Research Reports / Authorization and implementation

Project 2025: who gave the instructions?

The historical movement and published blueprint are established. This report follows named individuals and actual government paperwork to distinguish a recommendation from a signed order, an implementing memo, a final agency action, and its legal status.

Verified through November 11, 2026 · Five proposal-to-instruction comparisons and one additional agency-action case · Primary sources below · The Story is unchanged.

What counts as proof of direction?

Every chain records published proposal → person responsible for the proposal → presidential authority → named implementing official and document → action or agency response → what remains unverified. The original Heritage program described four separate pillars: policy, candidate database, training and nonpublic agency playbooks. Its May 2023 partner list includes America First Legal, Center for Renewing America, CPI, American Moment and Personnel Policy Operations, establishing an actual shared planning coalition. It does not list DOGE, and the records reviewed here do not establish that Peter Thiel or Elon Musk authored the Mandate. [1] [2]

Decision-making is not one kind of power: authors can propose policy, presidents can sign orders, OMB/OPM can issue government-wide implementation guidance, agency heads retain statutory responsibilities, and courts can review contested actions. A document proving one level does not automatically prove a person controlled the next.

Decision chain 01 · Authorizing and instructing agencies

Federal workforce reductions and DOGE: Vought and Ezell signed the instructions

Before government: policy development

Project 2025's chapters on the White House, central personnel agencies and federal workforce proposed stronger executive personnel management and changes to career positions. Russ Vought authored Chapter 2. The exact February 2025 DOGE reorganization process was a separate presidential initiative, not a published verbatim provision of the 2023 book. [1]

February 11: presidential order

Trump's Executive Order 14210 directed agency heads to prepare for large-scale reductions in force and develop reorganization plans, with agency DOGE team leaders consulted on various matters. Agency heads and OMB were named in the formal mechanism. [7]

February 26: named implementation authors

Vought, as OMB director, and Charles Ezell, as acting OPM director, jointly issued a six-page memorandum. It required Phase 1 plans by March 13 and Phase 2 plans by April 14, both to OMB and OPM for review and approval, with subsequent monthly progress reports. It specifically told agency heads to work with their DOGE team leaders. [8]

Where final approval must be proved

OMB/OPM required direct-service components to await certification of a positive effect on service delivery; agencies retained obligations under applicable law. A court dispute later established that agencies had produced plans, but the government said the plans and their review were not automatically final agency personnel decisions. The Supreme Court stayed a preliminary injunction without resolving the legality of individual agency plans. [8] [9]

Chain status: official instruction documented; individual agency-level implementation requires its own authorization record. To trace an individual reduction, obtain that agency's submitted ARRP, OMB/OPM response or certification, the agency head's final RIF authorization and subsequent outcomes. This chain directly connects Vought, OPM and agency DOGE teams; it does not establish Musk personally signed any agency's RIF.

Later authority chain · October 2025–October 2026

From annual staffing policy to hiring-system access

Separate from the February DOGE reorganization plan: Executive Order 14356 (October 15, 2025) was implemented through a November 5 memorandum jointly signed by OMB Director Russell Vought and OPM Director Scott Kupor. It set a December 1 deadline for FY2026 annual staffing plans, a November 17 deadline for Strategic Hiring Committees, and later reporting/amendment processes. Its OPM notice contact is staffing@opm.gov, distinct from the earlier ARRP contact. The submission framework does not prove any specific agency plan was approved.

OPM's July 30, 2026 bulletin established an FY2027 staffing-data workflow through Collect.opm.gov and warned that non-submitters' USA Staffing access would be locked beginning October 1 pending submission and OMB/OPM approval. That is a published administrative enforcement tool, not evidence it was activated for a particular agency. The bulletin lists Matthew Davis as an access contact, not an approving officer. This later workflow does not identify who handled FEMA's FY2026 December 2025 staffing target.

The court-tested FEMA case compares these processes with the actual DHS instruction, an 11,383-position proposal, OMB/OPM notification and the judgment of unlawful DHS personnel control.

