The Office of Information and Regulatory Affairs (OIRA) issued a memo on Streamlining the Review of Deregulatory Actions (M-25-36). The memo seeks "the timely and efficient execution" of the Administration's deregulatory agenda as established under Executive Orders 14192 Unleashing Prosperity Through Deregulation and 14219 Ensuring Lawful Governance and Implementing the President's “Department of Government Efficiency” Deregulatory Initiative.
The October 21, 2025, memo offers guidance to agencies on how to streamline and expedite the rescission of regulations that are (1) "facially unlawful prior government regulations" (as discussed in the April 9, 2025, Presidential Memorandum Directing the Repeal of Unlawful Regulations), and (2) "those types of deregulatory activity that will continue to require the development of ore extensive agency record-building."
Executive Order 12866 Regulatory Planning and Review provides OIRA 90 days to review regulatory actions. The memo provides shortened timelines for review of deregulatory actions as follows:
While OIRA may still need to take more time for technically complex or highly impactful reviews that deregulate entire sectors of the economy or for rulemakings that can be expected to generate significant litigation, OIRA is imposing a presumptive maximum 28-day OIRA review period for deregulatory actions that are executed with factual records (see part III infra) and a presumptive maximum 14-day OIRA review period for facially unlawful rules (see part II infra).
One example of streamlining regulatory review is that agencies are encouraged to presume that deregulatory actions do not trigger consultation under the executive orders for Federalism (EO 13132), Consultation and Coordination With Indian Tribal Governments (EO 13175), and Property Rights (EO 12630). If consultation is justified, then the agencies should further presume it can take place during EO 12866 review and the public comment period.
The memo also provides a discussion of the counteracting the ossification of rulemaking, use of good cause exceptions for skipping notice and comment, and exceptions to the requirement for 30-day notice before the effective date of a final rule.