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What companies can expect in the first 100 days of the new Trump administration
President Donald J. Trump became the 47th president on January 20, 2025, and with his inauguration comes a wave of policy changes that will affect business.
On February 1 under the International Emergency Economic Powers Act (IEEPA), the president announced tariffs of 25% on Canada and Mexico and an additional 10% tariff on China over illegal immigration and the flow of fentanyl. Energy imports from Canada would face a 10% tariff. All tariffs were set to take effect as of February 4, 2025, but tariffs on Mexico and Canada were postponed one month after the countries agreed to providing more border security. China retaliated with tariffs on some US imports. The situation continues to evolve. Canada, Mexico and China the three biggest trading partners for the US.
In a series of executive orders (EOs) in his first days in office, President Trump announced actions his administration would take to reshape energy and immigration policy, including withdrawing the US from the Paris Agreement on global warming, declaring a national energy emergency to speed permitting and a national emergency at the southern border. He also signed EOs revoking a number of EOs from former President Joseph Biden, as well as a memorandum aimed at fighting inflation.
Beyond the wave of EOs, President Trump’s inauguration also marks the beginning of action on a significant “must-pass” tax bill, as his administration and the Republican-controlled Congress face a December 31, 2025, deadline to extend key 2017 Tax Cuts and Jobs Act (TCJA) individual, business and international provisions set to expire or change at the end of the year.
The first 100 days of President Trump’s second term will offer hints of what his policy outlook will be, how he plans to implement changes and the implementation timeline. These changes come as the US economy has shown signs of momentum, though the president’s tax and trade policies could have implications on growth.
Tax executives should prepare for intensive tax discussions but, at the same time, temper expectations for immediate changes within the first 100 days. Within this timeframe, we’re most likely to see a budget resolution — by February or March — that will set the parameters for the anticipated tax bill. Major legislation addressing expiring provisions of the 2017 Tax Cuts and Jobs Act (TCJA) and President Trump’s campaign tax proposals may not emerge until the second half of 2025.
The new administration and Republican leaders in Congress are still debating whether to do one or two reconciliation bill packages to address tax issues, immigration and border security, energy production and mandatory spending cuts during the calendar year. Reconciliation bills require the approval of a budget resolution with reconciliation instructions for the committees that would be responsible for drafting legislation. An FY25 reconciliation bill would have to be completed before September 30, when the federal government’s fiscal year will end.
With narrow Republican margins in Congress, passing Trump’s campaign proposals — such as cutting the corporate rate to 15% from 21% for US manufacturers and reinstating 100% bonus depreciation — could be challenging. Extending just the expiring individual provisions of the TCJA would add about $4 trillion to the federal debt over the following 10 years, according to the Congressional Budget Office.
The president has said revenue from higher tariffs could be used to offset some of the cost of his tax proposals. Existing statutes give the administration significant authority to unilaterally impose or increase tariffs, but broader measures aimed at generating revenue for tax reform may require Congressional approval. It’s unclear whether Republicans would want to vote on specific tariff measures that might increase the price of goods on their constituents.
The US response to OECD’s Pillar Two global minimum tax remains in question. On January 20, President Trump issued an EO directing the Treasury secretary, US Trade Representative and permanent representative to the OECD to notify the organization that commitments the prior administration made “with respect to the global tax deal have no force or effect within the US absent an act by the Congress adopting the relevant provisions of the global tax deal.”
While the Trump administration and Congress may consider retaliatory measures against Pillar Two measures that are seen as unfairly targeting US companies, US multinationals operating in jurisdictions that have implemented Pillar Two-inspired minimum taxes in the meantime will be subject to their requirements, including considerable reporting obligations.
What should your company be doing now?
- Prepare as key legislation looms. Whether it’s one reconciliation bill that would cover immigration and border security, tax issues and spending, or a two-bill strategy to “get something passed as quickly as possible,” it will be important to model various scenarios to understand how potential shifts could affect your cash flow, investments and overall tax liabilities.
Model and unify strategies for tariff resilience. Engage in flexible modeling to understand the effect potential tariffs may have, assess production and sourcing strategies, integrate customs and tax planning and monitor and model potential retaliatory actions.
Continue to monitor legislative developments. While House Ways and Means Chairman Jason Smith (R-MO) said Republicans on the committee will reintroduce the Defend American Jobs and Investment Act, a retaliatory measure aimed at Pillar Two, the clock cannot be turned back completely as other countries continue to move forward with the global minimum tax. The evolving political landscape over the next several months will be a critical factor in shaping the future of these tax policies.
Get on the calendar. Engage with policymakers to build public support for tax and trade policies that promote growth and business investment. This is an opportunity to convey the impact policy will have on the US economy and job creation.
Executive call-to-action
| Tax leader | Model the potential effects of a 2025 tax bill. Estimate your increased tariff exposure based on various potential changes to US tariffs for China, Mexico and the rest of the world. Evaluate the impact this could have on growth. Work with the C-suite to mitigate the potential effects these changes will have on your broader business strategy, including operational considerations such as sourcing. |
| CFO | Create short- and long-term scenario models to address potential impacts from tax reforms and tariffs. Engage with policymakers and maintain transparent communication with the C-suite to champion a unified approach to evolving policies. |
| COO | Capture value through value chain transformation, working with tax executives on indirect tax simplification and planning. Assess the impact of potential manufacturing, supply chain and trade changes considering tariffs. Begin identifying alternate sourcing channels for areas with significant impacts. |
| CEO | Call on members of Congress who are trying to build consensus on tax legislation. Provide insights and information lawmakers need to consider when crafting tax policies to promote job creation and economic growth. |
| Board | Encourage management to provide enhanced reporting on tax legislation efforts. |
The next 100 days will be pivotal as the details of President Trump’s trade policy unfold. On February 1, the administration issued EOs announcing 25% tariffs on imports from Canada and Mexico and an additional 10% tariff on China. Canadian energy imports would face a 10% tariff. The tariffs, aimed at stemming illegal immigration and the flow of fentanyl, were set to go into effect February 4, but President Trump agreed to a one-month delay for Mexico and Canada after the countries agreed to reinforce their borders. China retaliated with a 15% tariff on liquefied natural gas and coal imports from the US and a 10% tariff on crude oil, agricultural machinery, pickup trucks and large-engine cars. The situation remains fluid for all affected countries and is evolving as negotiations continue.