Decision chain 02 · Specific Project 2025-to-government match

Independent-agency regulation: Vought's published recommendation became an executive order

  1. 2023 proposal: Vought's Executive Office chapter (Chapter 2, printed p. 49) proposed applying OIRA review and White House oversight to historically independent regulators. [1]
  2. February 18, 2025 presidential authorization: Trump signed Executive Order 14215, directing independent agencies to submit significant proposed and final regulations for OIRA review. The order also assigned OMB a role in independent-agency planning and apportionments, with specified statutory limitations. [3]
  3. April 17 implementing official: Jeffrey Bossert Clark, acting OIRA administrator, signed OMB memorandum M-25-24 detailing the procedures through which historically independent regulators would submit actions for executive regulatory review. [4]

Chain status: specific policy-to-order match and named implementing official verified. The public documents do not identify the private drafter of EO 14215, nor do they demonstrate how every individual rule changed. To establish outcomes, compare the OIRA review records, change/return letters, final rules and legal challenges for particular agencies.

Decision chain 03 · Explicit DOGE–OMB regulatory coordination

Deregulation: a presidential order named DOGE leaders and Vought's OMB together

  1. February 19, 2025 order: Executive Order 14219 instructed agency heads to review regulations in coordination with their DOGE team leaders and the OMB director. It required submission of identified regulations to OIRA and provided procedures concerning federal regulatory enforcement. Military, national-security, homeland-security and immigration functions were exempted. [5]
  2. April–May executive implementation: Jeffrey Clark signed OMB M-25-28 dated May 7. It explained which potential repeals to prioritize, told agencies how to document a decision not to repeal a rule, and referred to the February DOGE regulatory order and an April 9 presidential memorandum. [6]
  3. Identifying actual decisions: Each final rescission, rulemaking record and enforcement termination must be examined separately to identify the responsible agency head, the OIRA review, statutory authority and whether a court later constrained it.

Chain status: direct, written OMB–DOGE coordination ordered by the president and implemented through a named official. This is a documented connection between DOGE and the OMB branch of the administration. It is not evidence of a DOGE-led independent repeal power; the order preserves agency-head duties and legal constraints.

Decision chain 04 · Civil-service reclassification

Schedule Policy/Career: from an earlier staffing blueprint to positions identified by presidential order

  1. 2023 published planning: Project 2025's White House and personnel chapters called for stronger presidential personnel control, including use of a Schedule F-style category. [1]
  2. January 20, 2025 order: Trump signed EO 14171 establishing the Schedule Policy/Career framework. [10]
  3. February 2026 rule and responsible official: OPM, led by Scott Kupor after July 2025, finalized a regulation and sent implementing guidance. The positions remain merit-based career positions but have altered procedural removal and appeal protections. [11]
  4. June 3–8, 2026 actual action: EO 14410 identified agency-specific positions for placement in the category. Kupor's June 8 memorandum instructed agencies to notify affected employees and update records accordingly. [12] [13]

Chain status: specific policy match, operative executive orders, final rule and agency implementation guidance. The White House described approximately 8,000 affected positions; this is an administration figure, not an independent audit of every personnel action. The position-specific implementation and any legal disputes remain separate evidence questions.

Decision chain 05 · Immigration authority

Expedited removal: who proposed it, and who signed the operative notice?

  1. 2023 proposal: Ken Cuccinelli, author of Project 2025's DHS chapter, urged broader use of expedited removal, alongside extensive structural changes to immigration agencies. [1]
  2. January 21, 2025 federal authorization: Benjamine C. Huffman, acting DHS secretary, signed the expanded expedited-removal designation; it was published January 24 in the Federal Register and had immediate effect. This is a named, legally designated official who authorized the agency action. [14]
  3. Judicial treatment: A June 23, 2026 D.C. Circuit decision vacated a stay of the expanded designation. The ruling does not resolve the correctness of every individual enforcement action or establish who drafted the policy internally. [15]

Chain status: blueprint-to-signed-agency-action alignment. Stephen Miller had White House immigration responsibilities, and his co-founded America First Legal was a Project 2025 coalition partner. Neither fact makes Miller the signatory or proves he personally instructed Huffman on the January designation. No legislation has dismantled DHS as Project 2025's principal organizational proposal suggested.

