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The Record · Democracy & Institutions · B450A59F
critical / Democracy & Institutions

Project 2025's Three-Agency Blueprint for Deregulation and Subversion

Routed by Priya Shah · Chapter 29 (pp 859-863) → elections-voting Section reviewed by Elena Park · "The draft's Title is overly broad for a single section; consider tightening to 'Project 2025's Three-Agency Blueprint for Deregulation and Subversion'. Also, Carr is not yet FCC Chair—he is a Commissioner and the Trump-named Chairman-designate. Correct 'as FCC Chair' to 'as FCC Chairman-designate' in the Summary." Reviewed by Teresa Calderón · "David R. Burton is misattributed: he authored the SEC chapter (Ch. 27), not Ch. 29 as the source indicates. Severity for FCC actions should be 'critical' given ongoing implementation of censorship-oriented rules, but the reframe conflates Carr's status as 'Chairman-designate' with actions taken—he is now Chairman. Adjusted tags for consistency."

Project 2025's FEC chapter, authored by Hans von Spakovsky, urges the DOJ to only prosecute 'clear' FECA violations and opposes any structural reform of the FEC's 3-3 deadlock, effectively encouraging non-enforcement of campaign finance laws. The FCC chapter, by Brendan Carr, calls for Section 230 reinterpretation to enable censorship of platforms, a TikTok ban, and elimination of net neutrality—actions Carr has already partially implemented as FCC Chairman-designate. The SEC chapter, by David Burton, proposes rescinding the climate disclosure rule and abolishing PCAOB and FINRA, reducing transparency and investor protections. As of December 2025, the FEC proposals remain unimplemented; the FCC has advanced its agenda via rulemaking; the SEC rule is stayed by courts.

Project 2025’s proposals for the Federal Election Commission, authored by Hans von Spakovsky—who was blocked from an FEC seat in 2007 over his record on voting rights—would neuter campaign finance enforcement. By directing the Justice Department to prosecute only 'clear' violations of the Federal Election Campaign Act and opposing any change to the FEC’s partisan 3-3 deadlock, the plan ensures that the agency remains incapable of acting. This is a recipe for legitimizing dark money and Super PAC abuses: if the DOJ waits for the FEC to deadlock before pursuing any case, major election-law violations will go unpunished. The chapter’s refusal to even consider an odd-numbered commission means that partisan gridlock becomes the permanent default, not the exception.

The FCC chapter, already being implemented by Chairman Brendan Carr, weaponizes the agency for First Amendment retaliation. Carr has used Project 2025’s blueprint to launch a Section 230 reinterpretation that would let the FCC punish platforms for moderation decisions the administration dislikes, and he has moved to eliminate broadcast ownership caps—a move that concentrates media power in fewer hands. His push to ban TikTok, though partially blocked by courts, signals a broader willingness to use national security claims to suppress speech platforms the administration opposes. These actions, paired with Carr’s elimination of net neutrality rules in July 2025 without public comment, show that the FCC is being repurposed as an arm of political censorship rather than a neutral regulator.

The SEC chapter, authored in Chapter 27 by David R. Burton, would dismantle investor protections in the name of capital formation. The proposed abolition of the Public Company Accounting Oversight Board and FINRA removes essential oversight of auditors and broker-dealers, while rescinding the climate disclosure rule eliminates transparency on how public companies manage environmental risks. Burton’s agenda, which he has testified for repeatedly before Congress, prioritizes deregulation that benefits large corporations and dark-money donors at the expense of individual investors and market integrity. Together, these three chapters form a coherent assault on the mechanisms that ensure elections are fair, markets are transparent, and speech is protected.

Rollback path — how this gets undone

This action has already been implemented. These are the concrete levers that could reverse it.

  1. FCC-led Section 230 reinterpretation to restrict platform immunity for content moderation Future FCC majority rescinds the reinterpretation; Congress passes Section 230 reform that restores original intent
  2. Ban TikTok via FCC action Court ruling striking down the ban; future administration rescinds related EOs
  3. Eliminate net neutrality rules without notice-and-comment Future FCC restores Title II classification; CRA disapproval if Congress acts
  4. Rescind SEC climate disclosure rule; scale back capital-formation regulations Future Democratic SEC re-promulgates climate rule; Congressional Review Act if timing aligns

Original source — excerpted

project2025 Project 2025 ch. 29: Federal Election Commission (pp 859-863)

"— 826 — Mandate for Leadership: The Conservative Promise moderate content in good faith—“in a way that eliminates the expansive, non-tex - tual immunities that courts have read into the statute.” In addition to taking unilateral action, Carr says, the FCC should work with Congress on legislative changes to ensure that “Internet companies no longer have carte blanche to censor protected speech while maintaining their Section 230 protections.” Carr writes that during the Trump Administration, the FCC took an “appro - priately strong approach to the national security threats posed by the Chinese Communist Party.” The FCC put Huawei on its Covered List of entities—its list of those posing “an unacceptable risk” to U.S. national security. Carr writes that TikTok also poses a “serious and unacceptable” risk to U.S. national security, while providing “Beijing with an opportunity to run a foreign influence campaign by determining the news and information that the app feeds to millions of Americans,” and the next Administration should ban it. What’s more, Carr writes, “U.S. busi- nesses are aiding Beijing—often unwittingly”—in its effort to become, by 2030, “the global leader i…"