There will be no exemptions, and the tariffs could expand or increase if any of the countries retaliate, according to the White House orders. Canada and Mexico quickly responded by announcing retaliatory tariffs on US products. China said it would file a complaint with the World Trade Organization.
The tariffs had been a looming threat. In his first days in office, President Trump also signed an EO directing federal agencies including the US Trade Representative to review US trade policies. While the president used EOs under the IEEPA for these tariffs, any other tariffs aimed at offsetting tax costs may require Congressional action.
These moves have significant implications for global supply chains. Expect considerable disruption and uncertainty for US importers. We’re already seeing a confluence of issues across tax, transfer pricing, supply chain and investment strategies. Companies that rely on global sourcing should continue to assess scenarios, weigh options and stay agile as they adapt to the evolving trade environment.
What does this mean for your company?
- Use data to drive decisions. Multinationals should evaluate how tariffs could affect annual operating profits. Data-driven insights are critical to help identify viable options to move forward. Pre- and post-scenario analyses can help you understand the impact down to the individual import.
Trade and customs. Identify tariff recovery measures. Leverage foreign trade zones or bonded warehouses to minimize cash flow and potential duty deferral benefits. Use programs such as duty drawbacks, if available. Consider changing to a lower duty tariff code via product or packaging modifications and change the country of origin for value-add activities.
Review your supply chain strategy. Assess the financial exposure from proposed tariffs through end-to-end modeling. A scenario analysis can help you identify vulnerabilities or opportunities. Determine alternatives, such as changes in suppliers, manufacturing footprint, use of free trade zones, postponement strategies and product redesign. And understand how retaliatory measures from trade partners may affect your operating model.
Align tax strategies. Conduct a transfer pricing policy assessment. The potential post-tariff effects on imported goods and associated service and intangible transactions may move intercompany margins out of arms-length range, requiring a proactive review and adjustments to maintain compliance.
Executive call-to-action
| COO | Conduct a sensitivity analysis to prepare for the financial effects of new and proposed tariffs under different conditions. Monitor changes in US-China and US-Mexico-Canada trade relations and prepare for various scenarios. |
| CFO | Take a multidisciplinary approach to gain a clear understanding of how changes in trade policy might affect your company — domestically and in international markets — by integrating insights from tax, supply chain, customs and policy specialists. |
| Tax leader | Assess overall income tax impacts and opportunities, such as the mix of income, tax attributes and incentives as part of the company’s supply chain reevaluation to generate “above-the-line” cash savings. |
Learn more
- US CBP proposes new rules to enhance and strengthen enforcement and limit de minimis shipments entering the US
- Trump Administration announces steep tariffs on Canada, Mexico, and China
- PwC’s US tariff industry analysis under incoming Trump administration
- Trump re-election signals need for businesses to prepare for impending global trade shifts
- Staggering numbers for Trump’s promise on tariffs
- Tariffs and Taxes: Retaliation & Retribution
- Navigating transfer pricing, trade and tariffs in a protectionist world
As the second Trump administration gets underway, we’ve already seen a burst of EOs and other directives implementing priorities that don’t require congressional action. These include a “regulatory freeze” of pending federal rules, allowing the new administration time to review and potentially reconsider them — something both President Trump and President Biden did in 2017 and 2021, respectively. The new president also revoked a range of Biden EOs, including those that reversed some of President Trump’s first-term EOs, foreshadowing broader policy reversals to come.
Further into the president’s first 100 days, the GOP-controlled Congress may try to unwind a broader swath of Biden-era regulations. Under the Congressional Review Act (CRA), Congress can rescind agency rules finalized in the waning months of the outgoing administration with a simple majority vote in both chambers. This, too, happened under both Trump and Biden in 2017 and 2021, when they entered the White House backed by a unified Congress. This time could be harder, though, as the Republican House majority is razor thin. Another challenge is that CRA resolutions can address only one regulation at a time, which can divert precious floor time from more urgent priorities like considering Trump appointments and resolving looming debates over tax and spending policy.
Beyond these efforts, the president’s deregulatory agenda is also unfolding through a reinstated “regulatory budget” program, first instituted in 2017. The new order requires agencies to rescind ten existing rules for every new rule they adopt and imposes a net-negative cap on each agency’s overall compliance cost impact on businesses. It tasks the OMB with standardizing how regulatory costs are measured. For fiscal year 2025, the total incremental cost of all new regulations must be “significantly less than zero,” accounting for offsets from the elimination of costs associated with repealed rules. Whether the program can achieve substantial compliance savings overall is unclear given the net-new regulatory burdens of Trump priorities on immigration and trade. These deregulatory efforts — and the ongoing lack of federal legislation in other areas — may also prompt the states to fill the policy void with a patchwork of new laws, potentially increasing the aggregate compliance burden on companies.
Another potential obstacle to the new administration’s policy agenda — both regulatory and deregulatory — lies in the courts. Rulemaking under the first Trump administration faced intense litigation, much of it successful. This time around, plaintiffs can leverage the Supreme Court’s repeal of Chevron deference if agencies under new leadership reinterpret their statutory authority in some novel way, prompting greater judicial scrutiny.
