The Pattern
Project 2025 is not a leak, a rumor, or an opposition-research summary. It is the Heritage Foundation’s own published document, hosted on Heritage’s own servers, credited to more than 35 primary authors and hundreds of additional contributors, and built around a stated goal: policy “actionable” starting on day one of a second Trump administration. The core text, Mandate for Leadership: The Conservative Promise, runs to roughly 900 pages. Heritage published it in April 2023 under the banner of the 2025 Presidential Transition Project, a coalition Heritage Foundation president Kevin Roberts has said brings together more than 110 conservative organizations.
This piece looks at that document, the public statements of Heritage’s own leadership, and the public record of what federal agencies have done since January 2025. It looks at specific proposals to merge government functions with a contested set of religious and political commitments, and tracks what has actually happened to those proposals since.
What Heritage published, and who ran it
Paul Dans, a former Trump-administration personnel official, directed Project 2025 through its writing and rollout. He announced his resignation on July 30, 2024, and left Heritage that August, after the document became a liability on the campaign trail. Heritage’s own statement on the departure said Dans “and Heritage decided to part ways over differences in the strategic direction of Project 2025,” and specified that the disagreement “did not involve any issues with his integrity or inappropriate/offensive behavior towards women.” Roberts, who has led Heritage as its president since December 2021, took over stewardship of the project himself. Dans later pursued other ventures, including a brief 2026 Senate primary campaign against Sen. Lindsey Graham in South Carolina, from which he withdrew.
The document itself was never a solo effort. Along with the policy text, Project 2025 built a searchable personnel database of vetted political appointees and a training program it called the “Presidential Administration Academy,” all coordinated across the 110-plus partner organizations Roberts cited. A single think tank writing a policy book is commentary. A funded network of a hundred-plus organizations, a shared personnel pipeline, and a training academy converging on one document is a funded architecture: infrastructure built so an agenda can move from position paper to federal policy wearing the appearance of a broad, independent consensus, even though the money and staffing both run through the same hub.
The disavowal, and its limits
During the 2024 campaign, Trump repeatedly and publicly distanced himself from the document. In July 2024 he wrote that he knew “nothing about” Project 2025 and had “no idea who is behind it,” calling some of its proposals “absolutely ridiculous and abysmal.” At the September 2024 debate, he said: “I have nothing to do with Project 2025. I haven’t read it. I don’t want to read it purposely. I’m not going to read it.” His campaign told reporters that “outside groups like Project 2025 do not reflect campaign strategy or policy.”
Heritage did not mirror that retreat. Days after Trump’s disavowal, Roberts told a radio interviewer that “the overlap is tremendous” between Project 2025 and Trump’s own platform, describing only “some quibbles and differences of opinion” that a future administration would work out on its own. The document was never withdrawn from Heritage’s website. Eight months into the second Trump term, FactCheck.org found that 32 of the 40 named authors of Project 2025’s chapters had ties to past or current Trump administrations or campaigns, several of them, including OMB Director Russ Vought, in senior roles. The candidate disavowed the document in public. The organization that wrote it kept operating as though the disavowal changed nothing, and the record since suggests it didn’t.
What the document proposes
Three parts of Mandate for Leadership bear directly on church-state entanglement, reproductive rights, and LGBTQ policy.
On religion and government: the document proposes eliminating the Department of Education in favor of religious- and charter-friendly “school choice,” and would bar accrediting bodies from imposing standards that conflict “with the religious mission or religious beliefs” of a school (p. 352), while urging, as a model for states and local governments to follow, that classrooms let staff “live out their faith in the classroom regardless of the impact on students and parents” (p. 346). Both citations are per the Baptist Joint Committee for Religious Liberty’s review of the text. It calls for expanding taxpayer funding to religious organizations with fewer eligibility safeguards, letting recipients of Title X funds (the federal program funding family-planning clinics for low-income patients) decline abortion referrals, and broadening religious and moral exemptions for health workers, foster-care agencies, and federal contractors. It urges the Department of Health and Human Services to adopt “a robust agenda to protect the fundamental right to life, protect conscience rights, and uphold bodily integrity rooted in biological realities, not ideology,” and to “return to being known as the Department of Life.” That renaming doesn’t repeal a single regulation. It recasts a debatable policy choice as settled identity: something to be for or against, not a position that has to win an argument. Borrowing the settled weight of “life” and “conscience” to do work that evidence and debate would otherwise have to do is authority laundering.
On reproductive rights: the document cites the 1873 Comstock Act by statute (p. 594), a never-repealed 19th-century law against mailing anything used to induce an abortion that some conservative lawyers argue could ban abortion pills nationwide without Congress passing anything new, and calls for enforcing its criminal mailing provisions against abortion medication, per the Center for American Progress’s review of the same section. It calls for rescinding federal guidance that treats emergency abortion care as protected under the Emergency Medical Treatment and Labor Act, tightening the FDA’s telehealth rules for mifepristone (the medication used in most drug-induced abortions), ending enforcement of the FACE Act (the law making it a federal crime to block or threaten people entering reproductive-health facilities, including but not limited to abortion clinics), and reinstating the “Mexico City Policy” restricting foreign aid to organizations that so much as refer for abortion abroad.
