First 100 Days: Upcoming Regulatory Signals for ‘Deregulation’
Regulatory shifts based on executive/legislative and agency actions/directions

KPMG Regulatory Insights
- ‘Deregulation’ is not ‘No Regulation’: Despite new directives, shifts in enforcement intensity and priority, and select rule recissions, existing regulations stand and require ongoing adherence.
- New Rulemaking to Plummet: Expect ongoing withdrawals of proposed rules, modifications to existing regulations, and the increasing use of statements versus guidance.
- Quick Investigation/Enforcement Shifts: Expect enforcement activities to focus on the “letter of the law”, and cases to include those deemed “egregious” under the new Administration’s directives and to be impacted by workforce reductions and mission/enforcement shifts (e.g., FCPA, CTA).
- Global Pressures: Expect the Administration to continue pressure globally to “de-regulate”, including but not limited to technology regulations (e.g., DSA, AI Act).
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March 2025
Regulatory signals of the new Administration’s mandate for ‘de-regulation’ include:
- Executive & Legislative Actions/Directions, including Issuance of Executive Orders/Actions, Use of the Congressional Review Act, Workforce/ Organization Changes and Pressure on Global Regulation.
- Agency Actions/Directions, including Modifications to/ Withdrawal of Rules/Guidance, Withdrawal from Legal Actions, and Redefined Enforcement Focus.
1. Executive & Legislative Actions/Directions
A series of directives look to reshape the regulatory environment. Signals include:
Signals | Description/Examples | Source |
---|---|---|
Issuance of Executive Orders/Actions | Implementation of Executive Orders and Actions on:
| |
Use of Congressional Review Act | Ongoing introduction of legislation (i.e., a joint resolution of disapproval) to overturn federal agency rulemakings/actions. Resolutions introduced to date include regulations issued by DOA, CFTC, DOD, DOE, EPA, FCC, FRB, FTC, OCC and Treasury. | |
Workforce/ Organizational Changes | Implementation of the Executive Order on “DOGE Workforce Optimization Initiative”, which calls for “large-scale reductions in force” across federal agencies (e.g., DOE, HHS, DHS, DOJ, etc.) to be accomplished through efficiency improvements and attrition with a directive that no more than one employee be hired for every four employees that depart. Execution of the Memorandum issued by the Office of Personnel Management pursuant to the Executive Order and outlining guidance and related reporting on the reduction and reorganization plans. |
|
Implementation of the Executive Order, “Ensuring Accountability for all Agencies, which directs all independent agencies to submit for review all proposed and final significant regulatory actions to OIRA within the Executive Office of the President before publishing in the Federal Register. Reported actions and/or statements from the Administration on potential consolidation or elimination of individual agencies (e.g., reducing size and scope, shifting to state authorities, reassessing ability to execute mission). |
| |
Pressure on Global Regulations | Implementation of Executive Memorandums on
| |
Public statements from the Administration at key global events (e.g., Paris AI Summit, Mobile World Congress) urging global/jurisdictional deregulation/ pullback for key areas such as AI and digital services. Withdrawal from global groups (e.g., Paris Climate Agreement, UN Human Rights Council (UNHRC), Network of Central Banks and Supervisors for Greening the Financial System (NGFS), World Health Organization (WHO)). |
|
2. Agency Actions/Direction
Under new leadership and in alignment with Executive Orders/directives, regulatory agencies are shifting their priorities, agendas, regulations/guidance and supervision/enforcement activities. Signals include:
Signals | Description/Examples | Source |
---|---|---|
Modification to/ Withdrawal of Rules/Guidance | Actions to reflect the new Administration’s policies and priorities, including:
| SEC Accounting Bulletin and Legal Bulletin FCC Chairman’s Statements here and here NIH Guidance Treasury Release
|
Potential changes to policies, directives, regulations, and/or orders previously taken pursuant to the rescinded Executive Order 14110 (2023 AI EO) and now deemed in conflict with new AI EO. | White House | |
Withdrawal from Legal Actions
| Determinations to pause, delay, and/or withdraw/dismiss litigation, including:
| SEC Statement |
Redefined Enforcement Focus
| Various amendments to individual agency enforcement activity, including:
|
DOJ Statement FDIC Statement SEC Statement CFTC Advisory Treasury Announcement |
Dive into our thinking:
First 100 Days: Upcoming Regulatory Signals for ‘Deregulation’
Regulatory shifts based on executive/legislative and agency actions/directions
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