Finally, the administration’s “Department of Government Efficiency” (DOGE) is charged with slashing government spending and restructuring federal agencies. While there are still many unknowns about it — how it will function, the extent to which it has authority, among other things — executives will want to stay aware of any developments.
What should your company be doing now?
Engage policymakers in strategic areas. Understand the potential business impacts of changes to tariffs and trade to inform your company’s perspective. Also formulate a point of view on the priorities of key appointees, the new Congress and DOGE that most affect your organization. Proactively engage with lawmakers at all levels. Advocate for policies that help support your industry’s growth and address regulatory challenges.
Prepare for regulatory shifts. Monitor regulatory changes in the US (both federal and state) and overseas. Confirm that your regulatory change management processes are efficient and effective and that they include established lines of communication across the C-suite and risk leaders to assess changes and weigh implementation options.
Build risk-oriented scenario planning as a core competency. Practice scenario planning to assess the potential impacts of policy changes, possible company moves and potential outcomes. Identify capability weaknesses and work to address gaps.
Consider integrated risk management. Evaluate and respond to evolving and fragmented regulatory requirements in an integrated manner.
Update your business continuity plans. Make sure your plans consider threats that may arise from policy changes, such as supply chain disruption and labor shortages.
Executive call-to-action
| CRO | Confirm that your regulatory change management capabilities are up to the task and that you have the necessary talent, processes and tools to address risks related to your company’s strategy and operations. Analyze the impacts of deregulation and an increasing patchwork of regulations globally and at state levels (AI, privacy, tech, healthcare, climate) and determine options for addressing requirements at different levels. |
| CISO | Plan for rising geopolitical risk and the different scenarios that may play out related to China and other territories. Weigh cybersecurity implications of potential changes ahead (supply chain and trade reconfiguration, increased M&A). Deliver timely and easy-to-understand reporting to C-suite colleagues on the state of cyber regulations. Work toward bolstering regulatory change management processes. |
| Board | Understand the measures your organization has taken to analyze the impact of potential changes to tax, tariff, trade and supply chain policies and evaluate potential response scenarios. Work with management to analyze strategies to take advantage of a potentially stronger M&A market and greater support for US growth and innovation. |
| Legal officer | Develop a policy response strategy with clear areas of responsibility for the new government’s priorities relevant to your company. Proactively collaborate with risk and compliance teams to form a shared point of view on legal and regulatory matters, assess the business implications of potential regulatory change and, more broadly, improve organizational effectiveness. |
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AI is shaping business more profoundly and more quickly than even the internet did. With the advance of AI agents — intelligent, autonomous digital workers — AI is now disrupting value chains and business models and changing what work means. The pace of innovation continues to accelerate, and AI remains a top priority for many companies.
The new administration appears eager to encourage AI innovation. We’ve already seen an EO rescinding the Biden administration’s sweeping federal regulatory framework. However, global and state regulations will likely remain even tighter. For companies active in multiple jurisdictions, compliance will still be challenging.
The foundational elements for AI success remain the same: A vision and strategy from leadership for making AI intrinsic to the business, embedding AI for growth and using Responsible AI to accelerate value creation and manage risks. A strong vision will aim for hybrid AI-human teams throughout the company, delivering new levels of innovation, speed and productivity. An effective Responsible AI framework will deliver rigorous governance and risk management securing data, validating outputs and so on. That will facilitate innovation, value at scale and high performance. It will help grow the trust which stakeholders will require to adopt your AI.
What should your company be doing now?
Get your data in order. AI needs accurate, relevant, well-governed data. Start now with a small set of high-quality data to drive high-value use cases and start generating ROI. The value you realize can then pay for broader data modernization.
Build a replicable process for compliance at scale. To reduce your compliance burden, build a process to assess and document your control environment so that it can be reused for multiple state and global regimes. Work on harmonizing different compliance data sets like risk statements, control libraries and regulatory requirements. Over time, as AI becomes intrinsic to your company, you also need a third line of defense — independent assurance from experienced third parties or specialized internal audit teams.
Build new skills and shift the culture. As job descriptions evolve to include assigning tasks to “swarms” of AI agents and overseeing their work, your employees will need policies, guidance and guardrails. Define these today, so you and your people will be ready for the future of work — rather than scrambling to close gaps and manage risks later.
Executive call-to-action
| CAIO | To advance AI in your company no matter how government policy evolves, help reshape your organization’s approach to strategy, workforce, technology, risk and tax — while also communicating constantly with key stakeholders. Concentrate on Responsible AI and make sure it’s embedded into AI initiatives from the design stage. That will help you stay ahead of new regulations. By growing stakeholder trust in AI and its outputs, it will also help you win organizational buy-in for AI and unlock AI value more quickly. |
| CIO | Make AI deliver value. If you haven’t already started, use AI to reinvent IT. The cost savings and capacity growth can be significant. Modernize your tech and data architecture for AI and get started on integrating Responsible AI. Your goal is to deliver business value and manage risks while paving the way for AI to become intrinsic to everything your organization does. |
| CRO | AI initiatives in your company will accelerate, no matter what AI-related measures emerge from the new administration. Work with your company’s technology and AI leads to either implement a robust Responsible AI framework or upgrade existing practices to meet new needs. You’ll need Responsible AI to help manage not only compliance risks, but also data risks, model risks, systems and infrastructure risks, use risks and process risks. |
| Board | AI will become integral to every aspect of your company — transforming operations, business models, experiences, reporting, everything — so board members will need to understand the resulting strategic opportunities, oversee risks and controls, and stay up to date with regulations. Start work now on new lines of accountability for a company where AI is making many decisions, and on new benchmarks for creating value and managing costs as hybrid human-AI teams become the norm. |
The new Trump administration is focused on increasing oil and gas production, coupled with enhanced energy innovation and domestic manufacturing, as the means to achieving energy independence. It’s a strategy that mirrors the shifts some other countries have made in recent years.
