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

2. Executive Office of the President · Notable

Undo Biden changes to EO 12866 and OMB Circular A-4

Done

49 2. Executive Office of the President

“If the current Administration proceeds with its declared intent to modify aspects of EO 12866 or review OMB Circular A-4, the related document that provides the foundation for cost-benefit analysis, the next President should immediately begin to undo those changes and develop a rigorous, data-driven approach that will result in the least burdensome rules possible.”

What has happened

  1. Done

    Circular A-4 followed three weeks later. Acting on EO 14192, the Director issued M-25-15: "Pursuant to Executive Order 14192 of January 31, 2025 (Unleashing Prosperity Through Deregulation), I revoke Office of Management and Budget Circular A-4 of November 9, 2023 (Regulatory Analysis), and all accompanying appendices, guidelines, and documents. I reinstate Office of Management and Budget Circular A-4 of September 17, 2003 (Regulatory Analysis)." Both named Biden-era documents are now undone and the pre-2023 cost-benefit framework is back in force; the companion memorandum M-25-23 did the same for Circular A-94.

  2. Partially done

    The Biden amendment to EO 12866 went in the first tranche of revocations. EO 14148 section 2(ddd) revokes "Executive Order 14094 of April 6, 2023 (Modernizing Regulatory Review)" — the order that had rewritten EO 12866's significance thresholds and its instructions on distributional analysis. Circular A-4 was untouched that day.

Research log

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

Research notes

EO 14192 section 5(b) is the directive M-25-15 executes; we read both at govinfo and whitehouse.gov respectively. The 2003 Circular A-4 is the version now posted on OMB’s circulars page. The Quote’s closing clause — “develop a rigorous, data-driven approach that will result in the least burdensome rules possible” — is a general aspiration; the checkable objects are EO 12866 and Circular A-4, and both are restored.

Action
rescind
Object
Biden-era revisions to EO 12866 and OMB Circular A-4
ID
46