The grievance-driven blueprint for the next Trump administration

For the better part of this year, Project 2025 has been a catchall among Democrats for the threat former President Donald Trump poses to American society. The more than 900-page Mandate for Leadership, crafted by conservative think tank the Heritage Foundation, is a sprawling and often contradictory mix of ideas from more than 100 organizations. It’s tied together not by unified policy predictions but by a series of preoccupations: China; “wokeness”; climate denialism; and a commitment to gutting or abolishing federal agencies. It includes plans that would remake America’s approach to technology, but like many things in the document, its authors can’t exactly agree on how.

Trump has attempted to distance himself from the policy plan, but it’s tied to him by numerous threads. His running mate, JD Vance, is friends with Kevin Roberts, the president of the Heritage Foundation, and Vance even wrote the introduction to Roberts’ forthcoming book, Dawn’s Early Light. (The book’s publication, initially slated for September, was postponed until after the election.) And some of Project 2025’s chapters were written by Trump’s own former administration officials, including FCC commissioner Brendan Carr and Department of Homeland Security official Ken Cuccinelli. 

If Trump is elected, it’s highly likely that some of Project 2025’s ideas would be implemented — we just don’t know which ones. The most provocative proposals, like banning pornography, are prominently highlighted but never explained. Authors, in turn, recommend fighting and embracing tech companies. “I don’t think I’ve encountered a single person in America who agrees with 100 percent,” Roberts said at the Reboot Conference in San Francisco in September. “It’s like the menu at the Cheesecake Factory.” 

Much of what’s on the menu is notably less delicious. We’re not going to break down every piece of Project 2025 here — you can find more general guides at CBS News, which showed how many of Project 2025’s policy recommendations match Trump’s own; ProPublica, which obtained secret training videos created for Project 2025’s Presidential Administration Academy; and The New York Times, which interviewed several former Trump officials involved in the creation of Project 2025. Instead, we’re taking a look at how its recommendations would affect tech at every level, from how companies can hire foreign workers to the social media platforms we use every day.

Though there are some contradictions between and within chapters — signs of fissures or points of contention among the dozens of participating organizations — Project 2025 does, in the end, amount to a coherent vision. The document calls for a radical expansion of government power to punish conservatives’ enemies in tech, oust potential dissenters within the federal bureaucracy, and enforce right-wing wish list items like mass deportations and a national abortion ban. All of this would be combined with mass deregulation and the defunding of social services and federal agencies that contribute to the public welfare. Project 2025’s authors want small government for social goods — but big government for retribution.

Federal Trade Commission

Authored by: Adam Candeub, a professor of law at Michigan State University. Candeub served as the acting assistant secretary of commerce for telecommunications and information under Trump. From 2020 to 2021, he was the deputy associate attorney general in Trump’s Department of Justice. 

Project 2025’s FTC guidelines are perhaps the clearest example of conservative ambivalence toward tech. The section doesn’t actually offer a set of policy proposals. Instead, it outlines two diametrically opposed approaches: one where the Trump administration fiercely enforces antitrust law to break up monopolies; and another where it does barely anything at all.

In the enforcement route, Project 2025 suggests using the FTC to rein in major corporations, especially big tech companies. It puts forward the European Union’s “less friendly regulatory environment” as a good model, possibly referring to EU laws like the Digital Markets Act, which have forced tech companies to make major hardware and software changes to their products. It encourages the FTC to partner with state attorneys general to scrutinize or block hospital, supermarket, and big tech mergers. And it recommends that the FTC look into whether social media platforms’ advertising to and contract-making with children constitute unfair trade practices.

While there’s overlap with Democratic antitrust priorities here, there’s also a focus on clearly partisan concerns. The chapter suggests investigating whether social media platforms censored political speech in collusion with the government, following up on probes by the Republican-led House of Representatives and Republican state attorneys general. (Hunter Biden’s laptop, unsurprisingly, gets a mention.) You’ll also see references to issues like the “de-banking” of controversial figures, which the Trump family has cited as an inspiration for its mysterious crypto platform. “We are witnessing in today’s markets the use of economic power — often market and perhaps even monopoly power — to undermine democratic institutions and civil society,” the chapter claims.

