Project 2025's Authors Wrote Down What They Wanted. Here's What's Happened Since.

“Mandate for Leadership,” Heritage Foundation’s 920-page transition blueprint, spelled out, chapter by chapter, with a named author on each, what a second Trump term should do across the federal government. This piece checks twenty-one of those chapters against the record, plus DOGE, an entity the document never mentions at all, but whose work two of its chapters argued for in theory. Trump disavowed the document as a candidate. Checked against executive orders, court rulings, agency actions, and the document’s own text and contributor list through August 2026, the record so far is neither the wholesale takeover critics describe nor the non-event the campaign claimed.

In this piece

• The short version · How to read this · What it is · The disavowal · Who wrote it, and where they landed
• Personnel power, Schedule F, and the courts · DOGE
• USAID and foreign aid · The State Department beyond USAID
• The Justice Department and the FBI · DHS and immigration enforcement
• The Department of Education
• HHS: reproductive health and gender-affirming care · The rest of HHS: NIH, CDC, vaccines, and Medicaid
• Energy and the EPA · Interior and public lands beyond energy
• Labor policy and the NLRB
• Financial regulation: the CFPB and the Fed · Treasury and the IRS
• The FCC and media policy · The Defense Department · The Intelligence Community
• Commerce, HUD, VA, and SBA
• The bigger picture · Not yet independently verified · Sources

The short version

• Project 2025 is Heritage Foundation’s 920-page policy document, Mandate for Leadership: The Conservative Promise, published April 2023, plus a personnel database and a training program for future appointees. It’s a coalition product. Over 100 conservative organizations signed on, with a named author credited to nearly every chapter.
• Donald Trump said repeatedly during the 2024 campaign that he knew nothing about it and disagreed with parts of it. Heritage said the document didn’t speak for any campaign.
• At least 31 of its named contributors were confirmed to administration jobs as of the last independent count (March 2025). The real number has almost certainly grown since. A handful hold nearly the exact job their own chapter described. Most of the officials actually running the government wrote none of it.
• Where a proposal didn’t need Congress, an executive order, a personnel move, an agency rule, it mostly happened, usually within the administration’s first year.
• Where a proposal did need Congress, abolishing a Cabinet department, abolishing an independent agency by statute, none of that has happened, whatever administrative workarounds have been tried instead.
• Courts, far more than the campaign’s denials, have been the actual variable determining how much survived. A single Supreme Court ruling in June 2026 overturned 90 years of precedent on a president’s power to remove independent agency officials, and that one ruling now runs through half the sections below.
• DOGE isn’t mentioned anywhere in the document’s 920 pages. Several of the record’s most dramatic actions, USAID’s dismantling, the FCC’s use of broadcast-license authority against news organizations, went further than what those specific chapters actually propose. And several of the most consequential actions in other areas, the NIH funding fight, the vaccine-policy overhaul at HHS, trace to no chapter at all; they’re the health secretary’s own initiative.
• USAID is this piece’s starkest case. A peer-reviewed Lancet study credits the agency with preventing roughly 91.8 million deaths since 2001, and projects more than 14 million more by 2030, 4.5 million of them children, if the ~83% cut holds. Every specific public justification offered for the cut, a Russia claim, a Gaza-condoms claim, a “criminal enterprise” characterization, was independently checked and found false. No court has found any legal authority for the shutdown either; the statute that once allowed one expired in 1999.
• One outside, non-neutral tracker (a joint project of two advocacy-aligned research groups) puts the total at 53% of the document’s domestic-policy recommendations completed or already underway, by its own count as of its most recent update. That’s a real number, but from an organization built to oppose the agenda it’s measuring, using a self-disclosed loose definition of a match. No neutral or academic tracker was found to exist.

How to read this

A few terms get thrown around loosely in political conversation, and they mean specific, different things in what follows.

An executive order is a president’s own directive to the agencies he oversees. It can redirect how existing law gets enforced, reorganize things within an agency’s existing legal authority, and set priorities, but it cannot rewrite a statute, create or abolish a Cabinet department, or spend money Congress hasn’t appropriated. Several orders described below say so themselves, acknowledging in their own text that full implementation requires Congress to act.

A rule (or “regulation”) is a more durable, legally binding action an agency takes under authority Congress has already given it, usually after a public comment period. Rules can be sued over, and they generally survive a change in administration, unlike an executive order, which a successor can simply revoke.

“Blocked in court” below almost always means a judge issued a preliminary injunction, an order pausing an action while the underlying lawsuit proceeds, because the challenger has shown a reasonable likelihood of eventually winning. It is not usually a final ruling. Several of the “blocked” items here could still be upheld on appeal; a couple already have been reversed the other way.

The Supreme Court’s emergency (“shadow”) docket, orders on requests to pause or allow a lower-court ruling while a case continues, decided quickly and often without full briefing or a signed opinion, is doing an unusual amount of the load-bearing work in this particular story. Several outcomes attributed to the Supreme Court below are these interim, procedural rulings, not final decisions on the merits of a case. The distinction is noted each time it matters.

What it is

Project 2025, formally the “2025 Presidential Transition Project,” was organized by the Heritage Foundation under its president, Kevin Roberts, as a coalition effort to prepare policy, personnel, and training for a future conservative administration. Heritage counted 60 partner organizations as of May 2023; by July 2024, responding to the controversy described below, it described its coalition as having grown past 110 conservative groups.

The project’s core document, Mandate for Leadership: The Conservative Promise, was published April 21, 2023: 920 pages, with a foreword by Roberts and edited by Paul Dans and Steven Groves. Nearly every substantive chapter carries a named author, mostly Heritage staff and allied policy figures, several of whom turn up again below holding, or conspicuously not holding, government jobs. Heritage has described three companion pieces alongside the document itself: a Presidential Personnel Database of pre-vetted appointee candidates, meant to let a new administration staff itself faster than the normal process allows; an online training program for future political appointees called the Presidential Administration Academy; and a “180-Day Playbook” laying out a new administration’s first six months in office. The Playbook has never, as far as this research could establish, been made public in full, an odd gap for a project this otherwise document-heavy, and one worth watching for.

As of this writing, project2025.org redirects to a new site, mandateforleadership.org, which functions mainly as a promotional page for the book rather than the detailed policy hub the original site was.

The disavowal

On July 5, 2024, Donald Trump posted on Truth Social: “I know nothing about Project 2025. I have no idea who is behind it. I disagree with some of the things they’re saying and some of the things they’re saying are absolutely ridiculous and abysmal.” He added that he had nothing to do with them. Heritage responded the same day, saying the project didn’t speak for any candidate or campaign.

The timing is worth noting. Two or three days earlier, Roberts had told Steve Bannon’s War Room audience that the country was in the midst of a second American Revolution he described as bloodless, so long as the left allowed it to be, a line that drew bipartisan criticism and immediately preceded Trump’s post. Even so, Roberts kept describing overlap between the document and the Trump campaign throughout the fall: in an October 2024 Wall Street Journal interview he pointed to border security, the economy, energy deregulation, and eliminating the Department of Education as areas where he saw the Trump campaign and Project 2025 substantially overlapping, and in a late-November interview he said flatly that Project 2025 policies happening under a second Trump term was not in doubt, citing overlap with Trump’s own campaign platform, Agenda47. (This piece doesn’t attempt to separately untangle Agenda47’s text from the Mandate’s, a real limitation, since Roberts himself leans on that overlap as his defense, and a reader trying to work out how much of what happened traces to Project 2025 specifically versus Trump’s own platform can’t fully do so from what’s here.)

Paul Dans stepped down as the project’s director on July 30, 2024. Coverage at the time framed the departure as a casualty of the campaign’s public criticism; Dans and Roberts, for their part, told reporters the document’s drafting phase had simply reached its planned end. No individual successor director was named; Roberts became the project’s primary public spokesperson. A CNN review published July 11, 2024, before Dans left, found at least 140 people who had worked in Trump’s first administration had a hand in writing the document, including more than half of the Mandate’s named authors and editors, six former Cabinet secretaries, and four future ambassadors. That figure describes who helped write the document during the campaign, not who holds a job in the current administration, a distinction worth holding onto going into the next section.

Heritage’s own institutional footing has been considerably less stable than its public messaging about the document. In October 2025, Roberts released a video defending a Tucker Carlson interview with the white nationalist Nick Fuentes, saying Heritage wouldn’t police the consciences of Christians on the political right; Heritage’s own internal antisemitism task force resigned in protest the following month, Princeton scholar Robert P. George resigned from Heritage’s board citing an unresolved rift with Roberts over the episode, two more board members followed him out in December, and more than a dozen staffers, including much of Heritage’s legal and economic-policy teams, left for a rival think tank founded by former Vice President Mike Pence. None of that bears on whether the document’s specific policy proposals are sound or unsound. It’s a separate fight over Heritage’s posture on antisemitism, included here only because it shows how unsettled the organization actually was behind the confident credit-claiming described above, even as the document it produced kept moving through federal agencies on its own schedule.

Since the inauguration, neither Trump nor the White House appears to have revisited the no-connection claim on the record, one way or the other. Roberts has: on NPR in April 2025, asked about the administration’s first 100 days, he said that if Heritage had played even a small part in supplying some of the ideas and some of the people behind it, the organization was glad to have helped, crediting the American people rather than Heritage directly, but a clear shift from outright denial toward quiet ownership.

Who wrote it, and where they landed

The most recent independent count of Project 2025 contributors serving in the administration comes from Newsweek, which reported in March 2025 that at least 31 named authors, instructors, or advisory-board members, or people affiliated with the associated group America First Legal, had been nominated, designated, or confirmed to administration posts: 7 at the Executive Office of the President, 5 at the State Department, 4 at Defense, and smaller numbers scattered across other agencies. No more recent recount at that same level of specificity was found for this piece. The true number has likely grown since (Paul Atkins, for instance, was sworn in to chair the SEC the following month, after Newsweek’s count closed), and it does not track cleanly onto CNN’s larger, differently-defined 140 figure above. A separate, more targeted count from the nonpartisan fact-checking organization FactCheck.org, roughly eight months into the term, measured something narrower still: of the document’s exactly 40 named chapter authors specifically, 32 had some documented tie, past or current, to a Trump administration or campaign. That’s the tightest, most precise of the three figures in circulation, and the most damaging to any claim of pure coincidence, precisely because it’s scoped to only the people who actually put their names on a chapter.

Individual cases resist a single clean story. Some are near-exact matches: Russ Vought, who wrote the Mandate’s chapter on the Executive Office of the President, was confirmed as OMB Director in February 2025 and later doubled as the Consumer Financial Protection Bureau’s acting director, and, as the DOGE section below describes, became the person most responsible for institutionalizing that effort’s functions after its original leadership left. Brendan Carr, author of the FCC chapter, has chaired that commission since Inauguration Day, and Adam Candeub, who wrote the companion FTC chapter, became the FCC’s general counsel in 2025 and was nominated in mid-2026 to lead the Justice Department’s Antitrust Division. Lindsey Burke, who wrote the Department of Education chapter, became that department’s Deputy Chief of Staff for Policy in June 2025, while the Senate-confirmed Secretary actually running the department, Linda McMahon, told senators during her confirmation hearing that she wasn’t aware of the document’s proposals on higher education specifically. Gene Hamilton, author of the Justice Department chapter, served as Deputy White House Counsel for roughly five months in 2025 before returning to lead the advocacy group America First Legal. Paul Winfree, who wrote the Federal Reserve chapter, was hired in June 2026 as an adviser to Fed Chair Kevin Warsh, a real link, though an advisory one, not a Board seat.

Others are absent entirely. Ken Cuccinelli (DHS), Mandy Gunasekara (EPA), Bernard McNamee (Energy), Roger Severino (HHS), Max Primorac (USAID, see below), Kiron Skinner (State), William Perry Pendley (Interior), Christopher Miller (Defense), Dustin Carmack (Intelligence Community), Thomas Gilman (Commerce), Brooks Tucker (Veterans Affairs), Karen Kerrigan (SBA), and William Walton, Stephen Moore, and David Burton (the three named authors of the Treasury chapter) hold no confirmed role in the second administration, and neither does Donald Devine, co-author with Dans of the civil-service chapter. A genuinely distinct fourth case is Ben Carson, author of the HUD chapter, who does hold a federal post, as a nutrition advisor at the Department of Agriculture, a role with no connection to the department he actually wrote about. Gunasekara has told reporters she doesn’t want to return to EPA, and Dans ran for a U.S. Senate seat in South Carolina instead (he withdrew from that race in April 2026). Some of the people actually running these agencies, Tom Homan, Kristi Noem and her successor Markwayne Mullin at DHS, EPA Administrator Lee Zeldin, Energy Secretary Chris Wright, Attorney General Pam Bondi, FBI Director Kash Patel, never wrote a line of the document at all, whatever trade press covering their agencies says about how closely their actions track it. Homan and CIA Director John Ratcliffe are both listed only in the document’s front-matter contributor roster, not as chapter authors; the Intelligence Community chapter was actually written by Ratcliffe’s former chief of staff, Dustin Carmack.

One case is worth flagging for the opposite reason. Stephen Miller, now the White House’s deputy chief of staff for policy, has publicly denied any involvement beyond recording an unrelated advice video for students. A full-text search of all 920 pages of the document turns up his name nowhere: the rare case where an insider’s denial is corroborated, rather than complicated, by the primary source.

