Presidential Control Over Independent Agencies: Seven Weeks Into Executive Order 14,215
On February 18, 2025, President Trump signed Executive Order 14,215, "Ensuring Accountability for All Agencies," asserting unprecedented presidential control over independent federal agencies. Seven weeks into implementation, 26.4% of independent entities (23 out of 87) have experienced major personnel disruptions, including leadership removals and operational shutdowns. This analysis tracks the impact and identifies agencies at risk of further intervention. Click here for a Google Sheet containing data about each agency, status, and litigation.
Purpose of This Analysis
This study was conducted to consolidate fragmented information about the executive order's effects. While news reports have covered individual agency disruptions, I have not seen a comprehensive tracking of personnel changes across all independent agencies. This analysis specifically focuses on personnel actions (removals and their associated lawsuits, layoffs, and administrative leave) rather than programmatic challenges to comply with other executive orders.
Background: What the Executive Order Does
Executive Order 14,215 dramatically expands White House control over independent agencies through several key provisions:
Unitary Executive Theory: Asserts that all executive power constitutionally belongs to the President, claiming independent regulatory agencies have operated with insufficient presidential oversight.
Regulatory Review: Requires all agencies, including independent ones, to submit regulatory actions to the Office of Information and Regulatory Affairs (OIRA) before publication.
Performance Oversight: Directs the OMB Director to establish performance standards for independent agency leadership and report directly to the President.
Budget Control: Authorizes OMB to review and adjust independent agencies' budgets to align with presidential priorities.
White House Coordination: Mandates regular consultation between independent agency chairs and White House offices, requiring each agency to establish a White House Liaison.
Legal Authority: Establishes that the President's and Attorney General's legal opinions are controlling.
Limited Exceptions: Exempts only the Federal Reserve's monetary policy functions, while its regulatory functions remain subject to oversight.
Current Implementation Status
Leadership Changes
Sixteen agencies have had board members or agency heads fired, sometimes on a partisan basis:
Federal Trade Commission (FTC)
Federal Election Commission (FEC)
National Labor Relations Board (NLRB)
Equal Employment Opportunity Commission (EEOC)
Federal Labor Relations Authority (FLRA)
Merit Systems Protection Board (MSPB)
Tennessee Valley Authority (TVA)
African Development Foundation
Inter-American Foundation
U.S. Institute of Peace
Office of Government Ethics (OGE)
Office of Special Counsel (OSC)
Amtrak
National Archives and Records Administration (NARA)
John F. Kennedy Center for the Performing Arts
Advisory Council on Historic Preservation
Agencies Without Quorum
Five agencies now lack the quorum necessary to take meaningful actions:
Tennessee Valley Authority (TVA)
Merit Systems Protection Board (MSPB)
National Labor Relations Board (NLRB)
Equal Employment Opportunity Commission (EEOC)
Advisory Council on Historic Preservation
Agencies Effectively Shuttered
Seven agencies have been essentially eliminated by the "Department of Government Efficiency" (DOGE) through mass personnel reductions:
Institute of Museum and Library Services
U.S. Institute of Peace
African Development Foundation
Federal Mediation and Conciliation Service
Agency for Global Media
National Endowment for the Humanities
Woodrow Wilson International Center for Scholars
Legal Challenges (with links!)
Seven active lawsuits have been filed concerning the removal of officials:
National Labor Relations Board (NLRB) (District Court) (D.C. Circuit)
Additional lawsuits may be forthcoming, as certain EEOC and FEC commissioners reportedly have retained legal counsel but have not yet filed suit. They may be waiting for Supreme Court rulings on other Appointments Clause cases.
Agencies at Risk
Near-Term Risk
Economic development agencies targeted by Executive Order 14,238 ("Continuing the Reduction of the Federal Bureaucracy," signed March 14, 2025) appear particularly vulnerable. Some of the agencies identified in E.O. 14,238 have already been DOGE’d.
Minority Business Development Agency
Community Development Financial Institutions Fund
Presidio Trust (possibly at higher risk due to its San Francisco location)
Medium-Term Risk
Regional economic development agencies are likely to face substantial challenges:
Denali Commission
Appalachian Regional Commission
Other regional development entities
Many of these were previously targeted for elimination during President Trump's first administration and may face severe budget constraints in the FY 2026 budget cycle.
Lower Risk
Agencies that industry relies upon for operations or that align with specific administration priorities may retain functionality:
Federal Communications Commission (FCC)
Securities and Exchange Commission (SEC) - particularly given its role in crypto regulation
Nuclear Regulatory Commission (potentially protected by political concerns over nuclear safety)
Methodology
This analysis tracks 87 federal entities classified as "independent.” These entities can be grouped in the following ways:
Independent regulatory commissions
Labor relations boards
Foreign aid organizations
Cultural institutions
Election-related entities
Economic development organizations
Article I courts
Other entities with statutorily protected leadership or balanced partisan representation
Data was compiled from OPM.gov's database of agencies, OMB's list of "designated federal entities" under section 415(h) of the Inspector General Act (last published in 2014), and direct research.
This spreadsheet will be updated periodically. If you identify an entity that should be included or have information about major changes not reflected here, please contact info@govoversight.net.