Executive Orders · The Regulatory Freeze · The Congressional Review Act · The Elections of 1980, 2022, and 2024
Presidential Reversal: What the Record Shows About Each Administration Undoing the Last
Every president who has taken the White House from the other party since 1981 has opened by stopping, withdrawing, or revoking the work of the man before him, using four instruments the record defines: the revocation order, the regulatory freeze memorandum, the Congressional Review Act disapproval, and the withdrawal of pending rules. The counts have climbed across four decades. In their first hundred days, presidents revoked five prior executive orders in 2001, nine in 2009, thirteen in 2017, and sixty-seven in 2021; on January 20, 2025, a single order revoked seventy-eight. The Congressional Review Act, used once in its first twenty years, has now been used twenty-three times in the present Congress. Each administration's documents give its reasons in its own words.
Reversal is the standing first act of American government, and it is conducted in paperwork. Since 1981, every president who has taken office from the opposing party has begun his administration by undoing pieces of his predecessor's work, and the undoing runs through four instruments whose texts survive: the executive order that revokes earlier executive orders by number; the regulatory freeze memorandum that stops the pipeline of unfinished rules on the first day; the Congressional Review Act resolution by which Congress and the new president together void a finished rule and bar its return in substantially the same form; and the withdrawal or postponement of rules still pending when the government changes hands. The American Presidency Project's count of the first hundred days shows the volume rising across the modern transitions: five prior executive orders revoked in 2001, nine in 2009, thirteen in 2017, and sixty-seven in 2021, when half of the new president's executive orders carried a revocation inside them. In January 2025 the bulk rescission became a document of its own: Executive Order 14148, signed on the first day, revoked seventy-eight orders and memoranda of the previous administration in a single list, and a second order eight weeks later revoked eighteen more. Congress's instrument has followed the same curve: the Congressional Research Service counts twenty successful disapprovals in the Act's first twenty-eight years—one in 2001, sixteen in 2017–2018, three in 2021—and the trackers of the present Congress count twenty-three more since January 2025. Each era's documents state the era's reasons in the era's vocabulary, and this report prints them from the documents. The elections held in the years of high inflation stand in the same file, and the desk prints those numbers beside the reversal counts, drawing no line between them. The record closes with the forward state of the instruments: reversal is now announced before inaugurations, the current administration continued rescinding through the autumn of 2025, and the statute's own carryover provision has already loaded the next Congress's window with the present administration's late rules.
The four instruments
The first instrument is the revocation clause. An executive order governs until a later president revokes it, and the revocation is ordinarily one sentence inside a successor order: a list of numbers, followed by the words “are hereby revoked.” Because a president's orders bind only the executive branch and rest on his own authority, a successor of either party may strike them at any hour of his tenure, and the Federal Register preserves each strike beside the order it struck. The second instrument works earlier in the pipeline. The freeze memorandum, issued on or within days of inauguration, directs agencies to send no new rule to the Office of the Federal Register until a department head appointed by the new president has reviewed it, to withdraw rules sent and awaiting publication, and to postpone, commonly by sixty days, the effective dates of rules published under the old administration and still pending. The third instrument belongs to Congress. The Congressional Review Act, enacted in 1996 and codified at 5 U.S.C. §§801–808, requires agencies to report each rule to both houses and gives Congress a window, sixty days of continuous session from receipt, to pass a joint resolution of disapproval in a text the statute itself dictates: “That Congress disapproves the rule submitted by the [agency] relating to [name of the rule], and such rule shall have no force or effect.” A rule disapproved is “treated as though such rule had never taken effect,” and the statute adds the provision with no parallel elsewhere in the reversal machinery: the rule “may not be reissued in substantially the same form” unless a later law authorizes it. Senate consideration runs on fast-track procedures without a filibuster. The fourth instrument is the quietest: the withdrawal of pending rules from the Unified Agenda of Regulatory and Deregulatory Actions, the government's semiannual inventory of work in progress, and the formal withdrawal notices agencies publish in the Federal Register when they abandon a proposed rule outright. Between the freeze and the withdrawal, an incoming administration can stop nearly everything its predecessor left unfinished, and the record shows each administration doing so.