Personnel power, Schedule F, and the courts

The civil-service chapter, Chapter 3, “Central Personnel Agencies,” written by Donald Devine, Dennis Dean Kirk, and Paul Dans, is built on a premise stated plainly in its opening pages: that who holds a job matters as much as what the policy says. Its central proposal is reviving and expanding “Schedule F,” a reclassification tool from Trump’s first term that moves federal positions out of the “competitive service,” where an employee can normally only be fired for cause through a formal process with appeal rights, and into an “excepted service” category where they can be removed at will, the way a political appointee can. The chapter treats the first Trump term’s version as merely an opening move, arguing for going considerably further. A separate chapter, Chapter 2, “Executive Office of the President,” written by Vought, argues for a broader theory sometimes called the unitary executive: the idea that all executive power is constitutionally vested in the president alone, so agencies Congress tried to insulate from direct presidential control, especially multi-member commissions with fixed terms and for-cause removal protections, rest on shakier constitutional ground than a century of practice assumed.

On his first day back in office, Trump signed an executive order reviving Schedule F under a new name, “Schedule Policy/Career,” and revoking the Biden administration’s order that had undone it. A companion order weeks later subjected independent regulatory agencies to White House budget and policy review for the first time, giving OMB new leverage over their spending and requiring them to accept a White House liaison. That same night in January, 17 inspectors general, the internal watchdogs stationed inside federal agencies specifically to operate somewhat independently of the officials they oversee, were fired by identical two-sentence email, without the 30 days’ notice to Congress a federal statute requires. A federal judge found the firings likely unlawful eight months later but declined to reinstate anyone, reasoning the administration could simply re-fire them properly the second time. When OPM finalized the actual reclassification rule in February 2026, it estimated as many as 50,000 positions could convert; the executive order that implemented it in June 2026 moved about 8,000, nearly all of them senior career officials, a fraction of the original estimate. Multiple union lawsuits over the reclassification remain unresolved. That same broader push toward centralized, at-will control over the federal workforce is also what produced DOGE, covered in its own section just below.

The single biggest legal shift arrived on June 29, 2026, when the Supreme Court, in Trump v. Slaughter, overruled Humphrey’s Executor v. United States, a 1935 precedent that had let Congress protect some agency heads from being fired without cause, by a 6–3 vote, finding that a Federal Trade Commissioner exercising this much executive power could be removed at will regardless of the statutory protection Congress wrote. That ruling is the connective tissue running through several sections below. It’s what let an earlier firing of an NLRB member stand, and it’s the theory the administration is now testing again against a sitting Federal Reserve governor.

DOGE: the entity the document never mentions

Search all 920 pages of the Mandate and neither “DOGE” nor “Department of Government Efficiency” appears anywhere: the idea simply didn’t exist yet. The document was published in April 2023; Trump and Elon Musk didn’t float the concept until an August 2024 livestream, and Trump didn’t formally announce the idea until a September 5, 2024 speech pitching a commission to audit federal spending, with the DOGE name and Musk’s and Vivek Ramaswamy’s co-leadership announced only after the election, on November 12, 2024.

What the document does contain is the theory DOGE later ran with. Vought’s chapter argues for centralized OMB control over agencies. The civil-service chapter argues, as noted above, that the original Schedule F push hadn’t gone nearly far enough. DOGE became the vehicle that acted on both ideas, using tactics its own intellectual ancestors never specified and, in the text itself, never named. That distinction matters: “DOGE implements an idea Project 2025’s authors argued for” is a defensible claim; “Project 2025 proposed DOGE” is not.

Legally, DOGE was never created as a new department; only Congress can do that. The executive order Trump signed on Inauguration Day instead renamed an existing Obama-era office, the U.S. Digital Service (created in 2014 to modernize federal technology), as the “U.S. DOGE Service,” moved it out of OMB and directly into the White House, and created within it a “Temporary Organization” with an explicit sunset date: July 4, 2026, eighteen months out. Every federal agency was ordered to stand up its own four-person DOGE team, a lead, an engineer, an HR specialist, and a lawyer, with a mandate giving that team sweeping, immediate access to the agency’s own unclassified records and computer systems. A second order, weeks later, directed agencies to prepare large-scale workforce reductions and capped new hiring at one hire for every four departures.

Musk himself never held the title of DOGE’s administrator; that went to Amy Gleason, a former USDS staffer. Musk was instead designated a “special government employee,” a status capped at 130 days of service in any 365-day period, and the White House’s consistent answer whenever his authority was challenged was that he was merely a senior adviser overseeing DOGE, not an officer of the United States. Ramaswamy left the arrangement on Inauguration Day itself, before DOGE had any legal form, to run for governor of Ohio.

That ambiguity over Musk’s actual authority became legally central. On March 18, 2025, a federal judge ruled, in a suit brought by USAID employees and contractors, that Musk’s role likely violated the Constitution’s Appointments Clause, the provision requiring that anyone exercising significant federal authority (“officers of the United States”) be nominated by the president and confirmed by the Senate, precisely so that power isn’t wielded by people accountable to no one but the president personally. The judge ordered USAID’s computer systems access restored; the administration said it would appeal, and no final ruling has been confirmed since. Two other fights over DOGE staff accessing sensitive government data systems produced only interim outcomes rather than a final answer on legality: a federal judge blocked, then herself lifted, DOGE’s access to Treasury’s payment infrastructure after the administration demonstrated adequate staff vetting; a parallel dispute over Social Security data reached the Supreme Court, which let the access continue on procedural grounds in June 2025 without ruling on whether it was actually lawful, and a lower court’s injunction against it was vacated on similar reasoning nearly a year later. A separate lawsuit arguing DOGE was functioning as an improperly unregistered federal advisory committee was largely abandoned by its own plaintiffs once DOGE’s formal structure shifted in ways that undercut the theory.

Musk left in May 2025, announcing it himself and framing it as his 130-day term simply expiring, a claim that landed only a day after his first public break with Trump, in which he denounced the tax-and-spending package then moving through Congress in unusually harsh terms and warned it would undercut everything DOGE had been doing. The feud escalated through the summer; Trump at one point suggested publicly that DOGE could eventually turn on Musk the same way it had gone after federal agencies. By November 2025, OPM’s director told Reuters that DOGE no longer functioned as a centralized entity at all: its functions had been quietly folded into OMB, run by Vought, months ahead of its already-scheduled sunset, which then arrived on time in July 2026.

What DOGE actually produced is now the subject of an unusually pointed factual dispute, not just a political one. Its own website claims $215 billion in total savings, a figure the administration has also framed as working out to roughly $1,335 for every taxpayer. The Government Accountability Office, Congress’s own nonpartisan auditor, examined the largest chunk of that figure, the roughly $110 billion attributed to contract, grant, and lease terminations, and published a report this August finding those estimates inaccurate or inadequately documented, with 96 percent of the claimed grant savings impossible to verify from the supporting records DOGE provided. A parallel GAO finding on office-lease terminations specifically discovered that more than a third of the leases DOGE counted toward its savings were already scheduled for termination before DOGE existed, and that a claimed $400 million in lease savings had to be revised down to roughly $53.5 million once those were removed from the count; the General Services Administration’s own final tally for the fiscal year was about $112 million a year saved from 260 completed terminations, real money, but a small fraction of what DOGE had publicly claimed. Vought has since told a House Appropriations hearing there are no plans to produce any closing report on what DOGE actually accomplished, and no successor entity has taken its place; DOGE’s own acting administrator, Amy Gleason, moved into an unrelated technology role at the Centers for Medicare and Medicaid Services. None of the Schedule F chapter’s three named authors, Devine, Kirk, or Dans, ever held a DOGE staff role, as far as this research could determine; DOGE’s own operatives and Project 2025’s named contributors turn out to be two largely separate rosters, with Vought as the one substantiated bridge between them.

USAID and foreign aid

The Mandate’s chapter on USAID, Chapter 9, written by Max Primorac, a former acting chief operating officer at the agency, does not call for eliminating USAID outright, a common assumption worth correcting directly. It proposes instead elevating the USAID Administrator into a new, deputy-secretary-level Director of Foreign Assistance post inside the State Department, meant to fix what it describes as foreign-aid spending scattered across roughly twenty different federal offices; stripping out the agency’s abortion, climate-change, and gender-equity programming; scaling its budget and footprint back toward roughly 2019 levels; steering more funding toward faith-based organizations and toward local partners in recipient countries; and taking a more confrontational posture toward Chinese influence in the developing world. What actually happened in 2025 went further and faster than that text.

Within days of the inauguration, the administration ordered a 90-day pause on foreign development assistance, followed by an 85-day, government-wide stop-work order from Secretary of State Marco Rubio. By February 3, 2025, USAID’s Washington headquarters was closed to its own staff and its sign taken down; Elon Musk, leading the effort through DOGE, described the shutdown on social media in terms suggesting the agency had been run through a wood chipper over the weekend. Nearly all direct-hire personnel worldwide were placed on administrative leave within three weeks. On March 10, Rubio announced that 83 percent of the agency’s programs, more than 5,000 individual contracts, were being cancelled outright, with the remaining fraction folded into the State Department; the same actions produced the Appointments Clause ruling described in the DOGE section above, since the judge in that case found DOGE and Musk chiefly responsible for the rushed shutdown. By July 1, 2025, USAID had formally ceased implementing any foreign assistance at all. Its pre-2025 workforce of just over 10,000 employees has been replaced by a new State Department bureau, the Bureau of Disaster and Humanitarian Response, formally stood up in March 2026, planned at roughly 232 total positions: a cut of about 98 percent. Customs and Border Protection took over USAID’s old headquarters lease; the FBI has separately announced plans to move its own headquarters into the same vacated space.

None of this happened through Congress, and that’s a live legal problem, not a settled one. USAID was created as an “independent establishment” under a 1998 statute, the Foreign Affairs Reform and Restructuring Act, and the specific presidential authority that law granted to reorganize or abolish federal foreign-affairs agencies expired in 1999, meaning no current unilateral executive authority to dissolve USAID actually exists on the books. Multiple bills to formally abolish the agency by statute remain stuck in committee, as does a competing bill that would require congressional approval before any such move. The administration itself formally notified Congress in March 2025 only that it intended to reorganize, alongside a stated plan to eventually seek abolishing legislation, legislation that, as of this writing, has never been introduced by the administration or passed. That gap between what happened and what Congress ever authorized is exactly what’s being litigated: a federal judge ruled in March 2025 that the shutdown likely lacked any statutory basis, before the Fourth Circuit paused that ruling and let the dismantling continue while the underlying appeal plays out. That court’s only other substantive action since was procedural rather than a ruling on the merits, a March 2026 order shielding Musk from being deposed, reasoning the record suggested he’d acted as a presidential adviser rather than a Senate-confirmable officer, and the constitutional question itself remains open at the appellate level nearly a year and a half later.

A separate legal fight reached the Supreme Court over money already owed rather than the shutdown’s legality: whether the government had to actually pay out foreign-aid funds Congress had already appropriated and contracted for. A district judge ordered the funds released; the administration sought an emergency stay; Chief Justice Roberts briefly paused the release himself hours before a compliance deadline, and then the full Court, in March 2025, denied the administration’s stay request over four justices’ dissent, forcing the funds out. A related fight over billions more in a disputed “pocket rescission,” a maneuver for effectively cancelling appropriated funds by running out the clock on the fiscal year rather than getting Congress to formally rescind them, produced a second Supreme Court intervention in September 2025 that paused part of a lower court’s order pending further appeal. That dispute remains unresolved as of this writing.

The one piece of this story Congress actually did legislate is narrower than most coverage suggests: the Rescissions Act of 2025, signed into law in July 2025, formally clawed back $9 billion already appropriated for foreign aid and public broadcasting combined, $7.9 billion of that specifically foreign assistance. Notably, a proposed $400 million cut specifically to PEPFAR, the two-decade-old global HIV/AIDS treatment program, was stripped out by a Senate amendment before the bill passed; PEPFAR has continued receiving its own appropriation since, though under a narrowed waiver limiting what it can fund and amid reporting that a substantial share of that money has struggled to actually reach providers on the ground. Separately, the administration cut off all U.S. funding to the UNFPA, the United Nations’ population and reproductive-health agency, entirely.

The administration’s specific waste and fraud claims about USAID have not held up well to scrutiny. OMB Director Vought told the Senate that the rescission targeted, among other things, over $9 million to advise Russian doctors on performing abortions; reporters noted USAID has not operated inside Russia at all since Putin expelled the agency in 2012, plus tens of millions more for vasectomy messaging in Ethiopia and funding he linked to sex trafficking in Nepal, none of it documented when reporters asked. Separately, a widely repeated claim that USAID had spent $50 million on condoms for Hamas in Gaza was rated false by two networks’ fact-checkers: the agency funded zero condoms anywhere in the Middle East in the three fiscal years before the claim was made. Musk’s own characterization of USAID as a criminal enterprise engaged in money laundering was found by an independent fact-checking organization to have no supporting evidence, and a former USAID Inspector General told reporters that fraud, waste, and abuse at the agency were not unusually widespread relative to other federal agencies of comparable size.

The humanitarian stakes of the actual cuts, as distinct from the waste claims, are the subject of serious peer-reviewed research rather than advocacy assertion. A study published in The Lancet estimated that USAID’s programs helped prevent roughly 91.8 million deaths worldwide between 2001 and 2021, 30.4 million of them children under five, largely through reductions in HIV/AIDS, malaria, and neglected tropical disease mortality, and projected more than 14 million additional deaths by 2030, including 4.5 million children, if the current roughly 83-percent funding cut holds. On PEPFAR specifically, an industry-tracking organization documented more than 1,700 HIV treatment sites closed, and separate modeling published in a peer-reviewed journal projects tens of thousands of excess HIV deaths in Africa by 2030 if disrupted funding isn’t restored; UNAIDS has separately warned of several million additional HIV infections and deaths by the end of the decade under a permanent-cuts scenario. These are modeled projections from named researchers working off the same funding data driving this fight, not confirmed body counts, a distinction worth holding onto even as the numbers involved are large.

