Is Project 2025 Still Shaping Trump’s Second Term?

Three months into Donald Trump’s second term, Americans are witnessing swift and dramatic changes across the federal government. During the 2024 campaign, Democrats raised alarms about “Project 2025,” a detailed conservative policy blueprint that Trump repeatedly distanced himself from. Now, as executive orders pile up and cabinet appointees pursue aggressive agency restructuring, it’s time to take a clear-eyed look at which elements of Project 2025 are becoming reality—and which parts of this controversial roadmap might still be on the horizon.

What Exactly Was Project 2025?

For those who need a refresher, Project 2025 was a 900+ page policy document created by The Heritage Foundation in partnership with dozens of conservative organizations. Officially titled “Mandate for Leadership: The Conservative Promise,” it outlined a comprehensive plan to transform the federal government through more than 2,000 specific policy recommendations across virtually every aspect of governance.

Kevin Roberts, president of The Heritage Foundation, described the project as “the most ambitious, most coordinated, and most thorough effort by conservatives to make sure the next conservative president has the personnel and the playbook to be successful.”¹

Despite Trump’s campaign trail assertions that he knew “nothing about Project 2025,”² the document was developed by numerous former Trump administration officials, including Russell Vought (former Office of Management and Budget director) and John McEntee (former White House personnel director). Many contributors were explicitly preparing for a second Trump presidency.

The First 90 Days: Where Project 2025 Has Materialized

Executive Branch Restructuring

One of Project 2025’s central recommendations was the dramatic expansion of presidential authority over federal agencies. The document called for reclassifying thousands of career civil servants under “Schedule F,” which would strip employment protections and allow mass firings and replacements with political loyalists.

On January 23, just three days after his inauguration, President Trump signed Executive Order 14125, recreating and expanding Schedule F.³ This order essentially mirrors the Project 2025 recommendation, potentially affecting up to 50,000 federal employees. The American Federation of Government Employees has already filed legal challenges, but implementation is moving forward during litigation.

Former OMB director Vought, a key Project 2025 architect, proudly noted, “The first action the president took was exactly what we recommended, almost word for word.”⁴

Justice Department Overhaul

Project 2025 called for significant restructuring of the Department of Justice, particularly the FBI, to “reestablish political accountability” and rein in what conservatives viewed as unrestrained prosecutorial power.

Attorney General Pam Bondi has already begun implementing this vision, announcing a comprehensive review of the FBI’s structure and dismissing several senior career officials in the Civil Rights Division and Criminal Division.⁵ Internal memos obtained by the Washington Post show plans for reorganizing major divisions along lines remarkably similar to Project 2025’s recommendations.⁶

Environmental Deregulation

Perhaps no area has seen more rapid alignment with Project 2025 than environmental policy. The Heritage document called for withdrawing from the Paris Climate Agreement, dismantling the EPA’s regulatory authority, and expediting fossil fuel development on federal lands.

In February, President Trump announced America’s withdrawal from the Paris Agreement for a second time. EPA Administrator Lee Zeldin has halted enforcement of numerous climate regulations, including methane emissions rules and vehicle efficiency standards.⁷ Meanwhile, Interior Secretary Doug Burgum has opened bidding for oil and gas leases on previously protected federal lands, precisely matching Project 2025’s recommendations for “unleashing American energy.”⁸

Where Project 2025 Is Still Taking Shape

Healthcare Transformation

Project 2025 outlined an ambitious plan to dismantle key components of the Affordable Care Act and restructure Medicare and Medicaid. While legislation would be required for major changes, administrative actions are already laying groundwork.

Health and Human Services Secretary Robert F. Kennedy Jr. has issued waivers allowing states to impose work requirements for Medicaid recipients and has suspended enforcement of ACA non-discrimination provisions.⁹ However, the most dramatic changes envisioned by Project 2025—converting Medicare to a premium support system and block-granting Medicaid—would require congressional action, which remains uncertain despite Republican majorities.