President Trump has already issued EOs revoking bans on offshore drilling as well as accelerating the development of new oil and natural gas projects on federal land by easing regulatory burdens. Some of his proposed leaders for the Department of Energy and the rumored leaders of a new, government-wide national energy council have history in the oil and gas industries.
Many of the federal production and investment tax credits for renewable energy that have driven sector growth will likely face challenges during Congressional budget negotiations. There’s particular uncertainty around uncommitted funds from the Inflation Reduction Act, although in-flight projects and committed funds are expected to remain on track. Incentives for domestic manufacturing are also expected to stay as well as the continuation of state policies geared at local economic development.
At the same time, energy security is now a national security imperative, and US energy consumption is surging faster than reliable energy sources can deliver. Strengthening domestic energy production — and achieving “energy dominance,” another of President Trump’s stated goals — will likely require an all-of-the-above strategy. That means a place for not just oil and natural gas, but investment in grid modernization and innovating other forms of domestic energy, including solar, wind, geothermal and nuclear.
With its ability to deliver reliable baseload power, nuclear is uniquely positioned to address surging demand and has been making headlines as tech giants turn to nuclear to power data centers. As the country’s existing nuclear plants approach the end of their operational lives, efforts are underway to shorten construction cycles, lower costs and secure support to enable the deployment of solutions like small modular reactors (SMRs) in the future. SMRs may hold the potential to enhance efficiency and solidify nuclear power’s role in meeting growing energy needs, but the technology remains untested.
What should your company be doing now?
Evaluate federal policy risks and opportunities. Assess how changes to federal policies, such as the rollback of tax credits, emissions standards or environmental regulations, could affect your operations, investments and supply chains.
Monitor state-level policies. The renewable energy sector — including solar, wind and battery storage — is likely to be most directly impacted by waning federal support. Ancillary industries, such as electric vehicles and energy efficiency technologies, could also feel ripple effects. But state and local governments could step in to play a larger role in shaping energy markets.
Engage in scenario planning. How might the market respond to policy cues? Should President Trump issue EOs to streamline federal permits for energy projects exceeding $1 billion, will that be enough to spur new activity offshore and in areas like the Arctic National Wildlife Refuge? Should federal support for renewable energy falter, will private sector commitments and technological advancements counterbalance federal retrenchment in renewables?
Executive call-to-action
| CEO | Work with your leaders on the focus areas and strike the right strategic balance. While there’s likely to be political and regulatory changes in the near term, be careful to avoid reactionary pivots that deviate from your long-term strategic objectives. It’s by maintaining focus on your mission that your organization can lead the way in transforming the energy landscape. |
| COO | Working with your finance team, anticipate cost implications and look for growth opportunities. Changes in trade policy or infrastructure priorities may influence material costs, particularly for industries reliant on imported renewable energy components like solar panels or wind turbines. Leverage the opportunity to provide adjacent services and solutions to address energy resiliency and independence needs. |
| CRO | Understand the current and future energy supply and demand and your company’s plans around traditional as well as renewable power sources and what regulatory requirements may arise from shifts in strategy. As part of business continuity planning, consider your plans to mitigate risks from natural disasters or targeted energy disruption. |
| CFO | Strengthen growth prospects by managing capital investment requirements and improving the balance sheet alongside other C-suite executives. Beyond credits for renewable energy, oil and gas companies have been able to claim R&D credits, whether for carbon capture, electrifying field operations or finding more efficient ways to drill. Understand the full range of implications for in-flight projects versus proposed projects, if federal funding under the IRA or other laws is delayed or repealed. |
| Tax leader | While House Speaker Mike Johnson (R-LA) and other Republican leaders have indicated that a full “repeal and replace” approach to the Inflation Reduction Act provisions appears unlikely, they have expressed an interest in prospective efforts to address the rising cost of the clean energy incentives. Monitor legislative developments and tax implications around federal energy subsidies and state policies that may present alternative opportunities for renewable projects. |
| Sustainability leader | The SEC’s climate-related disclosure rules could be revised or even reversed by the new administration, which could lead to individual states following California’s lead and instituting their own requirements. US companies will still need to follow global disclosure regulations such as the EU’s Corporate Sustainability Reporting Directive. Look beyond the four-year election cycle and political winds and act with the long view in mind to stay on the right course for your business. |
| CIO | Large load users — tech providers, developers, hyperscalers and manufacturers — can look to build coalitions to influence regulatory reform to increase the speed of grid connection. Companies can help drive reform that enables their own goals and manages the affordability concerns of utilities. This role is essential in developing the enabling technology that will support a modernized grid infrastructure over the long term. |
As President Trump returns to the White House, his administration will likely double down on some of the priorities that helped define his first term: Championing traditional energy, maximizing domestic production and dismantling climate initiatives.
On his first day in office, President Trump used EOs to roll back pro-climate regulations aimed at restricting public land drilling, improving vehicle emissions standards and expanding renewable energy efforts. He opened Alaska’s Arctic National Wildlife Refuge for oil and gas drilling and withdrew the US from the Paris Agreement, repeating an action he took during his first term. He’ll likely use EOs to quickly advance a pro-energy agenda as well. Tariff increases — a centerpiece of his campaign — could impact global supply chains. During his first term, the Trump administration repealed more than 100 environmental protections, targeting wetlands, mercury emissions and carbon dioxide limits.
Also on the regulatory front, the SEC’s climate-related disclosure rules could be revised or even reversed. In the absence of federal standards, individual states may follow California’s lead and adopt their own disclosure requirements, creating a patchwork of regulations with varying scope and deadlines.
The future of the Inflation Reduction Act, which provides hundreds of billions of dollars in tax incentives for sustainability projects, remains uncertain. While President Trump signed an EO that paused funding, the IRA has provided significant investments in jobs and capital projects across districts nationwide, making full repeal challenging. Many Republicans have seen its benefits in their own states.
