First 100 Days - Companies Face Uncertainty Amidst Administration's Deregulatory Push

NEW YORK, April 30, 2025 – The first 100 days of the new Administration have brought significant regulatory shifts, creating both challenges and opportunities for businesses. A new KPMG article, "First 100 Days: Where (De?)Regulation Goes from Here," examines the potential business impacts of these changes, focusing on five key regulatory signals: Regulatory Pullback, Reductions in Regulatory Workforce, Authority of Independent Agencies, Redirection of Regulations, and Resetting of Enforcement.

The Administration has issued more than 200 presidential directives including more than 140 Executive Orders, signaling clear shifts in public policy priorities.  In Congress, scores of recent regulations have been the subject of Congressional Review Act (CRA) disapproval bills but only a few repeals to date have been enacted although others are anticipated as the CRA window is expected to close in a few weeks. Simultaneously, more than 200 legal challenges have been filed against the Administration since January 2025, reflecting the dynamic and contested nature of these regulatory changes.

With regulations being redirected to focus on areas such as cryptocurrency, new challenges and opportunities are presented for innovation and expansion. Challenges include changing risk and compliance risks, slowed approval processes, and increased legal uncertainty. Opportunities include lower compliance costs, increased innovation, and expansion into new business areas.

There is also a reset in enforcement activities, which could create legal uncertainty and, in some instances, serve to increase inherent risk. Further, it is likely that ‘deregulation’ will not take effect as quickly as anticipated and will not impact businesses, even those in the same industry, in the same way – creating a ‘non-level playing field’ within and across industry sectors.

Some enforcement activity is shifting to the states, with State Attorneys General actively stepping in to bolster enforcement. This is the case in a number of key areas such as consumer protection, AI systems safety and privacy, fair labor practices, cybersecurity and data privacy, and securities fraud. State Attorneys General are relying on a combination of existing authorities and newly enacted laws and/or rulemaking initiatives that address the changes in rapidly evolving regulatory areas as well as in areas perceived to have regulatory “gaps” in federal oversight.

"Historic regulatory processes and norms are being challenged, with abrupt and voluminous regulatory shifts adding to business uncertainty,” said Amy Matsuo, Regulatory Insights Leader, KPMG LLP. "The growing regulatory divergence and fragmentation add another layer of complexity to establishing a clear path from strategy and operations to effective risk and compliance. This begs the question – will a deregulatory policy really equate to deregulation? "

Companies must take a proactive approach to compliance and risk management to succeed in the face of ongoing regulatory uncertainty. Remaining agile and adaptive is key to protecting the business from dynamic changes in risks. This includes staying informed about regulatory changes, effectively using data and technology, and ensuring sound risk management and controls.

Despite the introduction of new directives, shifts in enforcement intensity and priority, and the revocation of select rules, it is crucial to emphasize that many existing regulations remain firmly in place. The regulatory landscape may be evolving, but the core obligations and standards that businesses must meet continue to hold significant weight.

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