The revocation counts
The American Presidency Project's comparison of the four party-changing transitions of this century counts executive orders only, through the first hundred days of each term, and the desk prints its figures with that scope attached. George W. Bush published eleven executive orders in the window and revoked five prior orders. Barack Obama published nineteen and revoked nine. Donald Trump published thirty-three in the first hundred days of 2017 and revoked thirteen. Joseph Biden published forty-two and revoked sixty-seven, with twenty-one of his orders carrying revocations inside them; across every category of presidential document in his first hundred days, the Project counts seventy-six prior orders explicitly rejected—revoked, amended, suspended, or reversed—in twenty-five of one hundred six documents. The unit of reversal then changed. Earlier presidents revoked predecessor orders inside orders of their own, a few at a time; the dedicated rescission order, a document whose whole content is a list of the dead, appears in the recent transitions. On January 20, 2021, Executive Order 13992 revoked six named regulatory orders of the Trump administration, including the two-for-one regulatory budget order of 2017, and a companion order the same day, Executive Order 13990, revoked nine further executive orders, three memoranda, and a pipeline permit on the American Presidency Project's reading of its text. Two further orders in February and May 2021, titled “Revocation of Certain Presidential Actions,” lengthened the list. On January 20, 2025, the instrument reached its present scale: Executive Order 14148 revoked seventy-eight presidential orders and memoranda of the Biden administration in Section 2, items (a) through the end of the alphabet twice over, and directed the president's domestic, economic, and national security advisers to compile lists of further candidates. The follow-up order of March 14, 2025, states the running total in its own first section—“I rescinded 78 Presidential orders and memoranda issued by then-President Biden”—and revoked eighteen additional actions, executive orders, national security memoranda, presidential memoranda, and determinations among them. Ninety-six bulk rescissions stand in the two orders within the administration's first eight weeks, ahead of the individual revocations carried in subject-matter orders across the same period.
The Congressional Review Act ledger
Congress's instrument slept for its first twenty years and then became routine. The Congressional Research Service's tally, which the George Washington University Regulatory Studies Center's cumulative count matches, records 461 resolutions of disapproval introduced between 1996 and 2024 and twenty enacted. The first success came on March 20, 2001, when the disapproval of the Labor Department's ergonomics rule, issued in the final months of the Clinton administration, became Public Law 107-5 under President Bush's signature. The second success waited sixteen years. In the 115th Congress of 2017–2018, sixteen disapprovals were enacted under President Trump's signature: the Regulatory Studies Center counts fifteen signed in 2017, fourteen of them against rules of the outgoing Obama administration, and Ballotpedia counts fourteen signed in the first four months alone. The sixteenth, signed May 21, 2018, disapproved a Consumer Financial Protection Bureau auto-lending guidance document, on the strength of a Government Accountability Office opinion holding that the guidance was a rule within the Act's meaning—the precedent that widened the instrument from rules to guidance. In the 117th Congress, three disapprovals were enacted under President Biden's signature, all on June 30, 2021: an Equal Employment Opportunity Commission conciliation rule, an Office of the Comptroller of the Currency “true lender” rule, and an Environmental Protection Agency rule that had itself rescinded the previous administration's methane standards, so that the disapproval restored the standards of two administrations back. The present Congress has exceeded the earlier record in a single session of work. The Regulatory Review's empirical analysis of the 2025 signings counts twenty-two disapproval resolutions signed into law during 2025, thirteen of them reaching rules submitted in the ordinary way during the statutory lookback window and nine reaching actions outside it: three California emissions waivers granted under the Clean Air Act, four Bureau of Land Management resource management plans, and further agency actions drawn in through Government Accountability Office opinions. The American Action Forum's tracker for the 119th Congress, in its update of October 26, 2026, counts twenty-three disapprovals enacted in the Congress and 148 resolutions introduced, addressing rules carrying an estimated $175.5 billion in compliance costs; the Senate majority leader's office, citing the same tracker as of November 2, 2026, records twenty-five resolutions passed and twenty-three become law. The desk prints the counts with their counters named, because the trackers differ at the edges over which agency actions count as rules, and the underlying statute's ledger—twenty enactments in twenty-eight years, then twenty-three in under two—is consistent on every count the desk reviewed.