Regardless of the new administration’s actions, many US companies remain focused on integrating sustainability into their operations, products, supply chains and business models to address threats to their long-term strategies and protect value-at-risk as well as potential areas of growth. In our October 2024 Pulse Survey, nearly half (46%) of the survey respondents indicated they would increase sustainability investments even if Trump returned to office while just 11% planned to cut back. That sentiment may stem from the need to comply with global regulations such as the European Union’s Corporate Sustainability Reporting Directive (CSRD), alongside growing consumer demand for sustainable products and the imperative to manage climate-related business risks.
What should your company be doing now?
Stay the course. While some organizations have stepped away from sustainability-related alliances, maintaining a sustainability strategy that has proven effective — and remains aligned with your business objectives — is critical. Key underlying trends such as the surge in electricity demand from data centers, emerging technologies and the reshoring of manufacturing and the transition to renewable energy will persist even under the new administration. Use this time to reflect on the successes achieved under previous policies and plan how to sustain that momentum moving forward. Leverage sustainability data to uncover opportunities for cost savings, enhance resilience and drive growth. Meanwhile, stay informed about evolving state, federal and global regulations impacting your industry and organization.
Prepare for regulatory uncertainty. While President Trump and a Republican Congress may try to fast-track their agenda, their plans are likely to be met with challenges designed to slow their momentum — but EOs can come quickly. Conduct policy scenario planning to gauge the impact of tariff increases and other regulatory changes on the business. Develop models to see how the supply chain and costs will be impacted and the key steps needed to manage against each.
Executive call-to-action
| Sustainability leader | Given policy uncertainty, continue championing sustainability projects already underway. Use this time to focus your efforts. Be clear about where you’re headed and the business outcomes you’re driving while also determining the impact on project completion if sustainability tax credits, incentives and other funding sources are scaled back. |
| CIO | Work with sustainability leaders and the COO on tech-enabling your organization’s reporting strategy so that it can effectively collect and analyze the significant data needed for existing regulations and any new ones on the horizon. |
| CFO/controller | Help your colleagues understand the regulatory environment domestically and internationally. Emphasize how reliable, thorough data is essential to all reporting obligations while demonstrating the value this information provides for value-at-risk assessments, cost savings and revenue growth. |
| CRO | Make sure the financial and operational risks related to sustainability are fully identified, analyzed, managed, monitored and reported. Regardless of any policy changes, those risks to your business will remain. Confirm that your existing compliance capabilities are flexible enough to adapt to whatever policy and regulatory changes may be coming in the months ahead, then stay in close contact with your organization’s public policy team. They can help you cut through the political noise and determine which policy scenarios may come to fruition. |
| Board | Stay informed on developments and regulatory changes to meet oversight and governance responsibilities — in whatever form they take. Question management about the steps your company’s taking to mitigate emerging threats or risk exposure, and if it has the resources it needs. |
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With President Trump’s return, his second administration is expected to continue to focus on national security and, where possible, opportunities to deregulate and alleviate burdens on the private sector. In his last term, President Trump steered clear of heavy legislative action and focused on the defense strategy. For instance, there’s still momentum to initiate a Department of Defense Cyber Force as a dedicated branch. The administration’s America-first stance, a potential rise in geopolitical tensions and nation-state targeting reinforce a defense-led priority.
On the regulatory front, President Trump will scrutinize regulations that have been finalized or proposed for implementation under the Biden administration. To that end, the Cybersecurity and Infrastructure Security Agency (CISA) issued a proposed rule to implement reporting requirements under the Cyber Incident Reporting for Critical Infrastructure Act of 2022 (CIRCIA). With the rule still yet to be finalized, there could be an accelerated effort from the Trump administration to make adjustments and limit which entities qualify as critical infrastructure.
The Trump administration is expected to lean heavily on the courts and limit the powers of federal regulatory agencies following the Supreme Court’s repeal of the Chevron doctrine and other recent decisions. Some states are likely to respond by becoming more active with legislation and giving prescriptive guidance, particularly in areas such as artificial intelligence (AI), connected devices and emerging technologies.
Despite efforts to reduce critical infrastructure regulatory burden, the administration will likely give sharper attention to its security. Given the most recent nation-state breach incidents impacting the telecom industry, threat vulnerability detection, threat intelligence sharing and response capabilities could be priorities for national threat defense.
What should your company be doing now?
Maintain core cybersecurity capabilities. Continue to prioritize cyber defense and resilience practices, even if regulations are decreased. Threats are still pervasive and complex, so your cyber posture should remain robust and exceed regulatory levels.
Continue to fortify compliance. Even if a Trump administration is focused on less regulation, national security is at the forefront and pulling back on compliance would be premature. The process to scale back regulations will be slow and won’t result in immediate reductions.
Balance risk and opportunity. Identify business and innovation opportunities that could emerge with regulatory relief. Evaluate the cybersecurity maturity threshold you would still need to meet to stay safe and build proactive cyber risk assessments up front as part of innovation processes.
Anticipate EOs and process changes. Stay proactive with a response to potential EOs and other directives. Although regulations are tougher to navigate, EOs could still present immediate obstacles to your organization’s current program and process priorities, requiring cybersecurity defenses to keep up.
