Heritage Foundation's Project 2025 reaches 50% implementation in Trump's first year

By Dec. 22, 2025 — less than one year into Trump's second term — crowd-sourced trackers reported roughly half of Project 2025's 319 measurable objectives had been implemented: 126 completed, 67 in progress. [12][36] The Heritage Foundation's own commentary declared the agenda 'halfway there.'

The Center for Progressive Reform, independently tracking 532 domestic policy actions across 20 federal agencies, put implementation at 47% by late 2025, accelerating to 53% by February 2026. [16] NPR's January 2026 retrospective confirmed the same pattern, quoting 🌴California Attorney General Rob Bonta: 'A lot of the policies from Day 1 to the last day and in between that the administration has adopted are right out of Project 2025.' [6]

Project 2025 is the Heritage Foundation's 920-page governing blueprint, formally titled Mandate for Leadership, published in April 2023 with input from more than 100 conservative organizations and roughly 140 former Trump officials. [19]

Unlike typical think-tank white papers, it is a staffing-and-execution manual: it specifies which offices to eliminate, which career employees to reclassify, which regulations to repeal, and in what sequence — designed to be actionable from the moment a new president takes office.

The document's stated mission is to reverse what it calls the 'administrative state' — the network of career professionals, independent agencies, and regulatory frameworks built over a century — and to replace it with an executive branch answerable solely to the president. [4]

The blueprint's architects didn't just write the plan — they took over the very agencies they described. RVRussell Vought, who co-authored the Executive Office chapter and advocated for bending the bureaucracy 'to the presidential will,' now leads the Office of Management and Budget, which he calls the 'nerve center' for presidential influence across all agencies. [21][22]

Brendan Carr, who wrote the FCC chapter, now chairs the FCC; PNPeter Navarro, who authored the trade section, is Trump's top trade adviser; and LZLee Zeldin, who had Project 2025 ties, leads the EPA. [27]

A DeSmog analysis of Trump's full Cabinet found that 70% of members had ties to Project 2025 organizations — meaning the blueprint's authors have direct control over the agencies the blueprint targeted. [38]

Trump publicly called Project 2025 'ridiculous' during the 2024 campaign, insisting he hadn't read it and had 'nothing to do with it.' [26] But within four days of taking office, Time magazine's analysis found nearly two-thirds of his executive actions 'mirror or partially mirror' Project 2025 proposals. FactCheck.org confirmed the administration was systematically working through the blueprint's priorities across agencies. [4]

By October 2025, Trump dropped the pretense entirely, boasting in writing that he had met with 'Russ Vought, he of PROJECT 2025 Fame,' while threatening to dismantle federal agencies — an open embrace that his own press secretary had earlier called 'irrelevant theories from Beltway insiders.' [6][29]

The fastest-moving front of Project 2025 targeted LGBTQ+ Americans — particularly transgender people — with USAID-related objectives reaching 92% completion by early 2025. [12][33]

Trump removed the X gender marker from U.S. passports on Day One, reversed federal recognition of non-binary identities across agencies, ordered the military to discharge transgender service members, and signed an executive order directing HHS to adopt a definition of family rooted in 'the biological reality of two sexes.' The Supreme Court allowed the passport rule to take effect, over dissent, in November 2025. [13]

Each of these actions corresponded directly to provisions in the Mandate for Leadership, which critics describe as the first time a presidential transition document had explicitly mapped anti-transgender policy as a governance priority. [25]

On reproductive rights, the administration worked through Project 2025's agenda at a pace that Guttmacher Institute researchers called 'the most coordinated federal rollback of reproductive health access in the post-Roe era.' [9]

Trump rescinded Biden-era guidance requiring hospitals to provide emergency abortion care under EMTALA — the law requiring any hospital accepting Medicare to stabilize patients in emergencies — leaving pregnant patients in legal limbo in states with total abortion bans. [3][15]

By November 2025, roughly 40% of Project 2025's 100+ reproductive-restriction objectives had been implemented, including new CDC guidance that reframes abortion data collection as a law-enforcement tool rather than a public health function, and the elimination of the White House Task Force on Reproductive Healthcare Access. [9]

Project 2025 called for abolishing the Consumer Financial Protection Bureau outright — on page 837, it labeled the agency 'arguably the most powerful and unaccountable regulatory agency in existence.' [8][10]

RVRussell Vought, installed as acting director, ordered all CFPB employees to stop work on Feb. 10, 2025, canceled the bureau's headquarters lease, halted ongoing investigations against Capital One, Zelle, and Cash App, and refused to draw the agency's Federal Reserve funding — effectively shuttering an agency Congress created by statute without a congressional vote. The CFPB had returned $21 billion to consumers since its founding after the 2008 financial crisis.

