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Executive Order Formally Establishes U.S. DOGE Service with IT Modernization Initiative

Client Alert | 1 min read | 01.24.25

Among the flurry of executive actions taken during his first day in office, President Trump formally established the U.S. Department of Government Efficiency Service (DOGE) via executive order (EO) on January 20, 2025, reconstituting the formerly named U.S. Digital Service that was created in 2014 by President Obama within the Office of Management and Budget. 

Deviating from initial announcements that DOGE would operate as an external advisory body staffed by volunteers, the newly created DOGE has been designated as a “temporary organization” within the Executive Office of the President, scheduled to sunset on July 4, 2026, with an Administrator reporting directly into the White House.  Within 30 days, each federal agency is also directed to establish a “DOGE Team” with at least four employees to carry out the administration’s DOGE agenda—one team lead, one engineer, one human resources specialist, and one attorney—who will receive “prompt and full access” to all unclassified agency records, software, and IT systems.

The EO notably avoids reference to any government-wide cost-cutting measures, but rather focuses DOGE’s mandate on a Software Modernization Initiative that seeks to improve the quality and efficiency of government-wide software and IT systems, and to promote the interoperability between agency networks, ensure data integrity, and facilitate responsible data collection and synchronization.  Given the embedding of DOGE officials within each agency and the unfettered access they will have to IT and spending data, however, we anticipate ample opportunity for DOGE to identify and make cost saving recommendations to administration officials and lawmakers.  In the meantime, government contractors supporting federal IT systems and networks should brace for the establishment of formal DOGE Teams at each agency, and an enhanced push toward the modernization of information technology and infrastructure.

Insights

Client Alert | 7 min read | 12.17.25

CARB Proposes Regulations Implementing California GHG Emissions and Climate-Related Financial Risk Reporting Laws

After hosting a series of workshops and issuing multiple rounds of materials, including enforcement notices, checklists, templates, and other guidance, the California Air Resources Board (CARB) has proposed regulations to implement the Climate Corporate Data Accountability Act (SB 253) and the Climate-Related Financial Risk Act (SB 261) (both as amended by SB 219), which require large U.S.-based businesses operating in California to disclose greenhouse gas (GHG) emissions and climate-related risks. CARB also published a Notice of Public Hearing and an Initial Statement of Reasons along with the proposed regulations. While CARB’s final rules were statutorily required to be promulgated by July 1, 2025, these are still just proposals. CARB’s proposed rules largely track earlier guidance regarding how CARB intends to define compliance obligations, exemptions, and key deadlines, and establish fee programs to fund regulatory operations....