H.R. 6622, Sunshine for Regulatory Decrees and Settlements Act

July 14, 2026

Cost Estimate

As ordered reported by the House Committee on the Judiciary on January 8, 2026

At a GlanceH.R. 6622, Sunshine for Regulatory Decrees and Settlements ActAs ordered reported by the House Committee on the Judiciary on January 8, 2026
By Fiscal Year, Millions of Dollars		2026	2026-2031	2026-2036
Direct Spending (Outlays)		0	*	1
Revenues		0	0	0
Increase or Decrease (-) in the Deficit		0	*	1
Spending Subject to Appropriation (Outlays)		*	32	not estimated
Increases net direct spending in any of the four consecutive 10-year periods beginning in 2037?	< $2.5 billion	Statutory pay-as-you-go procedures apply?		Yes
	< $2.5 billion	Mandate Effects
Increases on-budget deficits in any of the four consecutive 10-year periods beginning in 2037?	< $5 billion	Contains intergovernmental mandate?		No
	< $5 billion	Contains private-sector mandate?		No
* = between zero and $500,000.
The bill would Modify the process for developing consent decrees and settlement agreements that compel federal agencies to take specified regulatory actions Require federal agencies to publish information about covered actions, respond to public comments, and submit certain information for court review Require negotiations to be conducted through mediation or alternative dispute resolution Require agencies to report annually to the Congress on the consent decrees and settlement agreements
Estimated budgetary effects would mainly stem from Increased workload for agencies to litigate lengthier and more complex cases and to comply with process and reporting requirements Larger amounts awarded to plaintiffs in attorneys’ fees for cases that the federal government loses or settles
Areas of significant uncertainty include Projecting the number and complexity of cases that would be affected and the corresponding increase in workload for federal agencies

Bill Summary

H.R. 6622 would modify the process for developing consent decrees and settlement agreements that compel federal agencies to take specified regulatory actions. In those circumstances, the bill would require respondent agencies to publish summaries of the terms and statutory basis of the proposed agreements. That information would be subject to public comment, and the agencies would be required to respond to and compile records of those comments and submit those materials to the court before any final settlement.

The bill would require settlement negotiations to be conducted through mediation or alternative dispute resolution and would require agencies to report annually to the Congress on the details and statutory bases of the agreements. Finally, agencies would need to certify their approval of the agreements and, if the agencies seek modifications, the court would be directed to review the revised agreements as though they were the original agreements.

Estimated Federal Cost

The estimated budgetary effects of H.R. 6622 are shown in Table 1. The costs of the legislation fall primarily within budget function 750 (administration of justice).

Table 1. Estimated Budgetary Effects of H.R. 6622
	By Fiscal Year, Millions of Dollars
	2026	2027	2028	2029	2030	2031	2026-2031
	Increases in Spending Subject to Appropriation
Estimated Authorization	*	6	6	6	7	7	32
Estimated Outlays	*	6	6	6	7	7	32
* = between zero and $500,000. CBO also estimates that enacting H.R. 6622 would increase direct spending by $1 million over the 2026-2036 period.

Basis of Estimate

CBO assumes that H.R. 6622 will be enacted near the end of fiscal year 2026.

Using data from the Department of Justice (DOJ), CBO expects that the agency will enter into roughly 200 consent decrees and settlement agreements annually over the 2027-2031 period that could be affected by H.R. 6622. CBO expects that the bill would primarily affect cases involving agencies that issue regulations concerning commerce, energy, the environment, health, labor, and land management. In such cases, plaintiffs can sue federal agencies to compel regulatory action that affects the rights of nonparticipants, such as private-sector entities or state and local governments. Based on analyses of similar cases involving DOJ that have been settled or have gone to litigation, CBO expects that about 25 percent of the cases each year would require significant additional work to resolve by settlement or litigation, although that number is subject to uncertainty.

Spending Subject to Appropriation

CBO estimates that the additional administrative costs and reimbursable attorneys’ fees needed to implement H.R. 6622 would cost respondent federal agencies $32 million over the 2026-2031 period. Any increase in related spending would be subject to the availability of appropriated funds.

Using information from DOJ, CBO estimates that the additional administrative costs under the bill would average $80,000 per case over the 2027-2031 period. CBO expects that most of that amount would stem from an increase in the number of cases that are litigated rather than settled and an increase in the time that litigation would take to resolve. Agencies also would incur administrative costs to satisfy the bill’s requirements to enter into mediation, respond to public comments, and report to the Congress each year. CBO expects that most of the additional work would be performed by attorneys and other DOJ staff. In total, CBO estimates, implementing the bill would increase administrative costs for federal agencies by $26 million over the 2026-2031 period. Most of that cost would be for DOJ, but every agency involved in a future settlement also would face increased costs.

Plaintiffs who successfully sue the federal government are entitled to collect attorneys’ fees, which are paid mainly from the respondent agencies’ appropriations. Because the bill would lengthen the process for developing agreements for some cases and increase the opportunity for additional parties to intervene, the amount of reimbursable attorneys’ fees would probably increase. In 2024, federal agencies paid $7,600, on average, in attorneys’ fees for about 15,700 cases. For regulatory cases (the type of case that CBO expects would be most affected by the bill), attorneys’ fees averaged $160,000. Such cases tend to be more complicated and thus require more time to resolve. Under the expectation that agencies would pay significantly larger awards for attorneys’ fees in many of the 25 percent of cases that would require additional work, CBO estimates that agencies would spend an additional $6 million for those fees over the 2026-2031 period.

Direct Spending

CBO expects that a small portion of the reimbursed attorneys’ fees would be paid from the Judgment Fund or the mandatory appropriations of agencies involved in litigation. That fund has a permanent, indefinite appropriation to pay monetary awards ordered against the government. Using data about the amounts of attorney’s fees paid by federal agencies in recent years, CBO estimates that enacting H.R. 6622 would increase direct spending by less than $500,000 in every year and by $1 million over the 2026‑2036 period.

Uncertainty

CBO’s estimate for H.R. 6622 is subject to significant uncertainty with respect to the number of cases that would be affected, the length and complexity of litigation, and the resulting increase in workload for affected agencies. As a result, the actual costs of implementing H.R. 6622 could be more or less than CBO estimates here.

In addition, enacting H.R. 6622 could change the number of consent decrees and negotiated settlements that federal agencies enter, as well as the terms of those agreements. Such changes could affect future regulations, with budgetary consequences for discretionary spending, direct spending, and revenues. Because CBO cannot predict how agencies, plaintiffs, and the courts would alter their litigation or settlement practices under the bill, CBO has no basis for estimating those potential costs or savings.

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. CBO estimates that enacting the bill would increase direct spending by less than $500,000 in every year and would total $1 million over the 2026-2036 period.

Increase in Long-Term Net Direct Spending and Deficits

CBO estimates that enacting H.R. 6622 would not increase net direct spending by more than $2.5 billion in any of the four consecutive 10-year periods beginning in 2037.

CBO estimates that enacting H.R. 6622 would not increase on‑budget deficits by more than $5 billion in any of the four consecutive 10-year periods beginning in 2037.