Each of these points is contradicted by a long-standing conservative counterpoint: the government should let the market regulate itself. If the FTC regulates how children use internet platforms, for example, it could undermine conservatives’ calls for “parental empowerment on education or vaccines.” Expanding cooperation between the FTC and state attorneys general could “tie middle America to big progressive government.”

Ultimately, though, the chapter seems to favor intervention. Conservatives “cannot unilaterally disarm and fail to use the power of government to further a conservative agenda,” it warns, even if their goal is to do away with the regulatory state.

Federal Communications Commission

Authored by: Brendan Carr, a member of the Federal Communications Commission who was appointed by Trump in 2017.

Much of this chapter focuses on “reining in” major tech companies. Carr proposes a host of policies, including eliminating certain immunities under Section 230 of the Communications Decency Act and “clarifying” that Section 230’s key 26 words should only be used in cases about platforms failing to remove illegal material posted by users, not as a broader shield for moderation decisions.

Carr’s real concern is with social media platforms’ alleged suppression of conservative speech. The chapter suggests requiring “Big Tech” to follow net neutrality-like rules similar to those for broadband providers, like disclosure on practices such as blocking and prioritizing content. Platforms should also be required to “offer a transparent appeals process” when user content is taken down. 

The chapter also suggests that the FCC regulatory power should be expanded with “fundamental Section 230 reforms” that let it regulate how online platforms moderate content — or, in Carr’s words, “no longer have carte blanche to censor protected speech.” Carr describes Texas’ HB 20 — the law that forbids platforms from removing, demonetizing, or downlinking posts based on “viewpoint,” which set the stage for NetChoice v. Paxton — as a possible model for federal legislation.

As companies must stop “censoring” conservative speech, they’re supposed to restrict children from accessing certain social media platforms. Carr quickly notes that these views “are not shared uniformly by all conservatives,” but as is the case in other chapters, the notion of expanding government powers to punish right-wing opponents ends up winning out over a more laissez-faire approach.

Congress should also require big tech to pay into the FCC’s Universal Service Fund, which helps fund broadband access in rural communities and is currently funded by broadband providers. It’s another example of Project 2025’s movement away from Reagan-era “small government” conservatives in favor of punishing disfavored targets with more regulation. 

The chapter also recommends that the FCC and White House work together to free additional airwaves for commercial wireless services and generally do more to “move spectrum into the commercial marketplace.” Carr also recommends that the government build out internet infrastructure on federally owned land. The latter, however, can’t be accomplished by the FCC alone, and Carr notes that it would require working with the Bureau of Land Management and the Forest Service, among other agencies. The chapter also recommends that the FCC more quickly review and approve applications to launch new satellites, specifically for the purposes of supporting StarLink, Kuiper, and similar efforts.

And then there’s China. One of the primary recommendations is that the FCC “address TikTok’s threat to national security.” (Congress has, since the time the Mandate for Leadership was published, done just that by attempting to ban the app unless it divests from its parent company, ByteDance; whether the courts will let that happen remains to be seen.) Others include creating a more regular process to review entities “with ties to the CCP’s surveillance state” and stopping US entities “from indirectly contributing to China’s AI goals.”

Financial regulatory agencies

Authored by: David R. Burton, a senior research fellow in economic policy at the Heritage Foundation; and Robert Bowes, a senior adviser to the assistant secretary of the Department of Housing and Urban Development under Trump and former adviser to Trump aide Stephen Miller.

While other sections are often ambivalent about government regulation, this chapter straightforwardly suggests giving major concessions to cryptocurrency and loosening restrictions on who can invest in private companies.