Applied agency chain 06 · The action went beyond the published Project 2025 proposal

USAID: OMB and State planning, Rubio's authority delegation, Lewin's signed personnel action

Textual comparison: Max Primorac's 2023 Project 2025 USAID chapter proposed extensive programmatic and leadership reform, not the total operational closure later pursued. Do not classify closure as a verbatim instruction from the published blueprint. [1]

  1. Executive and departmental planning: In an October 2026 evaluation, the State Department Inspector General said State and OMB initiated a foreign-assistance review and the process to close USAID and transfer select functions. This confirms an OMB-to-agency planning connection independently of the private drafting history. [19]
  2. March 18, 2025 delegated authority: WIRED's October 27, 2026 investigation examined appointment documents and court filings showing Secretary of State and acting USAID administrator Marco Rubio delegated deputy-administrator/COO functions to Jeremy Lewin, a DOGE-associated official. Internal USAID HR/security records reviewed by WIRED did not show normal onboarding was complete. Lewin says Rubio lawfully dual-appointed and detailed him with counsel's advice; the legal implications remain disputed. [20]
  3. March 28 personnel action: WIRED reported Lewin signed a letter terminating remaining USAID staff. Separately, the USAID Inspector General confirms that State informed Congress on March 28 that USAID would cease operating independently, with certain functions moving to State by July 1. These are distinct personnel and institutional actions, not one document. [20] [21]
  4. Independently measured outcome: GAO's September 30, 2026 audit reports USAID staffing declined from roughly 13,600 in January 2025 to 241 in April 2026, and that around 6,780 of 7,510 USAID awards were terminated by March 2026. GAO found significant gaps in State's documentation for funding and workforce decisions. The $79.1 billion cumulative obligated value of terminated awards is not a proven cash-savings figure. [22]

Chain status: A public inspector-general review confirms a State–OMB planning connection, reporting documents Rubio's delegation and Lewin's signature, and the GAO audit measures consequences. These documents do not establish Vought personally authorized Lewin's appointment, Musk personally signed the terminations, or Thiel directed USAID. Lewin's authority was litigated and contested; reporting allegations are not a final judicial finding. Further DOGE and Lewin records.

Court-tested agency decision · Sept. 11, 2026

FEMA: a specific DHS instruction, a proposed 50% cut and judicial findings

Order and recipients: In AFGE v. Trump, the Northern District of California traced the proposed roughly 50% cut in FEMA staffing to DHS, identifying Deputy Chief of Staff Joseph Guy and adviser Kara Voorhies as likely sources of the instruction to acting FEMA leader Karen Evans. Evans submitted a December 4, 2025 plan for 11,383 positions; her notes recorded calls with Guy and Voorhies. FEMA's own program and regional staffing assessments had sought 24,812 and 23,146 positions, and human capital officer La’Toya Prieur had not approved the 50% plan. Read the Sept. 11 summary-judgment order, Doc. 491.

OMB/OPM cross-reference: The order quotes a December 17, 2025 Evans email that approximately 11,500 positions had been communicated to OPM and OMB at a high level. That demonstrates notification, not identified recipients or approval. The December FEMA annual staffing plan is not automatically the same document as the earlier March/April Agency RIF and Reorganization Plans directed by Vought and Ezell. These remain separate document streams until connected through actual records. Read OPM's February plan-submission guidance.

Effect and legal status: Some CORE disaster-response employees received nonrenewal notices. The district court ruled DHS unlawfully took control of FEMA personnel authority and that FEMA unlawfully acquiesced; it found the plan arbitrary and capricious. A separate September 11 order found Evans intentionally deleted relevant Signal chats and imposed adverse-evidence sanctions, while not attributing the same deletion intent to Guy. These were court findings, not merely allegations. Read records-preservation ruling, Doc. 490.

Unresolved origin: The court identified an internal DHS-to-FEMA instruction path, but the exact source of the numerical target, any OMB/OPM signoff, and any direct 2025 order by Miller, Vought, Musk or Thiel remain unestablished. Read the dedicated court-evidence case report.