Executive call-to-action
| CISO | Take the lead on delivering consistent and actionable updates to leadership and executive teams on geopolitical risks and the state of cyber regulations and executive policies. Translate the business impacts and implement regulatory change management processes to stay agile. Be prepared to share how your team is enabling the business as it responds to changes in supply chains/trade, increased M&A activity and innovation. |
| CRO | Confirm that your company’s regulatory change management capabilities are up to the task and that you have the necessary talent, processes and tools to address related risks. Analyze the impacts of deregulation and an increasing patchwork of regulations globally and at state levels (AI, privacy, tech, healthcare, climate) and determine options for addressing requirements at different levels. |
| CEO | Understand what scenarios could play out with respect to changing regulations and potential EOs. Make sure risk and business leaders are keeping you up to date. Allocate sufficient investment and resource capacity to cyber resilience — in detection, response, recovery — to address threats from nation-states and other bad actors, as well as the expanded threat landscape brought on by AI and other innovations. |
| Board | Understand measures your organization has taken to analyze the impact of potential regulatory action and evaluate potential response scenarios. Question management about the investment and resource capacity needed to support cyber resilience, M&A growth and innovation. |
Dealmakers should keep a close eye on the impacts of tariffs and immigration restrictions in the first 100 days. Both could add inflationary pressures and could introduce supply and demand shocks, creating complexity and uncertainty.
One potential near-term effect of tariff and deportation initiatives could be that interest rates might not come down at the pace, or to the extent, previously projected by financial markets, stalling projected dealmaking activity. Supply or demand shocks created by tariffs or deportation initiatives could also affect both the overall economy and executive confidence, key factors for M&A activity.
Companies considering M&A opportunities in the Middle East and Eastern Europe will want to keep a close eye on President Trump’s early foreign policy posture. While the president won’t be able to end the conflicts there single-handedly, US policy could provide clues as to how much longer those wars might last and under what terms they might be resolved.
A final point worth watching in the first 100 days: Dealmakers should monitor the changing regulatory environment as they’ve been anticipating a friendlier M&A and capital markets environment due to the perception that the Trump administration will be more deregulatory than its predecessor. While that’s likely the case, there are areas — deals with national security implications, for instance — that could receive as much or more scrutiny as before. There’s also tension between the administration’s coalition of populists on one hand and corporate advocates on the other. Companies will need to closely track which side of that coalition the regulators they will be working with come from.
What should your company be doing now?
Analyze the potential impact of tariffs or national security policies: Identify potential drivers of, and inhibitors to, volume and price growth that can help determine which target acquisitions are good strategic fits.
Conduct enhanced due diligence on supply chains: Understand who the alternative suppliers are for potential targets and the cost implications of using them.
Develop different scenario plans: Create a playbook for handling expedited divestitures in case tariffs or geopolitical shocks make it impossible, or unprofitable, to continue operations in a specific country or region.
Reconsider the strategic investment landscape. Changes in regulatory priorities may make onshoring or energy deals, for instance, more attractive than under the previous administration.
Executive call-to-action
| CFO | Reassess how your company measures the potential opportunity versus the cost of new domestic ventures under the Trump administration’s “America-first” philosophy. Update your due diligence playbook to assess risks from new tariffs and geopolitical conflicts. |
| CEO | Develop working relationships with key lawmakers, regulators and members of the press. Use your role to publicly champion the benefits of deals to all stakeholders — not just shareholders. Meanwhile, prepare for an uptick in activity by updating your deal playbook and continually reviewing your potential deal pipeline as regulatory, financial market and competitive conditions shift. |
| Corporate development | Conduct periodic, objective and thorough portfolio assessments. Determine how existing businesses might be affected by the new administration’s “America- first” philosophy and identify options to take advantage of opportunities and mitigate risks. |
Industries
The final months of the Biden administration saw a number of actions from outgoing regulators as President Trump began to announce their replacements. Before SEC Chair Gary Gensler stepped down on inauguration day, he oversaw the finalization of updates to the SEC’s broker-dealer customer protection rule and initiated a lawsuit against Trump administration advisor Elon Musk. CFPB Director Rohit Chopra, who could be removed by President Trump, was particularly active — finalizing last-minute rules to advance open banking, cap overdraft fees, expand supervision of digital payment providers and ban the inclusion of medical debt in credit reporting.
The fate of these actions will ultimately be determined under the Trump administration. All of these final rules could be nullified or changed through several mechanisms — they could be overturned by the Republican-majority Congress through the Congressional Review Act (CRA), struck down in court (particularly if new agency leaders decline to defend them) or new leaders could issue modified versions. Notably, Republicans’ face two major challenges in using the CRA: their razor thin majorities and the reality that CRA resolutions must be addressed one regulation at a time, which can divert precious floor time from more urgent priorities.
President Trump has already announced nominees for several key financial services positions, including Scott Bessent as Treasury secretary, Paul Atkins to chair the SEC and Howard Lutnick as Commerce secretary. He has also named the first-ever White House AI and crypto czar, tech entrepreneur David Sacks. In the coming weeks and months, he will announce nominees to lead the OCC, FDIC, CFTC and CFPB. He will also be able to name a new vice chair for supervision at the Fed after Michael Barr announced that he would step down, although the president will likely need to choose from the existing slate of governors as Barr will remain on the board and there are no current vacancies.
These nominees are likely to be confirmed by the Republican-majority Senate, which will allow them to quickly begin redirecting the priorities of the financial services agencies. Based on the first Trump administration and the views of the nominees announced so far, the new agency leaders will likely seek to streamline regulatory requirements and establish regulatory frameworks for new products such as digital assets. Digital asset advocates have particularly high hopes for the Trump administration due to support espoused throughout the campaign and the announcement of a new “crypto council.” Some of the earliest concrete changes could come at the SEC, such as withdrawal of the Staff Accounting Bulletin (SAB) 121 classifying digital assets as liabilities and reversal of what the industry has criticized as “regulation by enforcement” in cases where the SEC has issued charges related to registration rather than fraud.
Even if some regulatory requirements are relaxed, regulators will continue to use their examination and enforcement powers to maintain financial system safety and soundness and to prevent market manipulation, fraud and financial crimes. It’s clear that many institutions still have work to do to remediate outstanding issues. The Fed’s November Supervision and Regulation Report revealed that just a third of large financial institutions had a satisfactory rating across all three components (capital planning and positions, liquidity risk management and positions and governance and controls).
