this blog if/when any actions are taken. That rule making is:

Cyber Incident Reporting for Critical Infrastructure Act (CIRCIA) Reporting Requirements, 1670-AA04.

Commentary

The Unified Agenda is an ongoing exercise in trying to keep track of the regulatory efforts of the Federal Government. Given the fact that the Executive Branch does not have enough people to complete all of the detailed work on developing and amending the regulations directed by the President, Congress and the Courts, it is not surprising that the ‘expected’ dates for the next stage of the rulemaking process are largely aspirational, and not actual predictions that can be tracked for their forecasting accuracy. Still, it is the tool that we have.

The one area of Unified Agenda that is less aspirational is the Abstract listing for each rulemaking. This is the current summary of what the administration sees as the purpose and scope of the rulemaking. They contain little in the way of details, but they do provide some insight into how any current work is proceeding.

 

For more information on the DHS actions listed in the Spring 2025 Unified Agenda, see my article on CFSN Detailed Analysis - https://patrickcoyle.substack.com/p/spring-2025-unified-agenda-dhs-rulemakings - subscription required.

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