Reviewing CPAC's Regulatory Work 2025-April 2026

Over the course of 2025 and through April 2026, the CPAC Foundation's Center for Regulatory Freedom (CRF) maintained a sustained and disciplined presence in the federal regulatory process. While legislative debates often dominate public attention, the structure, cost, and real-world impact of public policy are ultimately determined through agency rulemaking, guidance, and information collection requirements. CRF’s work was grounded in the recognition that meaningful engagement in the administrative process is essential to shaping policy outcomes.

Throughout this period, CRF focused on ensuring that regulatory actions remained aligned with statutory authority, economic reality, and practical implementation. This required continuous participation across agencies, issue areas, and stages of the regulatory lifecycle. Understanding that the Trump administration had a historic deregulatory record in 2025, cutting regulatory costs by an unprecedented $211 Billion, this made the engagement of CRF all the more important in injecting a free-market/limited government perspective into administration decision-making.

A Continuous Engagement Model

CRF operated on a continuous engagement model rather than an episodic one. Across 2025 and into the first four months of 2026, CRF regularly reviewed and responded to proposed rules, information collection requests, and requests for comment across the federal government.

Through April 2026, CRF filed well over one hundred formal submissions into the administrative record, averaging approximately 8–12 filings per week during 2026. These submissions included:

• Notices of Proposed Rulemaking (NPRMs)

• Paperwork Reduction Act (PRA) information collection reviews

• Requests for Information (RFIs)

  
  

At any given time, CRF maintained an active pipeline of pending engagements, ensuring that participation occurred early enough to inform regulatory design rather than merely respond to finalized proposals.

Broad Engagement Across the Administrative State

CRF’s engagement spanned more than twenty federal agencies and covered a wide range of policy domains, including:

• Environmental and energy regulation

• Healthcare and pharmaceutical policy

• Financial regulation and monetary policy

• Communications and technology

• Labor and employment

• Trade, infrastructure, and national security

This breadth reflected a consistent operational premise: while regulatory subject matter varies, the structural challenges of regulatory design—unclear authority, excessive burden, misaligned incentives, and unintended economic effects—are recurring across agencies.

A Consistent Analytical Framework

Across its submissions, CRF applied a consistent analytical framework grounded in:

• Statutory fidelity and administrative discipline

• Cost-benefit calibration and burden minimization

• Paperwork Reduction Act standards of necessity and practical utility

• Performance-based and technology-neutral regulatory design

• Recognition of downstream economic and consumer impacts

This framework was applied across disparate policy areas, enabling CRF to identify recurring structural issues in regulatory design and to provide consistent, actionable recommendations to agencies.

Integration with Policy, Media, and Stakeholder Engagement

CRF’s regulatory work was integrated with broader policy and stakeholder engagement. Throughout this period, the Center:

• Engaged with industry stakeholders and policy organizations

• Participated in media and public commentary to translate regulatory issues for broader audiences

• Coordinated with allied organizations to expand participation in the administrative process

This integration ensured that regulatory engagement was not isolated from broader policy discussions, but instead informed and was informed by them.

Representative Engagement: Final Week of April 2026

CRF’s activity during the final week of April 2026 illustrates the scope and consistency of its engagement model. During this period, the Center submitted multiple formal comments across agencies and issue areas, including:

• Comments to the Environmental Protection Agency supporting a reporting deadline extension under TSCA Section 8(d), while identifying broader structural issues in the design of information collection requirements

• Comments to the Department of the Treasury and Office of the Comptroller of the Currency addressing implementation of the GENIUS Act, emphasizing the need for regulatory frameworks aligned with the economic function of payment stablecoins

• Comments to the Food and Drug Administration on dietary supplement manufacturing and recordkeeping requirements, highlighting the importance of calibrated documentation standards in a post-market regulatory framework

• Comments to the Department of the Interior’s Bureau of Ocean Energy Management supporting administrative streamlining while emphasizing the need for regulatory clarity, predictability, and economic workability in offshore mineral development

• Comments to the Environmental Protection Agency on compliance date extensions for TSCA risk management rules, identifying measurement feasibility and administrability challenges in existing frameworks

• Comments to the Federal Reserve supporting the removal of reputational risk as a supervisory concept and emphasizing the importance of objective, financially grounded regulatory standards

• Comments to the Department of Labor supporting a structured and administrable framework for independent contractor classification, emphasizing clarity, predictability, and alignment with economic reality

These submissions reflect the breadth of CRF’s engagement across environmental, financial, labor, healthcare, and industrial policy within a single week.

Conclusion

Across 2025 and through April 2026, the Center for Regulatory Freedom maintained a sustained, high-frequency presence in the federal regulatory process. This work demonstrated that regulatory engagement is not an episodic activity, but a continuous function requiring consistent attention, analytical discipline, and cross-agency coordination.

The record developed over this period reflects a model of engagement grounded in participation, scale, and structural analysis. As regulatory activity continues to shape the implementation of public policy, sustained engagement in the administrative process remains essential to ensuring that regulatory outcomes are economically grounded, administratively workable, and aligned with statutory purpose.