What should your company be doing now?
Assemble wish lists for regulatory relief and supervisory transparency: The new administration won’t grant every request, but your firm should be prepared to provide defensible reasoning for relief in response to new proposals and requests for information.
Prepare for regulatory shifts: In anticipation of requests for comment and proposals, firms should monitor statements from incoming regulatory agency leaders about which rules they’re targeting for revision. Confirm that regulatory change management processes are effectively monitoring regulatory developments, assessing their impact on your organization and communicating those implications to relevant stakeholders.
Capitalize on emerging market opportunities: Developing innovative products, partnering with fintechs and engaging with digital assets could get easier under the Trump administration. Traditional FS players should pursue these opportunities while maintaining sound third-party risk management and product approval reviews involving all three lines of defense.
Maintain strong compliance practices. While regulatory changes work through the agencies and courts, supervisory expectations will remain high and some states, notably California and New York, will retain requirements that are pulled back on a federal level. Throughout this process, firms should continue to maintain robust compliance and risk management practices, both to avoid supervisory actions and as a strategic imperative.
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As President Trump takes office, a strong lineup of disruptors and strategic nominations for leadership positions is taking shape, aiming to shift the emphasis from treatment to prevention while enhancing personalized care and continuing to push to cut drug prices.
President Trump issued dozens of EOs on Inauguration Day to quickly implement his agenda to overturn Biden-era policies, particularly in the areas of diversity, equity and inclusion (DEI), AI, vaccine mandates, Affordable Care Act (ACA) expansions and health equity. A focus on reforms to immigration, tariffs and tax policies also persists, which could significantly affect the health industry workforce, alter supply chains and create budget constraints for health systems. A potential counterbalance, the president’s tax policy may include corporate cuts for products produced domestically.
On the legislative front, the Republican majority in the Senate provides an opportunity to employ the budget reconciliation process, which will allow an acceleration of the GOP health agenda without concessions to Democrats. Key aspects include changes in government funding programs, coverage/eligibility shifts for Medicaid, continued scrutiny of drug pricing, expanded site neutral payments and reform to federal 340B Drug Pricing Program and Pharmacy Benefit Management (PBM) oversight. These efforts may lead to budget constraints for providers, changes in payer mixes and adjustments in pharmaceutical pipeline and marketing strategies.
As for regulatory change, key cabinet nominees are already influencing healthcare debates, with potential structural changes at the FDA and Centers for Medicare and Medicaid Services. The reallocation of funding toward prevention and chronic disease management could impact research grants and agency budgets, notably at the NIH and CDC. Momentum also exists for alternative health solutions, which may lead to changes in labeling requirements, advertising and agricultural regulations.
Finally, changes in FTC and DOJ leadership suggest a potential easing of M&A scrutiny, while bipartisan support grows for increased oversight of PBMs. Impending funding cuts, driven by agency leadership, may also contribute to increased consolidation of health systems.
What should your company be doing now?
Conduct scenario planning for policy shifts: Proactively monitor regulatory changes and shifts in Medicaid and Medicare funding models to adapt business strategies and ensure compliance. Plan for various FDA regulatory scenarios to maintain safety and compliance.
Enhance transparency: Bolster processes and systems that streamline compliance with transparency requirements, including pricing disclosures, to reduce operational risks and satisfy consumer demands.
Revisit supply chain for critical healthcare items: Assess supply chains and consider transitioning to domestic production to align with policy shifts and reduce reliance on global suppliers.
Continue with a self-governance approach to AI oversight: Companies such as those in medtech should build internal AI governance frameworks to capitalize on opportunities in a currently deregulated market while addressing risks related to self-imposed compliance and liability.
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As President Trump takes office for a second term, technology, media and telecommunications (TMT) executives should prepare for shifts in trade and tax policy, an evolving regulatory environment and opportunities in AI and other emerging technologies.
While federal tax legislation could offer financial relief to corporations and individuals, the OECD’s Pillar Two framework was the subject of one of President Trump’s January 20 EOs. The EO directs administration officials to notify the OECD that any commitments made by the prior administration “with respect to the global tax deal have no force or effect within the US.” In addition, the administration’s approach to digital service taxes, already a contentious international issue, could impact cross-border digital business operations. And the administration’s tariff plans and other protectionist measures could further disrupt supply chains. Semiconductors, a sector already reshaped by national security concerns, will face heightened scrutiny as the administration doubles down on “Buy American” mandates and export controls.
These economic and trade policies are likely to intersect with shifts in leadership and technological priorities. President Trump’s appointments of prominent tech leaders to key advisory roles are expected to significantly influence the administration’s policy agenda. Figures such as Sriram Krishnan, Scott Kupor, Elon Musk and David Sacks, tapped as senior White House advisors, bring deep industry experience in areas like AI and digital infrastructure. Their presence underscores a focus on fostering technological leadership and innovation-friendly policies that align with the sector’s growth ambitions.
AI, long championed by the president, is expected to benefit from a broader push toward deregulation as well as expedited environmental and regulatory reviews for large-scale projects. This includes significant investments in data centers and AI-related infrastructure and the streamlining of guidelines around AI innovation and deployment. These moves will support AI and cloud business needs, particularly for hyperscalers, as well as 5G networks and expanded broadband access. Additionally, the president’s repeal of President Biden’s executive order on AI may leave it up to individual states to tackle AI and privacy rules, complicating compliance for businesses. Meanwhile, increasing differences in AI regulations between the US and EU environments could lead companies to adopt regional approaches, making it harder for non-US firms to compete globally.