Anyone who’s been following Trump’s attempts to court the crypto community should know what’s coming here. There are a host of recommendations for the Securities and Exchange Commission, which the authors say has “chosen regulation by enforcement” for cryptocurrency. The biggest change would be redefining digital assets as commodities, instead of securities, so they’re no longer regulated by the SEC.

The chapter also recommends making private capital raising less restrictive by changing a rule known as Regulation D. Under Regulation D, companies can raise unlimited funds for securities from an unlimited number of “accredited investors,” with no disclosure needed to the SEC. “Accredited investors” must currently have a salary of $200,000 (or $300,000 combined with their spouse) or a net worth of at least $1 million, excluding their primary residence. As of 2022, more than 24 million American households met these requirements. Project 2025 recommends broadening these qualifications or eliminating them altogether.

In practice, this would let anyone invest in any private company, not just — as the rule stands today — companies on the public market. To go public, companies have to meet certain requirements and file a registration statement with the SEC, where they’re subject to reporting requirements. In exchange, they currently get access to a much broader pool of potential investors. Eliminating the accredited investor requirement would effectively allow companies to skirt the requirements of going public — and the oversight they’re subject to afterward.

Department of Commerce

Authored by: Thomas F. Gilman, the director of ACLJ Action, a conservative organization affiliated with the American Center for Law and Justice. Gilman was the chief financial officer and assistant secretary for administration of the US Department of Commerce under Trump.

This sprawling chapter touches on nearly every major Project 2025 theme, from fears of China to the “alarm industry” of federal climate monitoring. Like practically every other section, it recommends expanding the federal government’s reach if it will advance conservative interests and doing away with any agencies that don’t.

In keeping with the goal of dismantling federal bureaucracies, this chapter suggests doing away with the National Oceanic and Atmospheric Administration (NOAA), which it says should be privatized or placed under the control of states and territories. Other agencies, like the National Weather Service (NWS) and Office of Oceanic and Atmospheric Research, would be severely downsized. (In a statement provided to the Los Angeles Times, Steven R. Smith, the CEO of AccuWeather — which Project 2025 suggested could replace the NWS — said AccuWeather’s forecast engine partly relies on NOAA data.) These agencies provide the data used in weather forecasts accessed by millions of Americans each day and also give the public crucial information about impending hurricanes, heatwaves, and other natural disasters and extreme weather events. 

The Republican libertarian wing may get its goal of privatizing federal agencies, but most of this chapter argues for more — not less — government interference in the market. Noting that China has made significant advances in semiconductor design, aerospace technologies, and other crucial industries, it recommends new rules to prevent tech transfer to foreign adversaries. It also suggests an executive order expanding the Export Control Reform Act of 2018 to restrict exports of Americans’ data. And it opposes intellectual property waivers for “cutting-edge technologies” like covid-19 vaccines — which an earlier chapter says the Centers for Disease Control and Prevention shouldn’t encourage people to get — through international agreements. These waivers, which were hotly debated for years following the onset of the pandemic, give low- and middle-income countries access to life-saving immunizations, though advocates say more needs to be done to achieve global vaccine equity.

The chapter also suggests adding certain app providers — including WeChat, TikTok, and TikTok’s parent company, ByteDance — to the entity list, which would prevent the apps from issuing program updates in the US, effectively making them nonoperational. The Heritage Foundation apparently didn’t get the memo that Trump loves TikTok now.

Department of Transportation

Authored by: Diana Furchtgott-Roth, director of the Heritage Foundation’s Center for Energy, Climate, and Environment.

Unlike other chapters that are openly antagonistic toward tech companies, this chapter suggests partnering with the private sector to “revolutionize travel.” There’s an emphasis on private transportation over public transportation — not just in terms of opposing government funding for mass transit but also supporting ridehailing apps, self-driving vehicles, and micromobility, which only gets a passing mention in the chapter but likely refers to e-bikes and electric scooters.