Education Overhaul

The “education freedom” section of Project 2025 called for eliminating the Department of Education or drastically reducing its role, while expanding school choice programs and restricting DEI initiatives in schools receiving federal funding.

Education Secretary Linda McMahon has begun rolling back civil rights guidance for schools and has announced plans to redirect federal education funds toward voucher programs.¹⁰ However, the complete department overhaul envisioned by Project 2025 hasn’t materialized yet, likely due to legislative hurdles.

Social Policy Changes

Some of Project 2025’s most controversial proposals involved rolling back LGBTQ+ protections, restricting abortion access, and implementing “traditional family” policies across federal agencies.

Progress here has been mixed. While several agencies have rescinded Obama and Biden-era guidance on transgender rights,¹¹ the administration has moved more cautiously on issuing new federal restrictions on abortion access, likely recognizing the political sensitivity following the 2022 Dobbs decision backlash.

What’s Coming Next? The Most Concerning Possibilities

For progressives concerned about Project 2025’s full implementation, several concerning elements may still be on the horizon:

1. Dismantling the “Administrative State”

Project 2025 envisioned fundamentally altering how federal regulations are created and enforced, calling for abolishing independent agencies like the Consumer Financial Protection Bureau and stripping regulatory power from others.

With Schedule F implementation underway, we may soon see more sweeping changes to regulatory agencies as career staff are replaced. Conservative legal scholars are also preparing court challenges that could dramatically limit federal regulatory authority under what’s known as the “major questions doctrine.”¹²

2. Weaponizing the Justice System

Perhaps the most alarming aspect of Project 2025 was its vision of reshaping the Justice Department as an instrument of presidential power. The document called for using federal law enforcement to target political opponents, restrict protest rights, and investigate journalists.

While Attorney General Bondi has made several concerning statements about investigating “left-wing groups,”¹³ the full implementation of these recommendations would represent an unprecedented shift in American governance. Civil liberties organizations are already preparing legal challenges.

3. Foreign Policy Realignment

Project 2025’s foreign policy vision called for significant withdrawal from international organizations, dramatic cuts to foreign aid, and restructuring military priorities around “America First” principles.

Secretary of State Marco Rubio has begun implementing some of these recommendations, notifying the United Nations of reduced American funding and suspending aid to several international organizations.¹⁴ More concerning elements—like withdrawing from NATO mutual defense commitments or abandoning Ukraine support—have not yet materialized but remain possibilities.

Finding Balance: A Progressive Response

The implementation of Project 2025 shouldn’t be viewed through a simplistic lens. Some recommendations, like civil service reform, might have bipartisan validity even if the current approach is flawed. Others, particularly those threatening democratic institutions or fundamental rights, deserve vigorous opposition.

For progressives, the priority should be distinguishing between normal policy disagreements and truly dangerous governance shifts. While we can debate tax policy or regulatory approaches, undermining independent agencies, weaponizing law enforcement, or abandoning international commitments represents a different category of concern.

The most effective response isn’t panic or hyperpartisan rhetoric, but rather focused engagement with specific policies. Legal challenges, public education, and pressure on moderate Republican legislators can help mitigate the most dangerous elements while allowing space for legitimate policy debate on others.

A Living Document in Action

Whatever President Trump may have said during the campaign, Project 2025 clearly serves as a roadmap for much of his administration’s early actions. While implementation isn’t comprehensive or identical, the document’s fingerprints are visible across executive actions and agency priorities.

For Americans across the political spectrum, understanding Project 2025 remains essential for evaluating the administration’s actions. Rather than treating the document as a partisan talking point, we should approach it as serious policy that deserves serious analysis—both where it offers legitimate reforms and where it threatens democratic norms.

As we move deeper into this presidential term, the most significant test may be whether institutions—courts, Congress, civil society, and voters themselves—can distinguish between normal policy shifts and fundamental threats to American democracy. That challenge transcends partisan divisions and speaks to what kind of governance system we want to preserve.