Project 2025 Tracker / What’s done, what’s next

18. Department of Labor and Related Agencies · Major · Needs Congress

Amend the Administrative Procedure Act to limit guidance documents

Not started

593 18. Department of Labor and Related Agencies

“Congress should amend the Administrative Procedure Act to explicitly limit the use of guidance documents.”

What has happened

  1. Not started

    No amendment to the Administrative Procedure Act limiting guidance documents has been enacted or passed either chamber. The two guidance bills that moved are about disclosure, not limits: the GOOD Act (H.R. 1515) passed the House by voice vote on 2025-03-03 and only requires agencies to post guidance documents in one place online, and the Guidance Clarity Act (S. 81, H.R. 2409) sits on the Senate and House calendars unpassed. None of the 104 public laws of the 119th Congress touches 5 U.S.C. chapter 5.

    No action found yet. This entry is the starting point, not a finding.

Research log

What was searched, and what didn’t count as evidence

Research notes

Negative search (playbook 1.6).

  • bills.ndjson (18,433 bills of the 119th Congress), title match on Administrative Procedure Act|Guidance Out Of Darkness|GOOD Act|guidance document: H.R. 1515 / S. 252 (GOOD Act), H.J.Res. 125 and S.J.Res. 82 (CRA disapproval of an HHS rule about APA text), H.R. 9277 and H.R. 9278 (APA judicial-review evidence rules). Title match on REINS|Guidance Clarity|Separation of Powers Restoration: H.R. 142 / S. 485 (REINS Act, referred), S. 81 / H.R. 2409 (Guidance Clarity Act, calendared), H.R. 1605 (Separation of Powers Restoration Act, reported from committee).
  • public-laws.ndjson (104 laws): nothing amending the APA.
  • congress.gov API, H.R. 1515 /actions and /summaries: passed the House 2025-03-03 by voice vote, received in the Senate 2025-03-04, no further action. The summary is entirely a posting requirement — publish guidance online on issuance, keep it in a single location, mark rescinded documents — with a GAO compliance report in five years. It does not limit what guidance may do, which is what the Quote asks for.

Leads. The Guidance Clarity Act (requiring guidance documents to carry a statement that they lack the force of law) is the closest bill to the ask and has been placed on both calendars, but calendar placement is not passage. congress.gov bill pages return 403 to automated fetches, so bill text was read only through the API’s summaries.

Action
restrict
Object
Administrative Procedure Act
ID
1633