A federal judge ordered the agency kept open in December 2025, but an appeals court allowed the administration to proceed with eliminating 80% of its workforce. [10]

The Department of Education — which Project 2025's very first education sentence said 'should be eliminated' — was formally targeted by Trump's March 2025 executive order and a sweeping November restructuring that transferred its largest programs to other agencies without congressional authorization. [11][14]

Half of the department's roughly 4,100 employees were fired or left; Title I funding for 2.8 million low-income students, IDEA special education funding for 7.5 million students with disabilities, and civil rights enforcement were all shifted to agencies with no education expertise.

In July 2025, the Supreme Court issued a 6-3 decision greenlighting the mass layoffs, with Justice Sotomayor warning in dissent that the ruling 'hands the Executive the power to repeal statutes by firing all those necessary to carry them out.' [24]

The EPA's 2009 endangerment finding — the legal bedrock that requires the agency to regulate greenhouse gases under the Clean Air Act, and the foundation of every federal climate rule for 16 years — was targeted for repeal as Project 2025 directed. [2]

EPA Administrator LZLee Zeldin announced in July 2025 that the agency would 'update' the finding, using a Department of Energy report whose internal reviewers had flagged parts as 'misleading' and 'not factual.' Scientific American reported that 85+ climate scientists found the DOE report had 'largely botched the climate science.' [2]

Parallel to this, the EPA eliminated its Office of Environmental Justice, scrapped the 'good neighbor rule' requiring states to address pollution crossing state lines, and rolled back soot standards linked to respiratory illness and premature death — all objectives specified in Mandate for Leadership.

Schedule F is the executive order Trump reinstated on Day One that strips civil service protections from any federal employee in a 'policy-related' role, reclassifying them as at-will workers the president can fire for any reason. [31]

The Pendleton Act of 1883 created merit-based civil service precisely to end the political spoils system — a system so corrupt it led to the assassination of President Garfield in 1881 by a man who felt entitled to a government job for supporting Garfield's campaign. GAO estimated approximately 50,000 positions could lose civil service appeal rights under the current version of Schedule F. [1][35]

A Boston University Law Review study found the order creates structural conditions for political loyalty tests in agencies that regulate food safety, air traffic control, and Social Security — functions that have been insulated from electoral cycles since the late 19th century. [20]

Project 2025 was not an improvised wish list — it was a $22 million, multi-year operational infrastructure built before the 2024 election, including a database of 20,000 pre-vetted conservative personnel ready to fill federal positions the day after inauguration. [29]

The Heritage Foundation coordinated more than 100 organizations and drew on the lessons of Trump's chaotic first term, when the administration arrived without a staffing plan and spent years fighting a bureaucracy it didn't know how to control.

Reagan-era Heritage President EFEdwin Feulner coined the maxim 'personnel is policy'; Project 2025 operationalized it by ensuring every agency head, deputy, and senior adviser came pre-screened, pre-committed, and pre-briefed on the blueprint's specific objectives — a depth of transition planning with no modern precedent. [6][19]

The 50% implementation figure, while striking, obscures where the remaining resistance lies: the objectives that require acts of Congress — abolishing the Education Department outright, repealing the Affordable Care Act's structure, eliminating remaining CFPB statutory authority, or formally rewriting the civil service laws — remain unfinished. [14][16]

Courts have blocked specific actions, including some Schedule F firings and the EMTALA abortion guidance repeal, though the Supreme Court's 2024 rulings broadly expanded presidential immunity and agency deregulatory authority.

What legal scholars note is that many of the completed 50% involved not new laws but the erasure of existing ones — regulatory rollbacks, enforcement halts, and personnel purges that are far harder to reverse than they were to implement, even if a future administration wanted to. [4][6]