Regulatory Cooling Off Act of 2025
The Regulatory Cooling Off Act of 2025 would impose a broad, multi-faceted delay on federal rulemaking. The core change is a mandatory six-month delay before a final rule may take effect, paired with substantially longer public-comment periods and new congressional oversight requirements. Specifically, the bill would extend the public notice and comment window to six months, require agencies to submit finalized rules to Congress at least six months before their effective date, require simultaneous and earlier disclosure to Congress, mandate concurrent public posting on agency websites, and expand the venue and timing for legal challenges and congressional review. The intent appears to be to slow the finalization of rules and to give Congress more time to review and potentially block or modify regulatory actions. Potential impacts include longer timelines for adopting new regulations across federal agencies, higher planning and compliance costs for regulated entities, greater opportunities for congressional input or veto, and new administrative processes for publishing and challenging rules. Some observers may view this as increasing regulatory certainty and accountability, while others may see it as heightening regulatory risk for agencies responding to new issues.
Key Points
- 1Substantially longer public participation window: The bill increases the minimum comment period from 30 days to 6 months (and adds a minimum 60-day window related to certain notice provisions in the rulemaking process).
- 2Six-month pre-approval requirement to Congress: Agencies must submit a finalized rule to each relevant congressional committee not later than six months before the rule’s effective date, creating an extended lead time for legislative review.
- 3Final rule timing and publication: The agency must publish a notice in the Federal Register on the date the finalized rule takes effect, tying the rule’s effective date to its publication date.
- 4Online posting requirement: Agencies must post a final or proposed rule on their website at least 24 hours before the Federal Register publication, increasing pre-release transparency.
- 5Expanded enforcement and review avenues:
- 6- Judicial venue for challenges: Actions under the statute can be brought in the district court where the plaintiff resides or where the agency has an office, expanding forum access for challengers.
- 7- Extended congressional review window: Section 801’s timelines are extended to six months (with an exception if Congress explicitly approves the rule via a joint resolution or similar measure).