How the four-person hypothesis fits these records

Russell Vought: blueprint author and implementation signatory

He authored the 2023 Executive Office chapter, served as OMB director, signed the DOGE workforce implementation memorandum with Ezell, and held OMB coordination duties under other DOGE orders. These are primary-source relationships. [1] [8] [16]

Stephen Miller: policy office, coalition and later chief of staff

Miller's America First Legal was a named Heritage coalition partner. Reuters later reported Miller, Vought and White House counsel coordination on executive actions in 2026. This adds a reported direct planning relationship but not personal authorship of the 2025 memos listed here. [2] [17]

Elon Musk and DOGE: agency-level operations

Executive Order 14158 created agency DOGE teams. EO 14219 and the Vought/Ezell memorandum expressly tied agency DOGE team leaders into OMB-related regulatory and staffing processes. GAO records Musk's White House advisory role, distinct from the formal USDS administrator. [18] [5] [8] [16]

Peter Thiel: related network, not named signatory

Palantir, co-founded by Thiel, worked with DOGE-associated personnel on an IRS project and later received an IRS API contract; the separate IRS/DHS case report documents the chain. The 2023 Project 2025 book and government memos in this report do not establish that Thiel directed them or that the Palantir contract was specified by the Heritage blueprint.

Overall finding: Specific published proposals became signed executive policies, and the administration created an identifiable mechanism linking DOGE teams, OMB, OPM and agency heads. The records do not establish that all four men formed one documented decision-making committee or personally approved the same agency actions. Those are additional propositions requiring communications, meeting records and named approvals.

The evidence that would decide the open questions

Five concrete missing record types: (1) agency Phase 1/2 reorganization plans and OMB/OPM approvals; (2) named DOGE team leaders and their written communications with agency heads and OMB; (3) OIRA review histories showing who requested changes to specific regulations; (4) Project 2025's unpublished agency playbooks and personnel-to-position placement records; (5) agency-specific contract approvals, data-access authorizations and outcome audits. The existence of executive-review mechanisms is established. A common source of private orders across all four people is not.

Evidence that narrows an overly broad inference: The official 2025 workforce memo exempted immigration enforcement and several public-safety functions from its general reductions. The DOJ's 2026 organizational chart still showed the FBI beneath the Deputy Attorney General, unlike one Project 2025 recommendation. The Department of Education and DHS had not been abolished by Congress. Different executive plans, including Trump's own earlier priorities and AFPI work, can also explain some overlapping policies.

Return to the Project 2025 blueprint report · DOGE agency procurement and data case · USDS / DOGE Encyclopedia

Original documents and independent reporting

  1. Heritage, Mandate for Leadership, 2023 (original full text, archived by U.S. Senate)
  2. Heritage May 2023 public Project 2025 coalition partners
  3. Executive Order 14215 — Ensuring Accountability for All Agencies, Feb. 18, 2025
  4. OMB M-25-24, April 17, 2025, signed by acting OIRA administrator Jeffrey Clark
  5. Executive Order 14219 — DOGE Deregulatory Initiative, Feb. 19, 2025
  6. OMB M-25-28, May 7, 2025 — Jeffrey Clark's DOGE deregulatory guidance
  7. Executive Order 14210 — DOGE Workforce Optimization, Feb. 11, 2025
  8. OMB/OPM joint RIF and Reorganization Plans memo, Feb. 26, 2025, Vought and Ezell
  9. Ninth Circuit, AFGE v. Trump & related discovery dispute, Sept. 19, 2025
  10. Executive Order 14171 — Schedule Policy/Career framework, Jan. 20, 2025
  11. OPM final Schedule Policy/Career rule announcement, Feb. 5, 2026
  12. Executive Order 14410 — identifies affected positions, June 3, 2026
  13. OPM June 8, 2026 memo — signed by Scott Kupor
  14. DHS expedited-removal designation — Jan. 21, 2025, signed by Benjamine Huffman
  15. D.C. Circuit June 23, 2026 expedited-removal opinion
  16. GAO August 2026 report on DOGE personnel, OMB coordination and legal roles
  17. Reuters Nov. 1, 2026 report on Miller, Vought and White House legal planning
  18. Executive Order 14158 — January 20, 2025 DOGE creation, agency staffing and reporting
  19. State OIG, October 2026 — State and OMB jointly initiated USAID closure/review process
  20. WIRED, October 27, 2026 — Rubio delegation, Lewin authority and personnel action, contested HR record
  21. USAID Inspector General, November 3, 2026 — March 28 congressional notification and outstanding awards
  22. GAO, September 30, 2026 — foreign-assistance workforce, awards and State guidance findings

Public inclusion documents roles, actions and sourced connections; it is not a conclusion about criminal liability, hidden command, or whether every official act was lawful.