The pattern here is worth stating plainly. Every specific public justification offered for the cuts has been checked and found false: the Russia claim describes work in a country USAID left in 2012; the Gaza-condoms claim was rated false, since the agency funded zero condoms anywhere in the Middle East in the years checked; Musk’s “criminal enterprise” characterization was found by an independent fact-checker to have no supporting evidence. No court has found any legal authority for the shutdown either. The statute that once let a president do this unilaterally expired in 1999. What was dismantled anyway, on those grounds, is a program a peer-reviewed Lancet study credits with preventing roughly 91.8 million deaths since 2001, and projects will cost more than 14 million more, 4.5 million of them children, by 2030 if the cut holds. Whatever the intent, the effect is measurable: a program with a documented record of saving lives at global scale, dismantled on public justifications independently found false, while the foreseeable, quantified human cost has gone unaddressed.

Neither of the chapter’s own credited authors, Primorac or Kiron Skinner, who wrote the broader State Department chapter, holds a matching government role today; Primorac remains a Heritage Foundation fellow who testified as an outside witness during the shutdown, and Skinner has reportedly taken on a broader advisory role at Heritage rather than any confirmed federal appointment. The person who most fits a helped-tear-it-down-then-got-the-job story is someone else entirely: Jeremy Lewin, a DOGE staffer who helped engineer USAID’s dismantling from the inside, became the State Department’s acting head of foreign assistance in July 2025, functionally landing in the office Primorac’s own chapter had proposed subordinating USAID under, and then moved to a senior National Security Council role in mid-2026. Lewin was never a Mandate author. The clearest personnel match in this entire story belongs to someone the document never credited with anything.

The State Department beyond USAID

A separate, broader State Department chapter, credited to Kiron Skinner, though at least one source lists a second contributor and this research couldn’t fully resolve that ambiguity, argues that much of the career Foreign Service is institutionally resistant to a conservative president’s agenda, and proposes expanding political-appointee authority, having every ambassador submit a resignation letter on day one for loyalty review, and prioritizing politically connected nominees for the most prominent postings. It calls for treating China adversarially, reconsidering NATO and international-organization commitments, freezing climate-treaty negotiations, and shifting the department’s human-rights framework away from the Universal Declaration of Human Rights toward one emphasizing religious freedom over LGBTQ-rights advocacy.

Secretary Marco Rubio’s reorganization, announced in April 2025, cut the department from 734 to 602 bureaus and offices, eliminated roughly 700 Washington-based positions, and closed or consolidated more than 100 overseas posts. It eliminated the department’s single most senior human-rights-dedicated position, folded the human-rights bureau into a renamed office, and shut down the units handling global women’s issues, global criminal justice, and international climate negotiations. A Supreme Court ruling that July lifted a district-court injunction against the reorganization, clearing the way for mass layoffs; a second wave tied to that fall’s government shutdown was later partly reversed by a separate court order. By the Foreign Service’s own professional association’s count, roughly a quarter of its members, an estimated 2,000 people, had resigned, retired, been dismissed, or seen their post eliminated by the end of 2025. That December, the administration recalled roughly 30 career diplomats from ambassadorial and senior posts, concentrated in Africa and Asia; the association called it a signal that political loyalty now outweighs tenure. A narrowed human-rights report released that August dropped sections on fair-trial rights, discrimination, and LGBTQ-specific abuses, drawing criticism from Human Rights Watch.

Skinner herself holds no confirmed role in the current administration; she remains affiliated with Pepperdine, Heritage, and the Hoover Institution. Rubio, who never wrote any part of the document, has explicitly and repeatedly distanced himself from it, dismissing Project 2025 in one 2024 interview as the kind of thing think tanks do, coming up with ideas, without treating it as binding on any campaign, even as reporting has separately noted Heritage briefed the Rubio campaign, among others, during the document’s development.

Critics of the reorganization include a group of more than 300 former national security officials who called the mass firings an act of sabotage against national security, and more than 130 former senior officials, including a past national security adviser, who wrote that gutting the department’s institutional knowledge was reckless. Rubio’s own framing has centered on ending what he’s called a bloated bureaucracy that stifles innovation, and, regarding the human-rights bureau specifically, an office he said had become a platform for activists to target foreign leaders it disfavored.

The Justice Department and the FBI

Gene Hamilton’s Justice Department chapter, read directly from the primary document rather than a secondhand summary, proposes moving the FBI out from under the Deputy Attorney General’s direct supervision via internal reorganization (something that, unlike creating a new agency, doesn’t require Congress), eliminating the FBI Director’s fixed 10-year term by statute, folding several of the FBI’s own headquarters offices into DOJ’s, and having the Civil Rights Division spend its first year investigating DEI programs as unlawful discrimination. The chapter frames all of this as restoring the department’s independence and impartiality, not ending them; critics reading the same text call it the opposite. The clearer textual hook for what critics usually mean by ending DOJ’s independence from the White House actually sits in a different chapter, Vought’s, which proposes reexamining a post-Watergate norm, formalized in an internal DOJ/White House memo, that restricts contact between the White House and the Justice Department on pending investigations to a small number of designated officials on each side, specifically to keep a president from directing individual prosecutions.

Whether the FBI has actually been moved out of the Deputy AG’s chain of command, as the chapter proposes, could not be confirmed either way. What is well documented is a pattern of specific prosecutions moving under visible White House pressure. In February 2025, department leadership ordered New York prosecutors to drop the corruption case against Mayor Eric Adams, in an arrangement internal correspondence later tied to his cooperation on immigration enforcement; seven prosecutors, including the U.S. Attorney herself, resigned rather than sign the dismissal motion. The judge who eventually dismissed the case did so “with prejudice,” meaning it can never be refiled, a stronger outcome than the “without prejudice” dismissal DOJ had actually requested, which would have left the charges available to bring back later as leverage, over the department’s objection, in a ruling that described the arrangement as functioning like a deal trading dismissal for the mayor’s cooperation.

In September 2025, after a federal prosecutor recommended against charging former FBI Director James Comey, the administration installed Trump’s own former personal attorney, Lindsey Halligan, as interim U.S. Attorney; days earlier, Trump had, by his own aides’ account, accidentally publicly posted on Truth Social demanding Bondi prosecute Comey, Adam Schiff, and New York Attorney General Letitia James. Comey and James were both indicted within weeks. In November, it emerged that the full grand jury had never actually seen the final version of Comey’s indictment, and a federal judge threw out both cases entirely, ruling that Halligan’s own appointment had been unlawful: federal law caps how long an interim U.S. Attorney can serve without either Senate confirmation or a judicial appointment, a limit intended to prevent exactly this kind of installation of a hand-picked prosecutor outside the normal process, and the judge found Halligan’s tenure had run past it. That ruling is now on appeal to the Fourth Circuit, with oral argument scheduled for September 15, 2026; two separate grand juries have since declined to reindict James, and a prosecutor was fired in January 2026 for refusing to lead a renewed push against Comey. A parallel case against former national security adviser John Bolton, indicted in October 2025 on 18 Espionage Act counts over classified material found in his personal notes, moved through ordinary channels without any of the irregular firings or hand-picked appointments seen in the other two, and ended in a guilty plea to a reduced set of charges around mid-2026.

Away from individual cases: roughly 70 percent of Civil Rights Division attorneys left within four months of new leadership taking over, concentrated in the education, voting-rights, and police-practices sections; the department dropped long-running police-reform consent decrees, court-supervised agreements requiring specific reforms, in Minneapolis and Louisville, over the objection of both cities’ mayors; and about 40 DOJ attorneys who had worked on January 6th prosecutions were fired by a single memo.

DHS and immigration enforcement

The DHS chapter, credited to Ken Cuccinelli, though this rests on outlets’ consistent secondary characterization rather than a verified read of the primary text, calls for consolidating CBP, ICE, and USCIS into one new agency, expanding workplace raids and mandatory E-Verify, making immigration detention mandatory rather than discretionary, restricting asylum eligibility, and ending the Flores settlement, a 1997 court-supervised agreement setting minimum standards for how long and under what conditions migrant children can be detained. One thing worth correcting up front: a direct textual analysis by the American Immigration Council found no specific numeric deportation target anywhere in the document itself. The figures in the millions per year that circulated later came from campaign and administration officials, not from the Mandate’s text.

Day-one orders expanded “expedited removal,” a fast-track deportation process that skips a full immigration-court hearing for certain recent arrivals, cut funding to sanctuary jurisdictions (an injunction protecting roughly 70 jurisdictions, including San Francisco and Santa Clara County, was largely upheld by the Ninth Circuit in August 2026), shut down the CBP One app that had scheduled asylum appointments, and reinstated the first-term “Remain in Mexico” policy. A separate order ending birthright citizenship for children of undocumented parents was struck down by the Supreme Court, 6–3, in June 2026, one of the few threads in this entire piece with a fully final resolution rather than an ongoing fight. Deportations rose substantially over the prior administration’s pace: the independent Migration Policy Institute estimated roughly 340,000 removals in fiscal 2025, up about 25 percent from roughly 271,000 the year before, though that independent estimate runs well below the 400,000-plus figure the administration itself publicized for a comparable period, and analysts have separately questioned whether administration totals cleanly distinguish forced removals from self-deportations. Congress’s mid-2025 budget package appropriated $45 billion for detention capacity, targeting roughly 100,000 average daily detention beds, and funding for 10,000 additional ICE officers over five years. Local police deputization agreements under the “287(g)” program, which lets state and local officers carry out federal immigration enforcement functions, grew from about 135 agreements in January 2025 to more than 2,300 across 39 states by August 2026.

The proposed single consolidated border agency does not appear to have been formally pursued, and the Flores settlement remains in effect after the administration’s attempt to terminate it was denied in court and remains under Ninth Circuit appeal, argued in June 2026 and undecided as of this writing, though family detention has expanded in practice regardless: reporting found several hundred children held well past the settlement’s intended limits. Two new state-run detention facilities drew particular attention: Florida’s “Alligator Alcatraz,” opened in the Everglades in July 2025 at roughly $450 million a year to run, was later closed, with the governor’s office describing it as always intended as temporary; a second facility in Baker County, Florida, opened weeks later.

National Guard troops, deployed under a state-controlled legal authority known as Title 32, which keeps them under governors’ operational control even while federally funded, supported ICE logistics in numerous states. Separate deployments that instead federalized Guard units under Title 10 authority, over the objections of the states’ own governors, in Los Angeles, Illinois, and Portland, were each blocked by courts; the distinction matters because federalizing the Guard this way runs up against the Posse Comitatus Act, an 1878 law generally barring the use of military force for domestic civilian law enforcement. The Supreme Court itself declined, 6–3, to lift the injunction against the Illinois deployment. The Alien Enemies Act, an 18th-century wartime statute, was invoked in March 2025 to deport alleged members of the Venezuelan gang Tren de Aragua without individual hearings; the Supreme Court allowed removals to proceed but required individual habeas petitions rather than blanket treatment, and a later appellate ruling found the gang didn’t actually meet the statute’s own “invasion” standard, cutting off further use of the law against that group. One deportation under a similar posture, of Kilmar Abrego Garcia, was later conceded by DOJ itself to have been a mistake that violated a standing court order protecting him from removal; he was eventually returned to the U.S. to face separate criminal charges, which were later dismissed. ICE detention deaths reached their highest level in more than two decades, and the administration’s own claim that roughly 70 percent of ICE arrestees have criminal records has been disputed by independent trackers finding a much lower share of the currently detained population has any conviction at all, a discrepancy the administration attributes to measuring arrestees rather than detainees, which critics say doesn’t fully resolve the gap.

The Department of Education

Lindsey Burke’s chapter opens, in language multiple outlets quote directly, by calling for the Department of Education to be eliminated outright. Because Congress, not the president, created the department by statute in 1979, only Congress can formally abolish it. A president’s executive order can redirect what the department does and how aggressively it does it, but can’t erase the agency itself. The order Trump signed in March 2025 acknowledges exactly this limit in its own text, directing the Secretary to facilitate closure only to the extent current law actually allows. Three bills to formally abolish the department remain stuck in committee.

Short of abolition, the administration cut roughly half the department’s staff (upheld for now by a 6–3 Supreme Court stay in July 2025, pending further litigation over whether the cuts themselves were lawful) and has spent the past year and a half parceling out its programs through a growing set of interagency agreements, a mechanism, authorized by a law called the Economy Act, that lets one agency pay another to take over a function without needing new legislation, as long as some existing statutory basis supports the transfer. Career and technical education and most K-12 programs, including Title I funding for low-income schools, moved to the Labor Department; several K-12 grant and school-safety programs moved to HHS; foreign-gift tracking for universities moved to State. Announced in June 2026, and considerably more contested, are proposals to move special-education oversight under the Individuals with Disabilities Education Act to HHS and civil-rights enforcement to the Justice Department. The IDEA move drew a pledge from Republican Senator Bill Cassidy to force a vote against it, alongside opposition from every Senate Democrat, on the theory that housing disability-education oversight inside a health agency treats students as patients rather than learners. A separate plan to move the $1.7 trillion student loan portfolio to the Small Business Administration was blocked in court and abandoned in favor of routing it through the Treasury Department instead. The department still exists as a legal matter, and its Office for Civil Rights, its case backlog already above 12,000 before the cuts, now operates with roughly half its prior staff across half as many regional offices.

HHS: reproductive health and gender-affirming care

Roger Severino’s chapter calls for DOJ to enforce the Comstock Act, an 1873 federal law, never formally repealed but effectively dormant for decades, that criminalizes mailing “obscene” materials and anything intended for producing an abortion, against mailed abortion medication; for the FDA to reconsider mifepristone’s approval outright or, short of that, reimpose a stricter REMS (Risk Evaluation and Mitigation Strategy, the FDA’s framework for extra restrictions on drugs with particular safety concerns) requiring in-person dispensing rather than mail delivery; for Title X family-planning funding to move away from providers that refer for abortion; and for ending federal funding for gender-affirming care for minors.

