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September 4, 2025

Spring 2025 Regulatory Agenda Released  

The Office of Information and Regulatory Affairs (OIRA), within the Office of Management and Budget (OMB), has released the Spring 2025 Unified Agenda of Regulatory and Deregulatory Actions. This semiannual publication outlines the rulemaking priorities of federal agencies, providing employers and the public with transparency into regulatory initiatives that may affect their operations in the months ahead. 

Since 1978, federal agencies have been required under executive order to publish these agendas, and the Unified Agenda has become the central resource for tracking upcoming proposals and rulemakings. RegInfo.gov hosts the full agenda, dating back to fall 1995, and allows users to view rulemaking entries by agency. 

Department of Labor Proposal: AEWR Methodology 

Of particular interest to agricultural employers, the Department of Labor (DOL) has signaled plans to amend its regulations governing the certification of agricultural labor or services performed by H-2A workers. The proposal (RIN: 1205-AC24) would revise the methodology used to determine the  

Adverse Effect Wage Rate (AEWR) for non-range agricultural occupations. 

The AEWR sets the minimum wage employers must offer and pay H-2A workers, as well as corresponding U.S. workers in “corresponding employment.” Changes to AEWR methodology can significantly impact employer labor costs, particularly in high-AEWR states like California and Arizona. Although details of the DOL’s proposed revisions are not yet public, the agency’s entry in the Unified Agenda confirms that rulemaking is underway. Employers should monitor this closely, as the AEWR has been the subject of multiple legal challenges in recent years.  

The DOL’s entry regarding the AEWR methodology revision is available here. 

Accessing the Agenda 

Employers and stakeholders can review the full Spring 2025 Unified Agenda at RegInfo.gov. The site allows users to select agencies from a drop-down menu and view both proposed and final rules under development.  

The regulatory agenda for USDA and DHS are also of interest to agricultural employers. Western Growers will be closely monitoring the Administration’s regulatory priorities in the weeks and months ahead.