Current policies, the document says, “strangle the development of new technologies” like drones. Instead, the DOT should encourage the use of small aircraft for air taxis or for quiet vertical flights. It should also push for a shift to digital or remote control towers for planes, letting flights be managed “anywhere from anywhere.”

Department of the Treasury

Authored by: William L. Walton, a trustee of the Heritage Foundation and the founder and chair of the private equity firm Rappahannock Ventures LLC; Stephen Moore, a visiting fellow in economics at the Heritage Foundation; and David R. Burton, a senior research fellow in economic policy at the Heritage Foundation.

Under Project 2025, the US would effectively abandon its commitment to stopping climate change. The chapter suggests getting rid of the department’s Climate Hub office and withdrawing from international climate change agreements, including the Paris agreement and the United Nations Framework Convention on Climate Change. Instead of focusing on clean energy or climate change-resilient infrastructure, the chapter suggests that the government should invest in domestic energy, especially oil and gas.

Like several other sections, this chapter takes aim at “wokeness” and diversity, equity, and inclusion (DEI) programs. As part of Project 2025’s plan to gut the federal workforce, it suggests identifying all Treasury officials who have participated in DEI initiatives, publishing their communications about DEI, and firing anyone who participated in DEI initiatives “without objecting on constitutional or moral grounds.”

Department of Health and Human Services

Authored by: Roger Severino, a vice president at the Heritage Foundation and former director of its DeVos Center for Religion and Civil Society, who served as the director of the HHS’s Office of Civil Rights under Trump.

The bottom line: Project 2025 would limit the government’s ability to do basic health governance while setting up a surveillance state for pet conservative issues like abortion and gender-affirming care for trans people. 

Much of the HHS chapter focuses on the Centers for Disease Control and Prevention’s response to covid-19, which the author characterizes as near totalitarian. The chapter recommends barring the CDC from saying that children should be masked or vaccinated against any illness and says that the CDC should be investigated for “colluding with Big Tech to censor dissenting opinions during Covid.” The author also suggests moving several CDC programs — including the Clinical Immunization Safety Assessment project, which researches vaccine safety — to the Food and Drug Administration.

Unsurprisingly, abortion would be severely restricted. Under Project 2025, the FDA would reverse the approval of pills that facilitate medication abortions, which the document calls the “single greatest threat to unborn children.” The FDA would also eliminate policies allowing people to order abortion pills by mail or online. As the CDC would stop encouraging vaccinations — which some conservatives believe infringe on bodily autonomy — the agency would increase its surveillance and recordkeeping of abortions and maternal mortality. This includes a recommendation that the HHS “use every available tool, including the cutting of funds” to force states to report “exactly how many abortions take place within its borders.” 

A separate study, through the National Institutes of Health, is recommended to investigate the “short-term and long-term negative effects of cross-sex interventions,” i.e., gender-affirming care. The report also recommends using AI to detect Medicaid fraud, which costs the US an estimated $100 billion a year and is typically perpetrated by healthcare providers, not individual beneficiaries of public healthcare.

Department of Homeland Security

Authored by: Ken Cuccinelli, who served in various capacities under Trump, including as the director of US Citizenship and Immigration Services and, later, the “senior official performing the duties of the Deputy Secretary of Homeland Security.”

Perhaps counterintuitively given Republicans’ laser focus on the US border, Project 2025 recommends abolishing the Department of Homeland Security. The goal, though, is to replace it with the Border Security and Immigration Agency, a new, more draconian, and less accountable immigration enforcement apparatus. 

The Transportation Security Administration (TSA) would be privatized, and the Coast Guard would be moved to either the Department of Defense or the Department of Justice. Dismantling the DHS almost certainly won’t happen — it would require an act of Congress, and lawmakers haven’t passed an immigration bill in decades.