A GOP-led emphasis on free speech and reduced social media content moderation has already led some TMT companies to adjust policies, impacting operations and trust, while traditional media might benefit from deregulation fostering mergers and acquisitions. Still, oversight on issues like cybersecurity and antitrust enforcement will likely intensify. The administration’s appointments of Brendan Carr to the FCC and Andrew Ferguson to the FTC signal a mixed regulatory environment where some mergers may proceed, but Big Tech faces continued scrutiny.
What should your company be doing now?
Adapt supply chains to mitigate tariff impacts. Balance global sourcing strategies with local manufacturing commitments to mitigate risks. Model various scenarios to understand potential costs and opportunities to deploy flexible strategies, such as leveraging tariff mitigation programs or increasing local sourcing.
Capitalize on AI opportunities. Prioritize investments in AI innovation and take a Responsible AI approach while preparing for emerging state-level regulatory requirements like California’s AI Transparency Act. Invest in AI safety that can adapt to frequent rule changes.
Strengthen cybersecurity and compliance frameworks. Expect heightened regulatory focus on cybersecurity and data governance. Align internal policies with evolving standards to manage risks effectively.
Prepare for shifting tax policies. Assess proposed 2025 tax legislation addressing expiring TCJA provisions, focusing on the potential benefits of reduced US corporate tax rates if current policy is used for baseline scoring and if tariffs are part of the revenue narrative. Engage with policymakers and refine your global tax strategies to help reduce risks from international compliance burdens.
Invest in resilience amid global competition. As trade policies and geopolitical tensions intensify, consider diversifying operations and partnerships to enhance flexibility and reduce exposure to market volatility.
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President Trump is primed to act on the priorities he has been signaling since the election. Central to this agenda is a focus on reshaping US manufacturing and trade policies. On February 1, under the International Emergency Economic Powers Act, the president announced tariffs 25% on imports from Canada and Mexico and an additional 10% tariff on imports from China. He also announced a 10% tariff on energy products from Canada. Days later, he agreed to a delay for Canada and Mexico, underscoring the fluid nature of trade negotiations.
These measures aim to drive supply chains back to the US, presenting strategic opportunities for businesses to reimagine their operations and explore domestic production incentives that could spur efficiency improvements and innovation. At the same time, these changes also pose challenges for businesses heavily reliant on imported materials, which may face higher costs and potential disruptions. Industrial products and services (IPS) leaders, particularly those anticipating trade impacts from the election — as indicated by three-quarters of respondents in our October 2024 Pulse Survey — should act now to mitigate risks and position themselves to take advantage of these shifts while remaining resilient and prepared.
President Trump has already started to leverage EOs to advance his trade agenda. Discussions on potentially reducing corporate tax rates to 15% for US-manufactured goods are likely to accelerate in Congress, aligning with the president’s goal to invigorate domestic production.
What should your company be doing now?
Initiate tariff impact assessments. Evaluate exposure to announced tariffs and identify cost-saving strategies like duty drawback programs or reconfiguring supply chains.
Reinforce supply chain resilience. Diversify suppliers, invest in automation and build flexibility to adapt to disruptions.
Explore onshore opportunities. Assess the possibility of growing domestic manufacturing, warehousing and distribution activities closer to home to improve efficiency and resilience.
Capitalize on tax incentives. Monitor developments to align strategies with potential reductions in corporate tax rates and manufacturing incentives.
Align workforce strategies. Plan for hiring, reskilling and upskilling to meet the demands of increased domestic production and technological advancements.
Prepare for regulatory adjustments. Strengthen compliance systems to respond swiftly to new EOs and policy shifts.
Engage in strategic scenario planning. Model different scenarios to understand the financial and operational impacts of tariffs, geopolitical changes and energy policy shifts.
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With Republicans capturing both the White House and Congress, consumer markets face a transformative period ahead — a reality reflected in our October 2024 Pulse Survey, where 74% of industry leaders said the election outcome could significantly alter how they do business.
President Trump’s “America First” economic agenda includes several key initiatives that will reshape the landscape, including heightened tariffs targeting goods from China, Mexico and Canada and tax incentives to promote domestic production. The implications vary across sub-sectors.
Consumer packaged goods companies and retailers face rising input costs, but regulatory reforms could drive innovation in operations and supply chain efficiency.
Hospitality and leisure could see shifts in discretionary spending patterns, while signals of regulatory relief point to reduced operational complexity.
Transport and logistics operators can leverage policy changes to build more resilient networks and optimize service configurations.
Restaurants and agriculture may face labor market shifts from broader immigration policy changes and higher import costs.
These changes present strategic opportunities. Increased domestic production incentives could spur efficiency improvements and innovation, particularly in the food and beverage sector where reformulation and investments will likely be shaped by the “Make America Healthy Again” initiative’s focus on product safety and transparency.
Deal activity is expected to accelerate as companies strategically pursue growth through M&A, particularly in the food, beverage and household products sectors. The coming wave of private equity exits provides opportunities for strategic combinations, while proposed reforms like tip tax elimination could strengthen workforce retention and corporate tax relief could boost domestic investment.
What should your company be doing now?
Reimagine operating models to create competitive advantages. Success will depend on how effectively businesses optimize multiple levers — from supply chains and digital capabilities to workforce strategies — to capture growth.
Identify potential risks and opportunities with cost modeling and sourcing strategies. Conduct scenario planning to measure business impacts (both direct and indirect) on products. Explore tariff mitigation strategies for current supply chains and develop alternatives such as nearshoring and localizing production while forming strategic alliances.
Optimize tax and compliance structures. Stay informed about policy shifts, pursue tax credits or incentives for domestic operations and strengthen reporting frameworks.
Invest in innovation and adaptable supply chains. Explore new sales channels, digital marketing and product diversification to mitigate demand fluctuations. Modernize planning and inventory management systems to proactively identify and respond to changing economic and regulatory conditions.
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