Rules stopped in the pipeline
The freeze memorandum is the oldest of the four instruments in continuous use, and its documentary lineage is unbroken. President Reagan's memorandum postponing pending federal regulations issued on January 29, 1981, nine days into his term. The Clinton transition produced an Office of Management and Budget regulatory review memorandum published at 58 Federal Register 6074 on January 22, 1993. Thereafter the memorandum arrives on inauguration day itself, signed by the incoming chief of staff: Andrew Card's “Regulatory Review Plan” for President George W. Bush, published at 66 Federal Register 7702, dated January 20, 2001; Rahm Emanuel's “Regulatory Review” for President Obama, at 74 Federal Register 4435, dated January 20, 2009; Reince Priebus's “Regulatory Freeze Pending Review” for President Trump, dated January 20, 2017; and Ronald Klain's memorandum of the same title for President Biden, dated January 20, 2021. In 2025 the document rose a grade: the “Regulatory Freeze Pending Review” of January 20, 2025 issued as a presidential memorandum over President Trump's own signature. The one transition in the series without a freeze is 1989, when President George H. W. Bush succeeded a president of his own party and had, as the Davis Polk memorandum on the Priebus freeze records, little reason to block the publication of regulations developed under his predecessor's appointees. The language of the recent memoranda is near-identical across parties. The Priebus memorandum of 2017 and the Klain memorandum of 2021 open with the same sentence, word for word: “The President has asked me to communicate to each of you his plan for managing the Federal regulatory process at the outset of his Administration.” Each continues with the same purpose, in order to ensure that the President's appointees or designees have the opportunity to review any new or pending regulations; each directs that unpublished rules be withdrawn from the Office of the Federal Register; each postpones or asks agencies to postpone the effective dates of published rules by sixty days. What the freeze stops, the withdrawal finishes. On September 11, 2025, the Department of Justice published a single Federal Register notice withdrawing sixteen notices of proposed rulemaking, advance notices, and supplemental notices, together with thirty-eight further regulatory actions carried in the Unified Agenda, fifty-four items in one document, “as part of the Federal Government's deregulatory initiative.” Eleven days into the same administration, Executive Order 14192 of January 31, 2025 had set the arithmetic the withdrawals serve, directing that for each new regulation an agency issue, it identify ten existing regulations for repeal—the successor, at five times the rate, of the two-for-one order of 2017 that Executive Order 13992 had revoked in 2021.
Every era's reason
The justifications are filed inside the instruments, and they change vocabulary on the same schedule as the instruments change hands. The freeze memoranda justify themselves identically in every era, as a pause for review: the new president's appointees must have the opportunity to examine what the old president's appointees left in the pipeline, and the memoranda claim no larger warrant than the calendar. The revocation orders speak in the moral vocabulary of their administrations. President Biden's Executive Order 13992 of January 20, 2021 states its policy in its first section: “It is the policy of my Administration to use available tools to confront the urgent challenges facing the Nation, including the coronavirus disease 2019 (COVID-19) pandemic, economic recovery, racial justice, and climate change,” and describes its own work in one clause—“This order revokes harmful policies and directives that threaten to frustrate the Federal Government's ability to confront these problems.” President Trump's Executive Order 14148 of January 20, 2025 opens its purpose section with the previous administration: “The previous administration has embedded deeply unpopular, inflationary, illegal, and radical practices within every agency and office of the Federal Government,” and continues, “Climate extremism has exploded inflation and overburdened businesses with regulation.” Its conclusion is filed as policy: “it is the policy of the United States to restore common sense to the Federal Government and unleash the potential of the American citizen,” and its promise is filed as a schedule: “The revocations within this order will be the first of many steps the United States Federal Government will take to repair our institutions and our economy.” The March 2025 order repeats the formula, describing its eighteen further rescissions as “necessary to advance the policy of the United States to restore common sense to the Federal Government and unleash the potential of American citizens.” Executive Order 14192 states the deregulatory program's purpose in the Department of Justice's quotation of it: “to promote prudent financial management and alleviate unnecessary regulatory burdens.” The Congressional Review Act states no reason at all; its stipulated resolution text names the agency and the rule and pronounces the rule without force or effect, and the reasons live in the floor debates instead. The desk notes the constant as a property of the documents: across forty-five years and five transitions, every instrument of reversal describes itself as repair—as review, restoration, or the removal of the harmful—and no instrument in the file describes its own operation as the substitution of one administration's preferences for another's, although a substitution is the entire content of each list.