As of this writing, the Justice Department has not reversed a 2022 legal opinion allowing the mailing of abortion medication; a coalition of anti-abortion groups petitioned the newly confirmed attorney general to do so in August 2026 and received only a promise to review it. The FDA opened a mifepristone safety review in September 2025 without reaching a decision by mid-2026; a court order that would have forced a return to in-person dispensing was put on hold by the Supreme Court in May 2026 pending further appeal, with oral argument and an FDA report both due in the coming weeks. No Title X funding rule has been finalized, and HHS’s own decision this spring to keep funding Planned Parenthood-affiliated Title X grantees drew public criticism from the head of the anti-abortion group SBA Pro-Life America, who described the decision as a betrayal of the administration’s own base, a useful reminder that the administration doing what Project 2025 wanted isn’t true of every domain, even by the standards of the document’s own allies.

Several other reproductive-health actions fall outside the Comstock/mifepristone/Title X fights above but belong in the same ledger. DOJ pardoned 23 people convicted under the FACE Act, the federal law making it a crime to block or threaten people entering a reproductive-health clinic, and moved to stop enforcing that law altogether. In June 2025, HHS and CMS rescinded 2022 guidance that had told hospitals federal law required them to provide emergency abortion care regardless of state bans; the same month, in separate litigation, a federal judge in Texas vacated a rule that had shielded reproductive-health records from law-enforcement requests.

On gender-affirming care, day-one executive orders set a funding-conditions strategy in motion that produced, among other things, an HHS “evidence review” explicitly breaking from the positions of major U.S. medical associations, and, finalized in August 2026, effective that October, a rule barring federal Medicaid and CHIP funds from covering gender-affirming care for minors. A separate rule stripping the same category of care from the Affordable Care Act’s required list of Essential Health Benefits (the categories of care ACA-compliant insurance plans must cover) was struck down that same month over a technical defect: HHS had skipped a legally required certification from the government’s own chief actuary before finalizing it. A different court, in a separate case, also struck down the administration’s attempt to reinstate broad religious and moral exemptions to the ACA’s contraceptive-coverage mandate, finding the agencies hadn’t adequately explained the reversal. Multiple other pieces of the gender-affirming-care agenda remain blocked by injunctions in various circuits. None of the officials actually running HHS, the FDA, or CMS wrote the chapter driving any of this.

The rest of HHS: NIH, CDC, vaccines, and Medicaid

Roger Severino’s HHS chapter, the same chapter behind the reproductive-health and gender-affirming-care proposals above, also calls for term limits on NIH leadership, eliminating the private foundation that raises money for NIH, splitting the CDC into two separate agencies (one for data, one for public-health recommendations), eliminating the CDC’s own private foundation, and converting Medicaid into a block grant or per-person spending cap paired with work requirements. Notably absent from the chapter’s own text: anything about the rate research universities can charge to cover overhead costs on federal grants, anything about the CDC’s vaccine advisory committee specifically, and anything resembling the administration’s actual 2025 marketplace-insurance rule. That gap matters, because the single biggest, most consequential fights in this part of HHS since 2025 turn out to have no clear textual root in the document at all.

NIH capped reimbursement for research overhead at 15 percent, down from a historical average around 27 to 28 percent, in February 2025; twenty-two state attorneys general and university associations sued within days, a federal judge permanently blocked the cap that April, and a federal appeals court unanimously upheld that ruling in January 2026. The administration let its window to appeal further lapse, ending the fight with the cap dead, helped along by a congressional appropriations rider, renewed every year since 2018 including by Republican-controlled Congresses, that separately bars any such rate change regardless of what any administration wants. Separately, NIH terminated grants tied to disfavored topics, DEI, gender-identity research, vaccine hesitancy, COVID-19 research, with tracked totals ranging from roughly $1.8 billion to $2.45 billion depending on the count; a federal judge found the terminations arbitrary, unsupported, and discriminatory, calling the evidence of bias in that record as clear as anything he’d seen on the bench. A Supreme Court ruling on its emergency docket let already-cancelled grants stay cancelled procedurally even while leaving standing the underlying finding that the guidance behind them was unlawful, a split outcome, with that underlying finding now before the First Circuit as well, argued in January 2026 and undecided as of this writing.

CDC lost roughly a fifth of its workforce as part of a department-wide restructuring that cut HHS overall from about 82,000 employees to about 62,000 and folded several health agencies into a new umbrella agency, a different shape than what Severino’s chapter proposed, and dwarfed in significance by what happened to vaccine policy specifically, an entire thread that traces to HHS Secretary Robert F. Kennedy Jr.’s own initiative, not to Project 2025’s text. Kennedy fired all 17 sitting members of the CDC’s vaccine advisory committee in June 2025, replaced them with a smaller panel that included several vaccine skeptics, and by early 2026 that reconstituted committee had voted to drop a longstanding newborn hepatitis-B vaccination recommendation while HHS issued a substantially revised childhood immunization schedule. A federal judge blocked nearly the entire sequence that March, finding it likely violated federal rulemaking law, and ordered the schedule, the committee’s membership, and its votes all reverted to where they stood before Kennedy’s changes began, an order now on appeal to the First Circuit, which HHS has asked to expedite ahead of the fall respiratory-virus season; no ruling had issued as of this writing. Along the way, the FDA’s top vaccine regulator resigned citing what he called an assault on scientific truth, a newly confirmed CDC director was fired within a month of her own confirmation after refusing to pre-commit to accepting the committee’s recommendations, and four of the CDC’s own senior scientists resigned in protest within days of each other. The agency went without a permanent director for nearly a year afterward; the Senate confirmed a successor, Dr. Erica Schwartz, on August 5, 2026. The American Academy of Pediatrics broke from the CDC entirely, publishing its own competing vaccine schedule for the first time in decades, one that a dozen other medical organizations and more than two dozen states have since adopted instead of the government’s own.

Medicaid work requirements are the one place in this whole section where the document’s text and the actual policy line up cleanly: a July 2025 budget law imposed an 80-hour-a-month work requirement on many adult Medicaid recipients, projected by the Congressional Budget Office to leave millions more people uninsured, with implementation being litigated by two dozen states over how narrowly the law defines who’s exempt. Even there, work requirements are a decades-old mainstream conservative position that predates this document by years, not something distinctively traceable to it.

Kennedy has no documented connection to Project 2025; he isn’t listed among its authors or contributors, has said Trump told him he’d never read the document, and has himself disparaged its author in conversations with reporters. Severino, for his part, holds no role in the current administration and has no documented personal connection to any of the fights described above.

Energy and the EPA

Bernard McNamee’s Energy Department chapter and Mandy Gunasekara’s EPA chapter both call for expanding fossil-fuel leasing, repealing Obama- and Biden-era climate rules, narrowing California’s authority to set its own vehicle-emissions standards, and shrinking EPA’s enforcement and environmental-justice functions.

Day-one orders launched a rollback of environmental-review requirements under the National Environmental Policy Act (finalized in January 2026) and declared a national energy emergency, invoking emergency permitting authority; several states sued, arguing the declaration was being used to bypass ordinary Clean Water Act and Endangered Species Act review. EPA proposed repealing 2024 power-plant carbon rules in mid-2025; that proposal was still awaiting final publication as of this writing. More significantly, EPA proposed rescinding the 2009 “endangerment finding,” the formal scientific and legal determination that greenhouse gases endanger public health and welfare, which under a 2007 Supreme Court ruling (Massachusetts v. EPA) is the specific legal trigger that lets EPA regulate greenhouse gas emissions under the Clean Air Act at all. Repealing it isn’t just undoing one rule; it aims to remove the foundation the agency’s entire climate-regulatory authority rests on. That rescission was finalized in February 2026 and now faces two consolidated federal court challenges, one from public-health and environmental groups, one from two dozen states, cities, and counties, with legal scholars across the ideological spectrum predicting it’s likely to lose, since it revisits reasoning the Supreme Court already rejected in 2007.

Congress separately used the Congressional Review Act, a fast-track mechanism that lets a new Congress void a recently finalized regulation with a simple-majority vote in both chambers, with no filibuster available, and, distinctively, permanently bars the agency from ever issuing anything “substantially similar” without new statutory authorization from Congress, to void California’s Clean Air Act waivers underpinning its electric-vehicle mandate in mid-2025; eleven states sued the same day, and a companion Congressional Review Act repeal eliminated a 2024 methane-emissions fee, though it’s unclear whether separate, substantive EPA methane emission standards for oil and gas operations have been touched at all. Coal leasing expanded across 13.1 million federal acres with a cut royalty rate, and offshore lease sales are now scheduled by law through 2040. EPA’s Office of Environmental Justice was eliminated in March 2025, one of the more exact matches between chapter and record in this entire piece.

Neither McNamee nor Gunasekara holds a role in the administration; Gunasekara has said publicly she doesn’t want to return to EPA. Administrator Zeldin, who wrote none of this, is nonetheless singled out by the energy-trade outlet E&E News as the official most responsible for how closely his agency’s actions track it, while that same outlet’s own tracking found only a small fraction of Energy Secretary Chris Wright’s specific policy choices actually followed McNamee’s chapter, with Wright diverging openly on carbon-capture funding and the department’s loan office.

Interior and public lands beyond energy

A separate Interior Department chapter, written by William Perry Pendley, a former acting BLM director whose 424-day tenure in that role during Trump’s first term was later ruled unlawful by a federal court, on grounds unrelated to Project 2025, goes further on public lands than the energy-leasing agenda above. It calls outright for repealing the Antiquities Act of 1906, the law presidents have used for more than a century to designate national monuments, arguing the law improperly grants a president emergency powers it shouldn’t. Short of repeal, it says the first Trump term’s monument shrinkages didn’t go far enough and names two specific monuments, one in Maine and one in Oregon, that should have been reduced and weren’t. On endangered species, it argues the Fish and Wildlife Service’s own science is compromised by outside specialists it calls a cartel, and calls for delisting the grizzly bear and gray wolf, ceding authority over the sage grouse to states, and abolishing the U.S. Geological Survey’s biological-research division outright.

The Justice Department itself supplied a key structural piece of this agenda in 2025: an opinion reversing an 87-year-old prior legal position, concluding that a president’s power to designate a monument implies a matching power to revoke or shrink one, a reading conservation lawyers immediately called radical, and one a law professor predicted was designed specifically to tee up a Supreme Court test. That test may now be coming: in July 2026, the administration cut Bears Ears National Monument by more than 90 percent and Grand Staircase-Escalante by a similar margin, re-designating both under their original names at a fraction of their former size and attempting to dissolve the tribal commission that had co-managed Bears Ears. Five tribal nations and a coalition of environmental groups condemned the cuts and said they intended to sue; no confirmation that a complaint over this second round of reductions was actually filed could be found as of this writing. A Tenth Circuit ruling that June, in the separate, still-unresolved fight over Biden’s 2021 restoration of the same two monuments, had already held that this kind of presidential decision is reviewable in court at all, a procedural win for future challengers that leaves the core constitutional question, whether a president can revoke a monument unilaterally, still open. Notably, Interior Secretary Doug Burgum called monument resizing not a priority as recently as April 2025, fifteen months before the administration went ahead anyway. Four more monuments under review, Baaj Nwaavjo I’tah Kukveni–Ancestral Footprints of the Grand Canyon and Ironwood Forest in Arizona, Organ Mountains-Desert Peaks in New Mexico, and Chuckwalla in California, round out a six-monument list that also includes Bears Ears and Grand Staircase-Escalante themselves; none of the other four had received a reduction proclamation as of this writing.

On endangered species, wildlife agencies finalized rules in 2026 restoring several earlier limits on species protection and, more consequentially, rescinding the regulatory definition of habitat destruction that had covered it for decades, adopting a narrower reading a Supreme Court justice once argued for only in dissent; that change takes effect that September. Gray wolf delisting remains contested: the House passed a bill in December 2025, but a Senate companion has stalled, and the administration’s grizzly bear proposal, still not finalized, turns out not to be a straight delisting at all. It would keep the bear’s Endangered Species Act listing in place while shifting day-to-day management to state and tribal authorities. A separate Interior rule that had put conservation on equal footing with grazing, mining, and timber as a recognized use of public land was fully repealed in mid-2026, and a broader overhaul of grazing regulations, the first in three decades, is pending. The National Park Service lost roughly a quarter of its permanent staff through the same 2025 personnel actions affecting the rest of the government, even though Congress separately declined to enact the deeper budget cuts the administration had proposed for the agency specifically.

Pendley holds no role in the current administration; the actual BLM director, a former New Mexico congressman, was never a Mandate author. Conservation groups have nonetheless described his record in terms similar to the chapter’s own framing.

Labor policy and the NLRB

Jonathan Berry’s chapter calls for narrowing overtime-pay eligibility, making it easier to classify workers as independent contractors rather than employees, ending “card check” union recognition, where a union is certified once a majority of workers simply sign cards, without a formal secret-ballot election, in favor of mandatory elections, reversing a 2023 National Labor Relations Board remedy called Cemex (which lets the Board order an employer straight into bargaining, rather than just rerunning a tainted election, when that employer commits serious unfair labor practices during a union campaign), cutting the NLRB’s budget, and ending federal contractor DEI requirements.

