H.R. 580, Unfunded Mandates Accountability and Transparency Act of 2025

Bill Summary

H.R. 580 would require agencies that promulgate major rules—those with an annual economic effect of $100 million or more—to prepare and publish regulatory impact analyses that would accompany the notice of proposed rulemaking and the final rule. Additionally, the bill would limit some of the discretion agencies have over selecting an approach to that regulatory analysis. H.R. 580 also would codify some policies that are common practice or required under executive orders related to regulatory impact analyses.

In addition, H.R. 580 would expand the role of the Office of Information and Regulatory Affairs (OIRA), within the Office of Management and Budget, and authorize OIRA to review and approve rules proposed by certain independent federal agencies. Under current law, most independent regulatory agencies are not required to submit regulatory impact analyses to OIRA.

The bill would amend an existing Congressional rule to make legislation out of order if the private-sector mandate costs are in excess of a specific threshold. That rule is not automatically enforced; a Member of Congress must raise a point of order to enforce it. (A point of order is an objection raised by a Member on the floor of the House or Senate that questions an action being taken as contrary to the rules of that body.) If a point of order is raised in the House or Senate, each chamber resolves the issue according to its established rules and procedures. Under current rules, only legislation with intergovernmental mandates above a specific threshold is subject to a point of order.

Estimated Federal Cost

CBO expects that enacting H.R. 580 could affect the issuance of some rules but because of the large number and variety of federal rules issued each year, CBO cannot determine whether those effects would have costs or result in savings for the federal government.

Although CBO has no basis on which to estimate the overall budgetary effects of enacting H.R. 580, we expect that the reporting requirements in the bill would increase administrative costs for many federal agencies. Under the bill, agencies that promulgate major rules would need to enhance their research and reporting efforts in the areas of cost-benefit analyses, consultations with interested parties, and assessments of alternatives to the rules.

The estimated costs for agencies to implement those requirements are shown in Table 1 and fall within multiple budget functions.

Basis of Estimate

For this estimate, CBO assumes that H.R. 580 will be enacted before the end of 2025.

Direct Spending

CBO cannot determine the bill’s overall effect on direct spending, but we expect that enacting the bill would increase direct spending for the administrative costs of the Federal Deposit Insurance Corporation (FDIC), the National Credit Union Administration (NCUA), and the Office of the Comptroller of the Currency (OCC); that spending is not subject to the availability of appropriated funds. The NCUA and the OCC collect fees from financial institutions to offset their operating costs; those fees are treated as reductions in direct spending. Using information from the FDIC, CBO estimates that the increased administrative workload under H.R. 580 to prepare additional analyses and reports would increase spending for that agency by $28 million over the 2026-2035 period.

Under current law, the Consumer Financial Protection Bureau (CFPB) is permanently authorized to spend amounts transferred from the combined earnings of the Federal Reserve in an amount necessary to carry out its responsibilities, subject to a statutory cap that was lowered by the 2025 reconciliation act. CBO expects that the CFPB will spend all the transferred funds up to its cap in each year over the 2026-2035 period. Thus, CBO treats any costs for the CFPB to implement H.R. 580 as contingent on future appropriations and discusses those costs below under the heading, “Spending Subject to Appropriation.”

Revenues

CBO cannot determine the bill’s overall effect on revenues, but we expect that enacting H.R. 580 also would affect revenues by changing the cost of operations for the Federal Reserve System, which remits its net earnings to the Treasury. Those remittances are classified as revenues in the federal budget. Based on the cost of similar activities, CBO estimates that the increased costs under the bill would reduce remittances to the Treasury by $27 million over the 2026-2035 period. The bill would not subject the Federal Reserve to the additional reporting requirements for any major rules proposed for monetary policy by the Federal Reserve Board of Governors or the Federal Open Market Committee.

Changes in costs for the Federal Reserve banks have historically resulted in changes to remittances during the same year. However, since fiscal year 2023, the central bank has recorded a deferred asset to account for accrued net losses from expenses in excess of income. As a result, remittances largely have been suspended. In CBO’s projections, remittances from the Federal Reserve will generally be suspended until 2030, and until they resume, most changes in costs incurred by the system will not be recorded as changes in remittances.[1]

Spending Subject to Appropriation

CBO cannot determine the bill’s overall effect on spending subject to appropriation, but we expect that implementing H.R. 580 would increase spending for agencies whose administrative funding is provided in annual appropriation acts. CBO estimates that agencies which tend to produce large numbers of major rules would need more personnel to produce the additional analyses and perform other administrative tasks under H.R. 580. CBO expects that the agencies that promulgate the most major rules, and thus would be the most affected by this bill, include the Departments of Agriculture, Education, Health and Human Services, Homeland Security, Labor, and Transportation, along with the CFPB, the Environmental Protection Agency, the Securities and Exchange Commission (SEC), and the Small Business Administration. Based on the costs of similar activities, CBO estimates that the administrative costs to implement H.R. 580 would total $55 million over the 2026-2030 period; that spending would be subject to the availability of appropriated funds.

Under current law, the SEC is authorized to collect fees sufficient to offset its annual appropriation; therefore, CBO estimates that the net budgetary effect of the SEC’s activities to implement H.R. 580 would not be significant, assuming appropriation actions consistent with the commission’s authorities.

Uncertainty

CBO expects that enacting H.R. 580 could affect the issuance of some federal rules. Because of the large number and variety of rules issued each year, CBO cannot determine whether those effects would result in costs or savings for the federal government.

Pay-As-You-Go Considerations

The Statutory Pay-As-You-Go Act of 2010 establishes budget-reporting and enforcement procedures for legislation affecting direct spending or revenues. Pay-as-you-go procedures apply to H.R. 580 because enacting the legislation would affect direct spending and revenues. However, CBO cannot determine the magnitude or direction of all of those effects.

Increase in Long-Term Net Direct Spending and Deficits

CBO cannot determine the magnitude or direction of the budgetary effects of H.R. 580. As a result, we cannot determine whether the legislation would increase net direct spending by more than $2.5 billion or on-budget deficits by more than $5 billion in any of the four consecutive 10-year periods beginning in 2036.

Mandates

If federal financial regulators increased fees to offset the costs of implementing the bill, H.R. 580 would increase the cost of an existing mandate on private-sector entities required to pay those assessments. CBO estimates that the incremental cost of the mandate would be well below the threshold for private-sector mandates as defined in the Unfunded Mandates Reform Act ($206 million in 2025, adjusted annually for inflation).

The bill contains no intergovernmental mandates.

Estimate Prepared By

Federal Costs:

Julia Aman (for the Federal Deposit Insurance Corporation, the National Credit Union Administration, and the Office of the Comptroller of the Currency)
David Hughes (for regulatory agencies whose spending is subject to appropriation)

Revenues: Nathaniel Frentz

Mandates: Andrew Laughlin

Estimate Reviewed By

Justin Humphrey
Chief, Finance, Housing, and Education Cost Estimates Unit

Joshua Shakin
Chief, Revenue Projections Unit

Kathleen FitzGerald
Chief, Public and Private Mandates Unit

H. Samuel Papenfuss 
Deputy Director of Budget Analysis

Estimate Approved By