Project 2025 doesn’t just recommend more stringent restrictions on unauthorized immigration; it also lays out a vision of severely restricted legal immigration. It recommends scrapping the family-based immigration system that has been in place since 1965 and replacing it with a “merit-based system that rewards high-skilled aliens.” Other suggestions include eliminating the diversity visa lottery and altering the work visa system. This, too, would largely require congressional action. 

As it prioritizes “merit-based” immigration to the US, the chapter proposes limiting foreign students’ ability to study here. In a move that (unlike much of this chapter) could be accomplished through executive action, it proposes ending what it calls Immigration and Customs Enforcement’s (ICE) “cozy deference to educational institutions,” i.e., the issuing of student visas to most foreign students admitted to US universities. It also calls to “eliminate or significantly reduce the number of visas issued to foreign students from enemy nations” — implicitly, China.

Intelligence community

Authored by: Dustin J. Carmack, Meta’s director of public policy for the Southern and Southeastern US. Carmack, a former research fellow at the Heritage Foundation, was the chief of staff for the Office of the Director of National Intelligence under Trump from 2020 to 2021.

Concerns about China are far more explicit in this chapter, which looks at the “vast, intricate bureaucracy of intelligence agencies within the federal government.” The chapter raises the threat of Chinese (and to a lesser extent, Russian) espionage, online influence campaigns, and “legitimate businesses serving as collection platforms,” a possible allusion to TikTok. The Mandate for Leadership recommends amending Executive Order 12333 — which was signed by President Ronald Reagan in 1981 and, among other things, authorizes mass data collection for intelligence purposes to address the threats the US and its allies face “in cyberspace.”

But the chapter also claims intelligence agencies have dedicated far too much time to surveilling the former president, which allegedly proves a “shocking extent of politicization” among the agencies and the officials who lead them. (Its evidence includes the letter signed by 51 former intelligence officials ahead of the 2020 US presidential election claiming that the story about Hunter Biden’s laptop was likely a Russian information operation.) The author calls for an investigation into “past politicization and abuses of intelligence information.” 

The chapter also recommends that Section 702 of the Foreign Intelligence Surveillance Act (FISA) — the controversial law allowing warrantless wiretapping that was reauthorized earlier this year — be reformed with “strong provisions to protect against partisanship,” pointing to the use of FISA to surveil former Trump campaign associate Carter Page as part of the FBI’s investigation into Trump’s ties to Russia. There is little mention of how these vast surveillance powers affect regular people. In fact, the chapter notes that an independent review found that Section 702 surveillance powers were “not abused,” though it does recommend that Congress review further reports to determine whether any FISA reforms are needed.

Buried amid all these claims, it also recommends the Department of Defense examine the possibility of joint satellite and space programs with “potential allied nations” to counter the threat posed by Russia and China. Additionally, it suggests agencies spy on the space programs of foreign adversaries and collect more data on adversaries’ potential threats to US space programs.

Media agencies

Authored by: Mora Namdar, a former State Department official who worked as a senior policy adviser and acting assistant secretary of state in consular affairs under Trump; and Mike Gonzalez, a former journalist and current senior fellow at the Heritage Foundation.

These agencies aren’t as consequential as juggernauts like the FTC, but the usual slash-and-burn recommendations apply. Project 2025 encourages undercutting the Open Technology Fund, a subagency within the US Agency for Global Media dedicated to protecting free speech around the world that has funded open-source projects like Signal. It calls the OTF a “wasteful and redundant boondoggle” that makes “small, insubstantial donations to much larger messaging applications and technology to bolster its unsubstantiated claims” and — contra its name and stated mission — suggests it fund closed-source technology instead.

The chapter also notes that there is “vast concern” about the vulnerability of undersea cable trunks that power the internet and says that major global conflict could cause widespread damage to these cables, potentially leading to long-lasting power outages. There is no mention of what can be done to prevent this, though the chapter does say that the US Agency for Global Media’s shortwave radio capabilities could help carry broadcasts and maintain communication in areas where online traffic is limited or restricted.