The Labor Department formally rescinded a Biden-era rule that would have expanded overtime eligibility, restoring the lower, first-Trump-term salary threshold in May 2026, with the department’s own wage-and-hour administrator saying no further increase is currently planned. A rule loosening contractor classification was still in public comment as of spring 2026. On the NLRB, Trump fired board member Gwynne Wilcox and General Counsel Jennifer Abruzzo in his first week, the first time any president has removed a sitting NLRB member. The board, which needs three sitting members to issue legally binding decisions, lost its quorum for nearly a year as Wilcox’s case moved through the courts, before the Supreme Court’s Slaughter ruling (discussed above) effectively closed off her legal argument; the board regained a working, Republican-appointed majority in stages, completed with a third confirmation in August 2026. That majority has not yet moved to reverse Cemex or the 2023 “quickie election” rule Berry’s chapter specifically targets; lower courts have split on Cemex regardless, with the Sixth Circuit rejecting the framework in March 2026 and the Ninth Circuit upholding it the following month. Day-one orders ended federal contractor affirmative-action requirements dating to a 1965 executive order and, a year later, added a mandatory contract clause against “illegal DEI,” both upheld so far against a Fourth Circuit challenge, though a Justice Department official has said on the record that the department isn’t investigating companies simply for having a DEI program, only for specific conduct it considers unlawful. A separate order stripping collective-bargaining rights from federal employees at more than a dozen national-security-adjacent agencies has been blocked in some circuits and allowed in others; the House passed a bipartisan bill to reverse it, and the Senate has not acted.

Berry himself did not become Labor Secretary; he was confirmed as the department’s Solicitor, its chief legal officer, in October 2025.

Financial regulation: the CFPB and the Fed

The Mandate’s Treasury Department chapter, Chapter 22, written by William L. Walton, Stephen Moore, and David R. Burton, and covered further below for its separate proposals on the IRS, calls on Congress to abolish the Consumer Financial Protection Bureau outright and, short of that, for a president to wind the agency down administratively: closing its offices, rescinding its rules, and returning its remaining functions to other regulators. Part of what makes the CFPB an unusual target is how Congress originally funded it: rather than the normal annual appropriations process, Congress in 2010 funded the bureau through automatic transfers from the Federal Reserve’s own earnings, specifically to insulate it from being starved of money by a hostile Congress or administration. That design is exactly what made a request for zero dollars in funding such a distinctive way to try to kill the agency. It wasn’t Congress declining to appropriate money; it was the bureau’s own acting leadership declining to draw money it was otherwise entitled to.

A separate Federal Reserve chapter, written by Paul Winfree, argues for narrowing the Fed’s “dual mandate,” its statutory obligation to pursue both stable prices and maximum employment, rather than price stability alone, shrinking its balance sheet, and, as options rather than firm recommendations, moving to a preset rules-based monetary policy or abolishing the Fed altogether in favor of a gold standard or “free banking.” Mainstream economists broadly, though not universally, treat a central bank’s independence from short-term political pressure over interest rates as important specifically for inflation credibility: the idea that markets will trust a central bank to fight inflation only if it isn’t beholden to a president who might prefer looser money before an election.

Russ Vought, simultaneously OMB Director and the CFPB’s acting director, tried to shut the bureau down within weeks of taking office, closing its headquarters, ordering staff to stop work, and declining to draw the bureau’s next quarterly funding allotment. A federal judge blocked the move, and when a modified version of the same effort surfaced later, she found the administration was again trying to shut the agency down through different means. The fight over the bureau’s staffing and funding remained unresolved through most of 2026; a truce pausing further cuts for at least 60 days was reached in July, and Vought’s own legal authority to keep running the bureau under the Federal Vacancies Reform Act, the statute limiting how long an “acting” official can hold a post without Senate confirmation, expired on August 1, 2026, handing the acting directorship to his deputy, Mark Paoletta. A permanent, Senate-confirmed director has not yet been installed; one earlier nominee’s confirmation was withdrawn, and a second nomination, Landon Levenbach, widely read as a maneuver to extend Vought’s own tenure under the same vacancies statute, was returned to the president unacted-on by the Senate in January 2026. A third nominee, Capital One executive Brian Johnson, had a Senate Banking Committee confirmation hearing on July 23, 2026, where he declined to endorse eliminating the agency outright; his nomination remained pending in committee as of this writing, with the Senate in recess until mid-September.

The Fed chapter’s specific structural proposals, the mandate change, the balance-sheet wind-down, the gold-standard option, do not appear to have been pursued through any legislative or executive channel. What happened instead was personnel pressure. In August 2025, Trump attempted to remove Fed Governor Lisa Cook over unproven fraud allegations, the first such attempt against a sitting governor in the Fed’s 111-year history; ordinarily, a Fed governor can only be removed “for cause,” meaning inefficiency, neglect of duty, or actual malfeasance in office, not policy disagreement or unproven accusations. The Supreme Court denied the administration’s request to let the removal proceed in June 2026, ruling, on the same day it decided Trump v. Slaughter elsewhere, notably treating the Fed as a constitutionally distinct case rather than folding it into the same removal-power theory, that Cook was entitled to real notice and a chance to respond before any removal could take effect. Trump restarted the process on those terms: a White House official notified Cook in writing on August 5, 2026 that the president was considering removing her again, citing the same underlying allegation, a criminal referral from Federal Housing Finance Agency Director Bill Pulte over two properties, in Michigan and Georgia, each at one point declared a “primary residence,” and gave her 21 days to respond. Cook’s attorney submitted a written response on August 26 calling the allegations baseless and arguing that, at most, an inadvertent paperwork error doesn’t meet the “for cause” standard. As of this writing, two days later, Trump has not announced a final decision, and the second attempt has not yet produced any new court filing. Separately, a criminal investigation into Fed Chair Jerome Powell over renovation cost overruns at Fed headquarters, opened after a Republican congressman’s referral, was dropped in April 2026; Powell’s term as chair ended on schedule the following month, and he chose to remain on the Board rather than resign, an unusual break with precedent last seen when a Fed chair did the same thing in 1948. His successor, Kevin Warsh, was confirmed in what multiple outlets described as the most party-line vote for that position in the Fed’s history.

Winfree, the Fed chapter’s author, was hired as an adviser to Warsh in June 2026, an advisory role, not a governor’s seat. Vought, who actually ran the shutdown attempt, is a widely-credited Project 2025 figure by reputation, but through a different chapter, the Executive Office of the President, not Chapter 22’s, whose own three named authors are covered further below.

Treasury and the IRS

The same Treasury Department chapter also targets the 2022 Inflation Reduction Act’s roughly $80 billion, decade-long IRS funding boost by name, calling it a radical expansion that would double the agency’s workforce, and says the IRS’s budget should be held flat in real terms. It also calls for making several additional senior IRS positions presidential appointments rather than career civil-service roles, closing the IRS’s diversity office, and increasing funding for the independent Taxpayer Advocate. It says nothing about the IRS’s since-cancelled free electronic-filing program, which didn’t yet exist in its current form when the chapter was written, though it does object to a related, contemporaneous proposal for expanded financial-account reporting requirements.

The IRS lost roughly a quarter of its entire workforce in 2025, including nearly a third of its revenue agents, the employees who actually conduct audits, through a mix of terminations, deferred-resignation offers, and attrition; Congress has separately clawed back roughly two-thirds of the Inflation Reduction Act’s original IRS funding across several bills since 2023. Tax attorneys interviewed by financial press describe enforcement actions against very high earners quietly expiring under the statute of limitations rather than being completed, and one research center’s modeling, using the IRS’s own historical data on what enforcement spending returns in additional revenue, projects the combined staffing and funding cuts could cost the federal government hundreds of billions of dollars in forgone revenue over the next decade. The National Taxpayer Advocate’s own account of the most recent filing season is more mixed than either side’s talking points suggest: individual tax returns were processed about as smoothly as before even with far fewer staff, but phone service measurably worsened, with barely a fifth of calls to the main taxpayer line getting answered.

The free electronic-filing pilot program itself, expanded to half the states by 2025, and rated highly by the taxpayers who used it, was ended for the 2026 filing season, not through the outright legislative repeal an earlier House bill had proposed, but through a Treasury report recommending the government instead expand its older partnership with private tax-software companies. A separate 2025 agreement letting immigration enforcement request taxpayer records on people under final removal orders led to tens of thousands of disclosures before a federal court found the arrangement likely unlawful and blocked further sharing. The agency has also cycled through an unusual number of leaders since the 2024 election: one Senate-confirmed commissioner, Billy Long, was removed roughly two months after his own confirmation, with Treasury Secretary Scott Bessent stepping in as acting commissioner. The IRS itself announced in March 2026 that Bessent’s acting authority had lapsed, though he told the Senate Finance Committee that June he was still “performing the duties” of the office; day-to-day leadership has since fallen to Frank Bisignano, who holds the newly created title of IRS Chief Executive Officer while simultaneously serving as Social Security Commissioner. No permanent, Senate-confirmed IRS Commissioner had been nominated as of this writing.

None of Chapter 22’s three named authors holds a position in the current administration, though one submitted written congressional testimony in 2025 on locking in the cuts described above. The clearest link between the chapter’s ideas and the current administration isn’t authorship but Treasury Secretary Scott Bessent’s own direct, hands-on control over IRS leadership, exactly the kind of expanded political authority over the agency the chapter argued for in the abstract, exercised by someone who never wrote a word of it.

The FCC and media policy

Brendan Carr’s FCC chapter is built around a claim that courts have read Section 230, the law shielding online platforms from liability for user content, far more broadly than its text supports, and it proposes an FCC order narrowing that immunity specifically for content-moderation decisions, alongside new transparency and appeals requirements for platforms and, at the congressional level, treating dominant platforms more like public utilities on non-discrimination grounds. Updating decades-old broadcast-ownership limits and a national spectrum-auction strategy round out the chapter’s other major asks. One thing the chapter does not do, worth stating plainly because it cuts against the pattern of everything that follows: it never proposes using broadcast license authority as leverage against news organizations over perceived political bias. That specific tool doesn’t appear anywhere in Carr’s own text.

Carr became FCC chairman on Inauguration Day and has spent the eighteen months since doing exactly that anyway, drawing on the commission’s older, general public-interest and news-distortion authority rather than anything the chapter itself proposed. His FCC opened an investigation into NPR and PBS underwriting announcements within his first two weeks (no resolution has been confirmed since); conditioned approval of a major media merger on ending the target company’s diversity programs and installing an outside news ombudsman, days after the same company settled a lawsuit Trump had personally brought over how one of its news programs had been edited; and, after a late-night television host made comments about a political assassination, warned publicly that broadcasters could handle the matter the easy way or the hard way, language that led two station-owning companies to pull the show from dozens of affiliates within hours, before it returned days later. In 2026, the FCC opened an unusually early review of one network’s broadcast licenses, not otherwise due for years, prompting that network’s parent company, Disney, to sue the FCC directly in August 2026, alleging retaliation for its news coverage; a judge declined to expedite the case, instead setting a briefing schedule running to late September and a hearing for the week of October 5. That same year, the commission repealed the decades-old cap limiting how much of the national television audience one company’s stations can reach, over a dissent arguing only Congress can change a limit set by statute.

No formal Section 230 rulemaking has actually been issued; legal scholars across the ideological spectrum, including some sympathetic to Carr’s broader goals, argue the FCC may simply lack the authority to do what the chapter proposes at all, especially after a recent Supreme Court ruling narrowing how much deference agencies get when they stretch a statute’s plain text. Separately, Carr told a Senate committee in December 2025 that the FCC isn’t really independent in a legal sense, since the president can remove commissioners at will, a claim the Supreme Court’s own ruling on removal power discussed above has since made considerably harder to dispute. It has also left the FCC’s lone Democratic commissioner, Anna Gomez, in a legally fragile spot rather than actually costing her the seat: her term expired June 30, 2026, two days after that ruling, and she has continued serving only in holdover status pending a successor, one multiple outlets say is unlikely given her public criticism of Carr. Two of the commission’s five seats sit vacant; Trump nominated a Carr aide, Danielle Thumann Severs, to one of them in August 2026, which would produce a 3–1 Republican majority if she’s confirmed.

A second Mandate author, Adam Candeub, wrote the companion FTC chapter, became the FCC’s general counsel in 2025, and was nominated in mid-2026 to lead the Justice Department’s Antitrust Division, a real, if secondary, personnel match. Critics of Carr’s approach include more than eighty legal scholars and former FCC officials who signed a letter alleging unconstitutional pressure campaigns against broadcasters, a bipartisan group of former FCC chairs who asked Carr directly to drop the license review, and the FCC’s own dissenting commissioner, who has repeatedly called the merger conditions and licensing threats First Amendment violations dressed up as ordinary process.

The Defense Department

Christopher Miller’s Defense Department chapter, Miller briefly served as acting defense secretary at the end of Trump’s first term, names China as the singular top threat to American security and calls for expanding and modernizing the nuclear arsenal accordingly, treating Russia, Iran, and North Korea as threats better handled by U.S. allies. Its most detailed proposals concern personnel and culture: eliminating diversity, equity, and inclusion offices across the military, auditing service-academy curricula to remove what it calls politicized content, expelling service members with gender dysphoria and ending public funding for transition-related care, instructing senior officers that their duty is military readiness rather than what it calls a social-engineering agenda, and slowing the promotion of officers it says were advanced for reasons other than warfighting skill. A frequently repeated line about reviewing general-officer promotions for ideological content is often misattributed to this chapter; it actually comes from Vought’s separate Executive Office of the President chapter.