The weather: prices and elections
The desk prints here two series from the record, side by side, and draws no line between them. The first is the Bureau of Labor Statistics' annual average change in the Consumer Price Index for All Urban Consumers. In 1979 the index rose 11.3 percent; in 1980, 13.5 percent, the highest annual reading since 1947; in 1981, 10.3 percent. In the recent cycle the Bureau's table reads: 4.7 percent in 2021, 8.0 percent in 2022—the highest annual average since 1981, with the twelve-month rate reaching 9.1 percent in June 2022—then 4.1 percent in 2023, 2.9 percent in 2024, and 2.6 percent in 2025. The second series is the outcomes of the federal elections held in those years. On November 4, 1980, Governor Ronald Reagan defeated President Jimmy Carter; the presidency and the Senate changed parties, and the House remained with the president's party's opponents. On November 8, 2022, in the midterm elections of the high-inflation year, the House of Representatives changed parties and the Senate did not; the president's party gained one seat there. On November 5, 2024, former President Donald Trump defeated Vice President Kamala Harris; the presidency and the Senate changed parties, and the House remained with the incoming president's party. The reversal counts printed in this report belong to the administrations those elections and their successors seated: the freeze memorandum of January 1981 followed the election of 1980; the ergonomics disapproval of 2001 followed the election of 2000; the sixty-seven first-hundred-day revocations followed the election of 2020, held in a year when the index rose 1.2 percent; and the seventy-eight revocations of January 2025 followed the election of 2024. The desk files the two series in one section because they are the two halves of the public record on the subject, and it leaves their relation to the reader.
The standing first act
The record's forward entries show the instruments loaded in advance and still in use. Reversal is now announced before it can be executed: the American Presidency Project records that the Biden campaign published a set of “Day One” priorities before the inauguration of 2021 and that each had been addressed in orders on the first day; Ballotpedia's inventory of the Biden revocations records that the Trump campaign's 2024 agenda named the reissue of a revoked 2020 personnel order as a day-one priority of the next administration, and the order was among those the new administration issued on its return. The current administration's rescissions continued past the spring: on November 28, 2025, the president announced on social media that any document signed by his predecessor with an autopen, “which was approximately 92% of them, is hereby terminated, and of no further force or effect.” The 92 percent figure is the president's own; no White House record of signing methods supports it in the material the desk reviewed, and the desk found no single instrument in the Federal Register effecting the blanket termination the post announced—the declaration stands in the record as a statement of intent, filed outside the four instruments this report has tracked. Congress's instrument, meanwhile, is pre-loaded against the present administration by the statute's own design. The Congressional Review Act's lookback provision restarts the full disapproval window in a new session of Congress for rules submitted in the final sixty legislative days of the old one, and the Congressional Research Service's overview notes the provision “may hold particular import in years in which there is a change in party control of the presidency.” Rules the agencies submit in the closing weeks of the 119th Congress will accordingly arrive in the 120th as fresh targets, with their sixty days unspent, whoever holds the majority that receives them. The 148 resolutions of disapproval introduced in the present Congress, against the twenty-three enacted, mark the volume of the attempt on the record.
The record as it stands on November 14, 2026, is therefore this. Four instruments carry the whole of presidential reversal: the revocation clause, used five times against prior orders in the first hundred days of 2001 and sixty-seven times in the first hundred days of 2021, and seventy-eight times in a single order on January 20, 2025; the freeze memorandum, issued in near-identical language at every party-changing transition since 1981 and signed by the president himself in 2025; the Congressional Review Act disapproval, enacted once in the Act's first twenty years, sixteen times in 2017–2018, three times in 2021, and twenty-three times in the 119th Congress; and the withdrawal of pending rules, executed through the semiannual Unified Agenda and in Federal Register withdrawal notices—in one Justice Department notice of September 11, 2025, by fifty-four items at a stroke. Every instrument carries its justification in its own text, and the justifications agree in form across the parties that wield them: review, restoration, repair. The elections of the high-inflation years, 1980 and 2024, seated the administrations that then executed the two largest reversal programs in the file, and the desk prints that adjacency as record. The window for the next reversal is already open in the statute, and the practice the instruments serve—an incoming government striking the outgoing government's work as its first official act—stands in the record as routine, documented, and expected by both parties in turn.