Defense Secretary Pete Hegseth, confirmed by the narrowest possible margin, with the vice president casting a tie-breaking vote amid contested allegations from his personal life, has enacted much of the personnel and culture agenda nearly verbatim. A February 2025 policy barred anyone with current or historical gender dysphoria from military service; a federal judge blocked its enforcement against currently serving troops within weeks, finding it steeped in bias, and an appeals court upheld that block in mid-2026 even as it let the ban apply to new enlistees, with the administration since asking the Supreme Court to take up the underlying question. Service academies were ordered to drop race and gender from admissions consideration, remove library materials on related topics, and disband cadet groups organized around race, gender, or sexual orientation. In his first month, Trump fired the sitting Joint Chiefs chairman, only the second Black officer to hold the post, along with the first woman to lead naval operations and the Army’s and Air Force’s top military lawyers; reporting has since documented a broader pattern in which roughly two dozen general and flag officers have been fired or forced into retirement over about fifteen months, disproportionately Black or female, with none cited for performance reasons, and Hegseth has personally intervened at least twice to remove Black or female officers from promotion lists. A wire-service report separately confirms a direct, unhedged 20-percent cut to the number of four-star general positions, matching the chapter’s call to reduce the generals’ ranks almost exactly. The actual National Defense Strategy released in January 2026 treats homeland defense and China as joint top priorities rather than naming China alone, a modest but real divergence from the chapter’s more singular framing, while reducing the relative U.S. commitment to European and Middle Eastern partners.

Miller holds no role in the current administration; he moved into private-sector defense investing weeks after Trump’s inauguration. Critics, including the ranking Democrat on the Senate Armed Services Committee and the federal judges who’ve ruled on the transgender-service policy, have characterized the personnel purges and gender-dysphoria policy as ideologically driven rather than readiness-driven; Hegseth’s own public framing, stated repeatedly before and after his confirmation, is that removing what he calls politicization restores meritocracy and lethality to the force.

The Intelligence Community

Dustin Carmack’s Intelligence Community chapter, he was Director of National Intelligence John Ratcliffe’s chief of staff during Trump’s first term, takes a narrower view of reform than its reputation suggests. It explicitly rejects creating any new domestic counterintelligence agency, leaving that role with the FBI and CIA; it argues for strengthening the Director of National Intelligence’s real authority over the sixteen other intelligence agencies, but proposes doing so through an executive-order fix rather than new legislation, and states outright that the office shouldn’t grow into a bigger bureaucratic headquarters, comparing its proper role to an orchestra conductor’s rather than a commander’s. On surveillance, the chapter defends the controversial Section 702 program specifically, citing an independent oversight board’s finding that it hadn’t been abused, and reserves its criticism for older surveillance authorities and the errors in the Carter Page FISA warrant application. Its most pointed personnel proposal calls for revoking the security clearances of former officials who discuss their work publicly without approval. And in a passage that sits in real tension with what critics say followed, the chapter explicitly warns against choosing intelligence leaders for political loyalty over expertise, and against leaders who tailor their conclusions to please a president.

Director of National Intelligence Tulsi Gabbard cut her office’s staff by roughly 40 to 50 percent and its budget by some $700 million a year, dissolving several analytic centers, a reduction in scope, not the strengthened coordinating authority the chapter actually asked for. CIA Director Ratcliffe reorganized the agency’s structure and sharply compressed its acquisition timelines. A wave of personnel actions drew far more controversy than the reorganizations themselves: a first-day executive order revoked the security clearances of 51 former officials who had signed a 2020 letter casting doubt on the Hunter Biden laptop story; the head of the National Security Agency and U.S. Cyber Command was fired that April, reportedly at the urging of a political activist rather than through any normal process; a CIA analyst was fired the same way; and Gabbard herself publicly disclosed an undercover CIA officer’s name in August 2025, ending that officer’s career and producing a documented rift between Gabbard and Ratcliffe. Section 702 itself lapsed in June 2026 after Congress failed to pass a further extension, a follow-up House bill to revive it failed 198–218 that same month, and remained unreauthorized as of this writing, though the underlying surveillance continues under existing FISA court certifications good through March 2027; the House was not scheduled to return from recess until August 31, 2026, and the Senate Intelligence Committee’s vice chairman said in late July that a deal remained elusive even with the permanent-DNI question settled. Gabbard also declassified material alleging the intelligence community’s 2017 Russia assessment had been manufactured, drawing a rare bipartisan objection from the House Intelligence Committee’s ranking Democrat. She resigned in May 2026, citing her husband’s cancer diagnosis rather than any policy dispute; after a brief acting succession, the Senate confirmed Jay Clayton, a former SEC chairman under the first Trump administration, as permanent Director of National Intelligence by a 51–47 vote on July 28, 2026, and he was sworn in on August 3.

Carmack holds no role in the current administration; he moved to Meta, eventually becoming the company’s top government-relations executive. Ratcliffe was never the chapter’s credited author, but its text draws directly on an interview conducted with him specifically for the document, a closer connection than a bare contributor listing, even without an authorship credit.

Commerce, HUD, VA, and SBA

Four smaller departments round out the document’s coverage, each with its own named chapter author and its own, mostly separate, story since 2025.

Commerce. Thomas Gilman’s chapter, he was the department’s chief financial officer in Trump’s first term, calls, under a section literally titled to that effect, for breaking up the National Oceanic and Atmospheric Administration, which it describes as a driver of unwarranted climate alarm; it specifically proposes commercializing National Weather Service forecasting and eliminating NOAA’s climate research office. It also calls for adding a citizenship question to the census. NOAA absorbed real, large cuts starting in Trump’s first weeks, roughly 800 probationary employees fired in February 2025, a further reduction in force that spring, and a budget proposal cutting the agency’s funding by more than a quarter, substantially executing the chapter’s proposal through budget and personnel action rather than formal restructuring; courts found the initial firings likely unlawful before an appeals court let them proceed again. A 2026 census field test included a citizenship question for the first time in decades. Separately, and with no clear connection to anything in Gilman’s chapter, Commerce Secretary Howard Lutnick has pushed to convert federal semiconductor-manufacturing grants into direct government equity stakes in companies including Intel, a genuine policy of this administration’s own making, not a Project 2025 proposal being carried out. Gilman holds no role in the administration.

HUD. Ben Carson’s chapter, notably short, running barely a dozen pages, calls for repealing the rule requiring localities to actively counteract housing segregation, ending the “Housing First” approach to homelessness in favor of requiring treatment ahead of permanent housing, and barring mixed-status immigrant families, including their U.S.-citizen children, from federally assisted housing. Secretary Scott Turner has moved on all three fronts: the fair-housing rule was withdrawn within weeks; a November 2025 overhaul cutting permanent-housing funding from roughly 86 percent to 30 percent of homelessness grants was struck down in court for violating federal rulemaking law, with a similar fight over the next funding round now underway; the mixed-status-family rule remains proposed, not final. Carson himself is not HUD Secretary this term; he was sworn in as a nutrition advisor at the Department of Agriculture instead, his chapter’s author present in the administration, just nowhere near the department he wrote about.

VA. Brooks Tucker’s chapter, he was the department’s acting chief of staff in Trump’s first term, calls by name for rescinding VA policy on abortion and gender-affirming care, legislatively locking in expanded access to private care outside the VA system, and automating the disability-claims process. Secretary Doug Collins finalized a rule reinstating the exclusion of abortion care from VA benefits, now being sued by a veterans’ advocacy group; VA separately rescinded its transgender veteran care policy. Private-care access expanded substantially, though more through a bipartisan 2025 law than the department acting alone. On claims processing, the results are genuinely striking regardless of one’s view of the rest of this record: the disability-claims backlog fell by roughly two-thirds over the past year, credited to AI-assisted review, to its lowest level since 2020. Workforce cuts followed the announce-big-then-retreat pattern seen elsewhere in this piece: an initial plan to cut as many as 83,000 positions was scaled back to an estimated 30,000 through attrition after bipartisan pushback. Tucker holds no role in the administration.

SBA. Karen Kerrigan’s chapter, she runs an outside small-business advocacy group, not a government office, calls for reversing looser lending standards adopted under the prior administration and for a comprehensive review of the agency’s programs. Administrator Kelly Loeffler reversed those standards within her first months. Separately, and only loosely connected to Kerrigan’s actual text, the agency has spent the past year and a half unwinding a presumption that certain racial or ethnic groups automatically qualify for its flagship minority-contracting program, following a court ruling that predates this administration, an effort that has included a full program audit, mandatory financial disclosures from thousands of participating firms, and hundreds of terminations, with tribal business advocates telling Congress the process has burdened firms that never had anything to hide. Kerrigan holds no government role.

The bigger picture

No single story fits all twenty-one of these chapters. The pattern that does repeat: proposals that didn’t require Congress, executive orders, agency rules, personnel decisions, moved fastest and furthest, usually within the first year. The ones that did require Congress, abolishing a Cabinet department, abolishing an independent agency by statute, repealing the Antiquities Act outright, haven’t happened, whatever administrative workarounds have been attempted instead. And in nearly every domain, the actual determining factor in how much of the document’s specific proposal survived contact with office wasn’t the campaign’s disavowal. It was the courts, especially a Supreme Court that spent June 2026 reconsidering nine decades of precedent on a president’s power to remove officials Congress had tried to insulate from him. That single ruling now runs underneath the personnel fights at the NLRB, the Fed, and the FCC alike.

A second pattern cuts the other way, and it recurs often enough to be a real finding rather than a coincidence: the record sometimes runs past what a specific chapter proposed. USAID’s own chapter called for subordinating the agency under a new State Department post, not eliminating it. The actual 2025 shutdown went further and faster, executed by DOGE, a body the document’s authors never designed and, in its own text, never named. The FCC’s chapter never proposes using broadcast-license authority against news organizations over perceived bias; that entire pattern, from the Paramount merger conditions to the Disney lawsuit, draws on the commission’s older general authority instead. And a third pattern cuts differently still: some of the single most consequential actions of the whole administration, the NIH funding fight, the wholesale rebuilding of vaccine policy, the mRNA contract cancellations, Commerce Secretary Howard Lutnick’s push to convert semiconductor grants into government equity stakes, trace to no chapter in the document at all. The HHS actions are Secretary Robert F. Kennedy Jr.’s own initiative, and he has no documented Project 2025 connection whatsoever; Lutnick’s equity push has no connection to Commerce’s own chapter either, which addresses NOAA and the census and says nothing about industrial policy of this kind. “The administration is executing a 920-page script” doesn’t survive contact with any of these three patterns intact. The intelligence chapter adds a fourth wrinkle worth naming on its own: it explicitly warns against picking intelligence leaders for political loyalty over expertise, and against leaders who shape conclusions to please a president, the exact failure mode critics say several of the personnel actions in that chapter’s own domain have since produced.

A fifth shape recurs often enough across unrelated departments to count as its own pattern rather than a coincidence: an ambitious number announced, then a much smaller one actually delivered. OPM’s own rule estimated up to 50,000 positions could convert to at-will “Schedule Policy/Career” status; the order that actually implemented it moved about 8,000. VA’s workforce-cut plan was announced at up to 83,000 positions and landed, after bipartisan pushback, around 30,000. DOGE’s own $215 billion savings claim survived a government audit at a small fraction of that scale. Ambitious announcements shrinking on contact with unions, courts, and Congress isn’t unique to this administration or this document, but the gap is wide and consistent enough here, across personnel, workforce, and accounting claims alike, to be worth naming on its own rather than folding into “moved fast” or “got blocked.”

DOGE is the clearest single illustration of the first four of these patterns at once. What’s in the document’s own text is the theory two other chapters supply: Vought’s case for centralized OMB control, and the civil-service chapter’s case that the original Schedule F push hadn’t gone nearly far enough. DOGE ran with both, on its own terms, using tactics no chapter specified. Fifteen months later, DOGE no longer functions as a centralized entity, its own government auditor calls most of its headline savings figure unverifiable, and the administration has said flatly there will be no accounting of what it actually did.

On the question of how much of the document has been implemented in total, the honest answer is still that no trustworthy number exists, and a fresh check turned up nothing to change that: the 53-percent figure cited in the short version above remains the most recent one found, dating to February 2026, and no neutral, academic, or newsroom-maintained tracker doing comparable work at the same scale has surfaced to replace or corroborate it. A separate, related muddying factor: Heritage Foundation president Kevin Roberts has repeatedly pointed to overlap with Trump’s own campaign platform, Agenda47, as evidence that specific policies trace to Trump’s own thinking rather than to Heritage’s document. That defense has real substance: Agenda47’s video rollout began four months before the Mandate was even published, and fact-checkers who’ve compared the two side by side found genuine, specific divergences alongside the overlap (Project 2025 goes further than Trump’s own stated positions on federal workforce reclassification and reproductive policy, for instance), but it’s also a defense Roberts himself has undercut, telling one interviewer in the same period that the overlap between the two was enormous. Both things are true at once, which is exactly why cleanly separating the two documents’ fingerprints on any single policy is often not fully possible from the public record.

The personnel question resists a clean verdict too. A handful of named chapter authors ended up running close to the exact office their chapter was about; more of them, Cuccinelli, Gunasekara, McNamee, Severino, Skinner, Pendley, Miller, and the three named Treasury authors, among others, didn’t, replaced by officials who never wrote a page of the document at all, yet whom trade and political press covering their own agencies routinely describe as carrying it out anyway. Meanwhile the person who most fits a helped-tear-it-down-then-got-the-job story, Jeremy Lewin at USAID and State, was never a Mandate author at all, and Ben Carson supplies a fourth variant on the personnel question entirely: he’s serving in this administration, just in a different department from the one his own chapter was about. And on at least one issue, Title X, an ally of the movement that wrote the document publicly complained the administration hadn’t gone far enough. The clean version of this story, planned and executed exactly as written, or invented from nothing and disavowed in full, isn’t the one the record actually supports. What the record supports is closer to this: a document whose authors are scattered unevenly through a government that has, so far, implemented pieces of their theory faster than Congress, slower than courts, sometimes further than the text itself proposed, sometimes not at all, and with a track record on its own claimed results, DOGE’s savings number chief among them, that doesn’t hold up especially well to outside audit.

Not yet independently verified

• Whether the FBI has actually been reorganized out of the Deputy Attorney General’s direct chain of command, as the DOJ chapter proposes.
• Whether prosecution of election-crime statute 18 U.S.C. § 241 was reassigned from DOJ’s Civil Rights Division to its Criminal Division, as that chapter also proposes.
• Whether the post-Watergate memo restricting DOJ–White House contact to designated channels has been formally rescinded or altered; a Senate Judiciary Committee FOIA request seeking the current policy was still pending as of late 2025.
• A reported “Civil Rights Fraud Initiative” using the False Claims Act against universities and corporations over DEI certifications, which would closely match the DOJ chapter’s proposal, seen in limited sourcing, not yet confirmed against a named outlet.
• The precise current size of Heritage’s vetted Presidential Personnel Database candidate pool; sources range from “thousands” to a stated goal of 20,000.
• Whether the “180-Day Playbook” has ever been released in full.
• The appellate status of the July 2025 ruling that struck down the administration’s attempted asylum suspension.
• Whether Project 2025’s proposed single consolidated border and immigration agency was ever formally proposed to Congress, or quietly dropped.
• Whether EPA’s substantive oil-and-gas methane emission standards, as distinct from the fee rule already repealed by Congress, have been proposed for repeal.
• Whether litigation has been filed against the August 2026 rule barring Medicaid/CHIP funding for gender-affirming care for minors.
• Whether the Labor Department’s proposed rule loosening independent-contractor classification has been finalized; as of late August 2026 it remained in the final stages of review, with no finalization date confirmed.
• Whether the NLRB, its Republican-appointed majority now complete as of August 7, 2026, has moved to reverse the Cemex bargaining-order remedy or streamlined-election rule that Berry’s chapter singles out; lower courts have split on Cemex in the meantime, with the Sixth and Ninth Circuits reaching opposite conclusions.
• The outcome of Trump’s renewed attempt to remove Fed Governor Lisa Cook. He notified her in writing on August 5, 2026 and gave her 21 days to respond; her attorney responded August 26 rejecting the allegations as baseless; no final decision had been announced as of two days later, when this was last checked.
• Whether Brian Johnson’s nomination for permanent, Senate-confirmed CFPB Director has advanced beyond his July 23, 2026 confirmation hearing; the Senate was in recess until mid-September as of this writing.
• The final appellate disposition of the March 2025 ruling finding Elon Musk’s DOGE role likely unconstitutional, the Fourth Circuit’s only action since was a March 2026 procedural ruling shielding Musk from deposition, not a merits decision, and of the related Second Circuit appeal over DOGE’s access to Treasury payment systems, where the state plaintiffs themselves have now argued the case is moot given DOGE’s disbandment.
• The State Department’s actual response to House Oversight Democrats’ formal demand for a full PEPFAR funding accounting; the August 26, 2026 deadline passed with no response found publicly as of two days later.
• Whether the “Protect U.S. National Security Act,” a bill that would bar eliminating USAID without congressional approval, has advanced at all since introduction.
• The current, authoritative PEPFAR appropriation figure for fiscal year 2026; sources reviewed for this piece diverge by more than a billion dollars.
• Whether a second named contributor co-authored the State Department chapter alongside Kiron Skinner; one secondary source suggests it, unconfirmed.
• Outcomes of the pending First Circuit appeals in both the NIH grant-termination case (argued January 2026, undecided) and the case challenging HHS’s vaccine-advisory-committee overhaul (HHS has asked to expedite ahead of the fall respiratory-virus season); either could reverse a major thread in this piece at any time.
• Whether any of the four other monuments on the same six-monument review list, which includes Bears Ears and Grand Staircase-Escalante themselves, not six beyond them, have received an actual reduction proclamation, as opposed to just being reviewed. Also open: whether a formal legal complaint over the July 2026 Bears Ears/Grand Staircase-Escalante cuts has actually been filed, as distinct from the widely reported intent to sue.
• Whether any narrowed version of a public-land-sale provision, stripped from 2025 budget legislation on procedural grounds, was later enacted in any other bill.
• Whether a court has issued a final ruling, as opposed to a preliminary one reported secondhand, on the legality of the 2025 IRS–immigration-enforcement data-sharing agreement.
• Current resolution status of the FCC’s pending Comcast/NBCUniversal investigation (the Disney v. FCC lawsuit now has a hearing scheduled for the week of October 5, 2026, but remains otherwise unresolved).
• Whether Congress has passed any FISA Section 702 reauthorization since the authority lapsed in June 2026; a House attempt failed 198–218 that same month, and no deal appeared imminent as of late July.
• Final resolution of the NOAA firings litigation and the GOP-led states’ lawsuits seeking to exclude noncitizens from census apportionment.
• Outcomes of HUD’s FY2026 Continuum of Care funding lawsuit (filed July 2026) and the veterans’-advocacy lawsuit over VA’s abortion-care rule.
• The actual scope of relief sought in a lawsuit reportedly aimed at invalidating the SBA itself, filed in the Eastern District of Louisiana in November 2025; the reporting language looks broader than what such a suit could plausibly achieve.
• The specific count of 23 FACE Act pardons, the halt to FACE Act enforcement, the full UNFPA defunding, and the Texas ruling vacating reproductive-health-records protections were cross-referenced from a sibling piece’s already-completed research (a separate, unrelated project) rather than independently re-verified by this piece’s own research passes, worth an independent check before treating them as confirmed to this piece’s own sourcing bar.

Sources

The Implementation Tracker section above is drawn from this piece’s own working tracker, twenty-six research passes across every chapter and thread. A complete working list, every source each of those passes actually pulled from, including litigation dockets, additional wire coverage, and law-firm client alerts used for procedural detail, is available on request; the sources below cover the primary documents and the reporting cited directly in this piece’s own text.

Primary documents

• The Heritage Foundation / Project 2025, Mandate for Leadership: The Conservative Promise, April 21, 2023 (full text; downloaded and searched directly for this piece, including via an Internet Archive full-text mirror used to confirm chapter attributions and the absence of any DOGE-related language)
• The Heritage Foundation, “Project 2025 Publishes Comprehensive Policy Guide,” press release, Apr. 21, 2023
• The Heritage Foundation, “Project 2025 Continues to Grow With 60 Partners,” press release, May 19, 2023
• The Heritage Foundation, “Heritage Applauds Appointment of Dr. Lindsey Burke as Deputy Chief of Staff at U.S. Department of Education,” June 9, 2025
• Consumer Financial Protection Bureau, “The Director” (official leadership page, accessed Aug. 28, 2026)
• Federal Reserve Board, “Lisa D. Cook” (official biography, accessed Aug. 28, 2026)
• U.S. Department of Education, “Returning Education to the States” (accessed Aug. 28, 2026)
• U.S. Government Accountability Office, GAO-26-108615, “DOGE Wall of Receipts: More Transparency Needed on How Savings Are Derived from Contract, Grant, and Lease Terminations,” Aug. 6, 2026
• The White House, Executive Order 14158, “Establishing and Implementing the President’s ‘Department of Government Efficiency,’” Jan. 20, 2025
• Supreme Court of the United States, Trump v. Slaughter, No. 25-332, decided June 29, 2026
• Supreme Court of the United States, Trump v. Cook, No. 25A312, order of June 29, 2026
• Supreme Court of the United States, McMahon v. New York, No. 24A1203, order of July 14, 2025
• The White House, executive orders 14171, 14215, 14410 (personnel); 14242 (education); 14159, 14160, 14165 (DHS/immigration); 14173, 14398, 14251 (labor); 14168, 14187 (HHS); 14154, 14156 (energy), texts via whitehouse.gov and govinfo.gov

Reporting and analysis, by section

Origin, disavowal, personnel

• FactCheck.org, “Trump, Project 2025 and the ‘Dismantling’ of the ‘Administrative State,’” Sept. 2025 (source of the “32 of 40 named chapter authors” figure)
• Deseret News, “Robert George resigns from Heritage Foundation board after Kevin Roberts statement on Tucker Carlson and Nick Fuentes,” Nov. 17, 2025
• OPB, “A rift in MAGA has top Heritage Foundation officials leaving to join with Mike Pence,” Dec. 23, 2025
• Axios, “Trump disavows Heritage Foundation’s Project 2025, despite MAGA ties,” July 5, 2024
• CNN, “Trump claims not to know who is behind Project 2025. A CNN review found at least 140 people who worked for him are involved,” July 11, 2024
• Forbes (Alison Durkee), “Project 2025 Director Steps Down After Trump Criticism, But Project Will Stay Active,” July 30, 2024
• NPR, “Heritage Foundation’s Kevin Roberts on Trump’s first 100 days,” Apr. 30, 2025
• Newsweek, “The Project 2025 Contributors Helming the Trump Administration,” Mar. 9, 2025
• ABC News, “How Trump has infused parts of Project 2025 into his administration,” Dec. 9, 2024
• ProPublica, “How Russell Vought Became Trump’s Shadow President,” Oct. 17, 2025

Personnel power / Schedule F

• CNN, “Trump fires inspectors general from more than a dozen federal agencies,” Jan. 25, 2025
• Federal News Network, “Judge finds Trump unlawfully fired agency IGs, but won’t reinstate them,” Sept. 2025
• U.S. Office of Personnel Management, “OPM Finalizes Schedule Policy/Career Rule,” Feb. 2026
• Government Executive, “Trump signs order moving thousands of federal employees into Schedule F,” June 2026

DOGE

• Government Executive, “Trump vows to establish an ‘efficiency commission’ with Elon Musk at the helm,” Sept. 2024
• Fast Company, “Trump just rebranded the U.S. Digital Service as ‘DOGE,’” Jan. 2025
• CBS News, “Judge finds Elon Musk and DOGE’s shutdown of USAID likely unconstitutional,” Mar. 18, 2025
• Senate Homeland Security and Governmental Affairs Committee (Minority Staff), Memorandum on Elon Musk Conflicts of Interest, Apr. 27, 2025
• CNBC, “Elon Musk thanks Trump, says he’s leaving government work with DOGE,” May 28, 2025
• CNN, “DOGE can access sensitive Treasury payment systems, judge rules,” May 27, 2025
• CNBC / TechCrunch, reporting on DOGE’s centralized structure disbanding, Nov. 24, 2025
• CBS News, “DOGE’s ‘wall of receipts’ riddled with inaccuracies and unsubstantiated claims, congressional watchdog says,” Aug. 2026
• House Committee on Oversight and Government Reform (Democrats), “Breaking Government: How DOGE and Trump Cost Taxpayers, Federal Workers, and Public Services,” Feb. 12, 2026
• Government Executive, “Project 2025 wanted to hobble the federal workforce. DOGE has hastily done that, and more,” Apr. 2025
• The Washington Post, “Elon Musk’s U.S. DOGE Service announces its formal end,” July 6, 2026

USAID

• American Immigration Council-style direct textual analysis of Chapter 9, cross-checked against an Internet Archive full-text mirror of the Mandate
• Law.com / The National Law Journal, “‘Last Resort’: 4th Circuit Shields Elon Musk From Deposition in USAID Shutdown Case,” Mar. 6, 2026
• NPR, “USAID officially shuts down and merges remaining operations with State Department,” July 1, 2025
• U.S. Department of State, “On Delivering an America First Foreign Assistance Program,” Mar. 2025
• Wikipedia (procedural summary, cross-checked against docket sources), “Department of State v. AIDS Vaccine Advocacy Coalition”
• Public Citizen, “Fact Sheet: The Supreme Court’s Decision in AIDS Vaccine Advocacy Coalition v. Department of State and Global Health Council v. Trump”
• Wikipedia, “Rescissions Act of 2025” (cross-checked against Congress.gov and named-outlet reporting)
• NPR, “Congress rolls back $9 billion in public media funding and foreign aid,” July 18, 2025
• The Lancet, “Evaluating the impact of two decades of USAID interventions and projecting the effects of defunding on mortality up to 2030”
• NPR, “Clawing back foreign aid is tied to ‘fraud, waste and abuse.’ What’s the evidence?” July 16, 2025
• CNN, “Fact check: $50 million for condoms in Gaza?” Jan. 29, 2025
• FactCheck.org, “No Basis for Corruption Accusations About USAID Administrator,” Feb. 2025
• House Oversight Committee (Democrats), letter to Secretary Rubio re: PEPFAR, Aug. 12, 2026

State Department (beyond USAID)

• Washington Post, “Rubio unveils sweeping reorganization of State Department,” Apr. 22, 2025
• Foreign Policy, “Rubio Unveils State Department Overhaul Cutting Democracy, Human Rights Offices,” Apr. 22, 2025
• AFSA, “At the Breaking Point: The State of the U.S. Foreign Service in 2025”
• NPR, “The Trump administration is recalling about 30 career diplomats,” Dec. 23, 2025
• Human Rights Watch, “US: Rights Report Mixes Facts, Deception, Political Spin,” Aug. 12, 2025
• Rolling Stone, “Rubio Dismisses Project 2025 as ‘Think Tank Stuff’ Despite Trump Allies Authoring Parts of It”

DOJ / FBI

• CNBC, “DOJ asks judge to dismiss Eric Adams case after seven prosecutors resign in protest,” Feb. 14, 2025
• NPR, “Federal judge drops corruption case against New York City Mayor Eric Adams,” Apr. 2, 2025
• NBC News, “Judge dismisses cases against James Comey and Letitia James after finding prosecutor was unlawfully appointed,” Nov. 24, 2025
• NBC News, “Justice Department appeals judge’s dismissal of indictments against James Comey and Letitia James,” Dec. 2025
• NBC News, “Former Trump national security adviser John Bolton indicted on criminal charges,” Oct. 16, 2025
• NPR, “70% of the DOJ’s Civil Rights Division lawyers are leaving because of Trump’s reshaping,” May 19, 2025
• CNN, “Justice Department ends police reform agreements and halts investigations into major departments,” May 21, 2025
• Washington Examiner, “Appeals court schedules hearing over James Comey and Letitia James cases,” July 17, 2026

DHS / immigration

• American Immigration Council, “What Project 2025 Says About Immigration”
• San Francisco Standard, “San Francisco wins fight over billions in Trump-threatened aid,” Aug. 25, 2026 (Ninth Circuit, County of King v. Turner)
• Migration Policy Institute, “A New Era of Immigration Enforcement Unfolds in the U.S. Interior and at the Border under Trump 2.0,” Oct. 2025
• NPR, “Supreme Court upholds birthright citizenship on constitutional grounds,” June 30, 2026
• NPR, “Supreme Court rules against Trump in National Guard case,” Dec. 23, 2025
• CBS News, “ICE’s detainee population reaches new record high of 73,000, as crackdown widens”
• Human Rights Watch, “Dying in Detention: Rising Deaths in an Expanding US Immigration Detention System,” June 25, 2026
• Cato Institute, “5% of People Detained By ICE Have Violent Convictions, 73% No Convictions”
• PolitiFact, “Do 70% of immigrant detainees have criminal convictions or charges? Fact-checking Kristi Noem,” Jan. 23, 2026

Department of Education

• NPR, “Supreme Court says Trump’s efforts to close the Education Department can continue,” July 14, 2025
• K-12 Dive, “Education Department can cut half of OCR staff for now, appeals court rules,” Sept. 30, 2025
• Education Week, “Education Department Moves Special Ed. and Civil Rights to Other Agencies,” June 2026
• CNBC, “Court order challenges Trump’s plan to move federal student loans to Small Business Administration,” May 27, 2025
• Congress.gov / Congressional Research Service, Legal Sidebar LSB11392, “Department of Education Interagency Agreements,” Feb. 4, 2026

HHS

• ACLU, “Trump Administration Rescinds EMTALA Guidance and Sends Clear Signal: Emergency Abortion Care Remains At Risk”
• KFF Health News, “Inside Project 2025: Former Trump Official Outlines Hard Right Turn Against Abortion,” Aug. 6, 2024
• KFF, “Overview of President Trump’s Executive Actions Impacting LGBTQ+ Health” (living tracker)
• Stateline, “Anti-abortion groups urge attorney general to halt mailing of abortion pills,” Aug. 10, 2026
• Roll Call, “Preserve, alter or end? Each proposed for family planning funds,” Apr. 14, 2026
• Healthcare Dive, “Federal judge vacates Trump admin restrictions on ACA gender-affirming care,” Aug. 2026
• Federal Register, “Prohibition on Federal Medicaid and Children’s Health Insurance Program Funding for Sex-Rejecting Procedures Furnished to Children,” Aug. 13, 2026 (2026-16508)

The rest of HHS (NIH/CDC/vaccines/Medicaid)

• The Budget Lab at Yale (used for the Treasury/IRS section but methodologically comparable), and separately: Inside Higher Ed, “Judges Cite Supreme Rulings, Still Block NIH Indirect Costs Cap,” Jan. 7, 2026
• STAT News, “NIH canceled grants totaling $1.8 billion in Trump cuts,” May 8, 2025
• NBC News, “CDC Director Susan Monarez Is Out, Confirmed by RFK Jr.,” Aug. 27, 2025
• CNN, “US judge blocks Kennedy’s efforts to overhaul US vaccine policy,” Mar. 16, 2026
• AJMC, “AAP Breaks With CDC, Maintains Broader 2026 Childhood and Adolescent Vaccine Schedule”
• KFF, “How Will the One Big Beautiful Bill Act Affect the ACA, Medicaid, and the Uninsured Rate?”
• The Fulcrum, “RFK Jr. as secretary of HHS is a departure from Project 2025,” Dec. 4, 2024
• NPR, “Dr. Erica Schwartz confirmed as CDC director, filling a leadership vacuum,” Aug. 5, 2026
• STAT News, “HHS appeals ruling that stalled many of Kennedy’s vaccine policy changes,” Apr. 29, 2026
• ACLU, “Federal Appeals Court Hears Case Challenging NIH Grant Terminations” (First Circuit oral argument, Jan. 6, 2026)

Energy / EPA

• E&E News, “EPA’s Zeldin emerges as Project 2025 frontman”
• E&E News, “Project 2025 seeps into DOE policy”
• U.S. EPA, “EPA Releases Proposal to Rescind Obama-Era Endangerment Finding,” July 29, 2025
• Clean Air Task Force, “U.S. EPA sued over illegal repeal of climate protections,” Feb. 2026
• The American Prospect, “EPA’s Endangerment Finding Repeal Stands on Shaky Foundations,” Mar. 4, 2026
• U.S. Department of the Interior, “Interior Unleashes American Coal Power,” Sept. 29, 2025
• CBS News, “EPA eliminating environmental justice jobs”

Interior / public lands

• NPR, “Justice Department says Trump can cancel national monuments that protect landscapes,” June 11, 2025
• Center for Biological Diversity, “Trump Slashes Bears Ears, Grand Staircase-Escalante National Monuments For Second Time,” July 13, 2026
• Earthjustice, “Trump Administration Illegally Attacks Bears Ears and Grand Staircase-Escalante National Monuments,” 2026
• Federal Register, “Rescinding the Definition of ‘Harm’ Under the Endangered Species Act,” July 14, 2026
• National Parks Conservation Association, “Staffing Crisis at National Parks Reaches Breaking Point… 24% Decline in Permanent Workforce”
• Deseret News, “What are the proposed changes to grazing law on BLM land?,” July 11, 2026
• Deseret News, “How much land can a president protect? Appeals court says courts can decide,” June 23, 2026 (Tenth Circuit reviewability ruling)
• Montana Free Press, “Feds transfer grizzly bear management to states,” July 15, 2026
• Cowboy State Daily, “After Senate Setback, Wyoming Delegates Say They’ll Keep Pushing Wolf Delisting,” Aug. 5, 2026

Labor / NLRB

• SHRM, “Supreme Court Permits Termination of NLRB Member Wilcox for Now”
• Bloomberg, “Trump Fires NLRB General Counsel Jennifer Abruzzo,” Jan. 28, 2025
• Ogletree Deakins, “Trump Administration Rescinds 2024 DOL White Collar Overtime Expansion”
• Morrison Foerster, “President Trump Rescinds Affirmative Action for Federal Contractors and Requires Enforcement Plan to End Unlawful DEI at Private Companies,” Jan. 22, 2025
• AFL-CIO, “AFL-CIO President on Federal Collective Bargaining Executive Order,” Mar. 2025
• National Law Review, “New Year, New Board, NLRB Nominations Confirmed, Board Regains Quorum”
• Foley & Lardner, “Republicans Gain 3-1 Majority on National Labor Relations Board,” Aug. 2026
• Faegre Drinker, “Sixth Circuit Rules Against NLRB’s Cemex Decision and Other Key Labor Developments Since the Start of 2026,” Mar. 2026

Financial regulation

• NPR, “Russell Vought closes CFPB HQ, tells staff to stop work,” Feb. 8, 2025
• NPR, “Judge orders Trump administration to continue to seek funding for the CFPB,” Dec. 30, 2025
• Consumer Finance Monitor, “Paoletta Becomes CFPB Acting Director,” Aug. 4, 2026
• Consumer Finance Monitor, “Senate sends Levenbach nomination to be CFPB Director back to president, allowing Vought to serve longer as acting director,” Jan. 9, 2026
• Congress.gov, PN1079, Nomination of Brian Johnson, Bureau of Consumer Financial Protection, 119th Congress (official record)
• Consumer Finance Monitor, “CFPB Director Nominee Brian Johnson Won’t Endorse Eliminating The CFPB,” July 24, 2026
• CNBC, “Supreme Court rules Trump cannot fire Fed Governor Lisa Cook for now,” June 29, 2026
• The Washington Post, “White House revives bid to remove Fed’s Lisa Cook over mortgage claims,” Aug. 7, 2026
• SCOTUSblog, “Fed Governor Lisa Cook responds to Trump administration’s letter stating that it is considering her removal,” Aug. 27, 2026
• ABC News, “Trump moving forward with attempt to fire Lisa Cook after Supreme Court setback: Sources,” Aug. 7, 2026
• Courthouse News Service, “Justice Department drops criminal probe into Fed Chair Jerome Powell,” Apr. 24, 2026
• CNBC, “Fed Chair Warsh makes first hires at central bank, including ‘Project 2025’ author,” June 2, 2026
• Public Citizen, CLP Blog, “How would the CFPB fare under Heritage’s Project 2025?”

Treasury / IRS

• The Budget Lab at Yale, “A Weakened IRS Has Substantial Consequences,” Apr. 10, 2026
• CNBC, “Tax attorneys say IRS has become a ‘zombie’ as agency cuts staff and halts audits of the wealthy,” Apr. 17, 2025
• Forbes, “The One Big Beautiful Bill Act Didn’t Kill IRS Direct File But It Sure Feels Like It,” July 15, 2025
• U.S. Department of the Treasury, “Report on the Replacement of Direct File,” Oct. 2, 2025
• CNN, “Trump ousts Billy Long as IRS commissioner, names Bessent acting head,” Aug. 8, 2025
• IRS.gov, “Update on IRS Commissioner position,” IR-2026-36, Mar. 13, 2026

FCC / media policy

• CNN Business, “FCC approves Skydance merger with Paramount,” July 24, 2025; “How Brendan Carr… helped take down Jimmy Kimmel,” Sept. 18, 2025; “Disney sues Trump’s FCC,” Aug. 18, 2026
• NPR, “Trump’s FCC chief opens investigation into NPR and PBS,” Jan. 30, 2025
• CNBC, “FCC chief Brendan Carr tells Senate that his agency is ‘not formally… independent,’” Dec. 17, 2025
• Poynter, “Here’s how many of Project 2025’s media proposals were implemented in 2025”
• Semafor, “Big tech critic Adam Candeub will take key FCC role,” Feb. 3, 2025
• Radio Ink, “Gomez Exits Her Term Defiant as FCC’s Future Remains Unclear,” July 1, 2026
• Axios, “Trump nominates Carr aide Danielle Thumann Severs to the FCC,” Aug. 10, 2026
• Deadline, “ABC’s Lawsuit Against FCC Gets October Hearing Date,” Aug. 2026

Defense Department

• Al Jazeera, “Pete Hegseth confirmed as US defence chief in tiebreaker Senate vote,” Jan. 25, 2025
• CNN, “Trump administration fires top US general and Navy chief in unprecedented purge of military leadership,” Feb. 21, 2025
• NPR, “Pentagon policy illegally banned transgender troops from military, appeals court rules,” June 2, 2026
• NPR, “Defense Secretary Hegseth intervened to stop promotions of Black and female officers,” Mar. 27, 2026
• SCOTUSblog, “Trump administration asks Supreme Court to consider ban on transgender persons in the military,” Aug. 28, 2026

Intelligence Community

• The Heritage Foundation / Project 2025, Mandate for Leadership, Ch. 7 “Intelligence Community,” by Dustin J. Carmack
• CNN, “Gabbard announces more cuts to top US intelligence agency,” Aug. 20, 2025
• The Washington Post, “National Security Agency and Cyber Command chief, Gen. Tim Haugh, ousted,” Apr. 3, 2025
• NBC News / CNBC, “Tensions rise between Tulsi Gabbard and CIA chief after her disclosure of undercover officer’s name, insiders say,” Aug. 30, 2025
• Foreign Affairs (David V. Gioe and Michael V. Hayden), “Trump Is Breaking American Intelligence,” July 2, 2025
• The Washington Post, “Tulsi Gabbard resigns as director of national intelligence,” May 22, 2026
• ODNI.gov, “Jay Clayton Sworn In As Director Of National Intelligence,” Press Release No. 12-26, Aug. 3, 2026
• NPR, “Senate confirms Jay Clayton as director of national intelligence,” July 29, 2026
• NPR, “A key U.S. spying program expires Friday night. What does that mean?,” June 12, 2026
• Deseret News, “Crucial U.S. spy powers will stay dark until September, but Congress is one step closer to renewal,” July 29, 2026

Commerce, HUD, VA, and SBA

• The Heritage Foundation / Project 2025, Mandate for Leadership, Ch. 15 (HUD, Benjamin Carson), Ch. 20 (VA, Brooks Tucker), Ch. 21 (Commerce, Thomas Gilman), Ch. 25 (SBA, Karen Kerrigan)
• CNN, “Trump officials fire 800 employees at NOAA,” Feb. 27, 2025
• HUD.gov, “HUD Secretary Scott Turner Leads Monumental Reforms to Homelessness Program, Ending Biden-Era Slush Fund”
• Shelterforce, “Judge Blocks HUD’s Effort to Overhaul Federal Funding for Homeless Services,” Jan. 23, 2026
• Federal Register, “Reproductive Health Services” (VA final rule), Dec. 31, 2025
• Nextgov/FCW, “Veterans Affairs reduces claims backlog at record rate,” Aug. 2025
• SBA.gov, “SBA Reforms 8(a) Business Development Program to End Racial Discrimination in Federal Contracting,” June 11, 2026
• USDA, “Dr. Benjamin S. Carson, Sr., M.D., Sworn in as National Nutrition Advisor at U.S. Department of Agriculture,” Sept. 24, 2025

Scorecard and Agenda47

• Center for Progressive Reform, “One Year of Project 2025: 53 Percent of Authoritarian Agenda’s Domestic Policy Recommendations Completed or Underway” Feb. 11, 2026 (advocacy-sourced; cite as such)
• PolitiFact, “How accurate are warnings by Democrats, Kamala Harris…,” Aug. 20, 2024
• VERIFY/TEGNA, “No, Project 2025 and Trump’s Agenda 47 are not the same”
• Forbes, “What Is Agenda47?,” Jan. 17, 2025
• Media Matters for America, on Kevin Roberts’ July 10, 2024 WMAL remarks