On LGBTQ policy: the document’s framing of obscenity law links pornography and what it calls “transgender ideology,” calls for rescinding federal rules that treat gender identity and sexual orientation as protected categories under sex-discrimination law, and proposes ending Pentagon policy allowing transgender military service.
On the civil service: the document calls for reviving Schedule F, a 2020 executive order that would strip employment protections from tens of thousands of federal employees in “policy-influencing” roles, so an incoming administration could remove and replace them without the misconduct or performance findings the merit system otherwise requires. The proposal doesn’t hide its purpose. It says career staff should be replaced with appointees who won’t resist the president’s direction. That is a documented institutional capture mechanism: a traceable plan to redirect a public institution’s staffing toward the people positioned to redirect its output.
What has been built since January 2025
Federal agencies have acted on each of these fronts. On his first day back in office, Trump signed Executive Order 14171, reviving and renaming Schedule F as “Schedule Policy/Career”; the Office of Personnel Management’s final implementing rule was published in the Federal Register on February 6, 2026. The same week, the administration reinstated the Mexico City Policy and pulled guidance that had let Medicaid enrollees and military families claim travel support for abortion care. The Department of Justice pardoned 23 people convicted of blocking access to abortion clinics and moved to stop enforcing the FACE Act. By July 2025, the U.S. Agency for International Development (USAID) had been dismantled outright, taking its international family-planning grants with it, and the administration had cut off funding to the UNFPA, the United Nations’ reproductive-health agency, entirely. In June 2025, HHS and the Centers for Medicare & Medicaid Services rescinded 2022 guidance affirming that hospitals must provide emergency abortion care under federal law regardless of state bans. That same month, in separate litigation, a federal judge in Texas vacated a rule that had shielded reproductive-health records from law-enforcement requests. That fall, HHS Secretary Robert F. Kennedy Jr. opened a safety review of mifepristone that reproductive-rights groups say targets the same telehealth access the document proposed narrowing. CMS proposed barring Medicaid and CHIP (the Children’s Health Insurance Program) funding for gender-affirming care for anyone under 18 in December 2025, then finalized that rule in August 2026. A transgender military service ban was signed within Trump’s second week in office.
The Center for Progressive Reform’s tracker counted 283 of 532 Project 2025 recommendations “initiated or completed” within the administration’s first year. Heritage has not disputed that figure; a Heritage spokesperson told the Christian Science Monitor in August 2026 only that the organization remains “proud to continue developing and advancing common-sense policy solutions that improve the lives of Americans.”
Where the record is still open
Not every proposal has landed as written. As of this writing, no Justice Department enforcement action has been publicly confirmed under the Comstock theory the document lays out. HHS’s mifepristone review has moved toward a similar practical result by a different, still-unresolved path. The Schedule Policy/Career rule faces pending legal challenges that could narrow its reach, according to a Congressional Research Service analysis. And the 283-of-532 figure comes from an advocacy organization that opposes the agenda it is tracking, not a neutral government audit; it should be read as that organization’s tally, not as an agreed-upon final count.
Kevin Roberts, on the record
Roberts’s most-quoted remark about the project came on Steve Bannon’s podcast in July 2024: “We are in the process of the second American Revolution, which will remain bloodless if the left allows it to be.” The line drew condemnation from Democratic officials and some Republicans. Heritage stood behind it and posted a follow-up video compilation it said showed the left inciting unrest of its own.
That was not the only crisis to hit Heritage’s leadership. In October 2025, Roberts released a video defending Tucker Carlson’s interview with white nationalist Nick Fuentes, saying Heritage would not engage in “canceling our own people or policing the consciences of Christians.” Heritage’s own task force on antisemitism left the organization in protest that November. Princeton scholar Robert P. George resigned from Heritage’s board the same month, writing that he and Roberts had “reached an impasse” after Roberts apologized for the video’s tone but would not retract its substance. Two more board members, Shane McCullar and Abby Spencer Moffat, resigned in December. More than a dozen staffers, including much of Heritage’s legal and economic-policy teams, left for former Vice President Mike Pence’s think tank, Advancing American Freedom. Roberts has said he is staying in his post.
That dispute is not about the substance of Project 2025’s church-state or reproductive-policy proposals; it is a separate fight over Heritage’s posture toward antisemitism on the political right, and the record on it is genuinely still unfolding. It belongs in this piece only because it is the clearest public evidence of how unsettled Heritage’s own institutional footing was by mid-2026, even as the document it produced kept moving through federal agencies on its own schedule.
Verdict: Documented blueprint. Heritage Foundation wrote a governing blueprint that would reach into church-state law, reproductive rights, LGBTQ policy, and the civil service. Its named candidate disavowed the document in public while Heritage’s own president called the overlap between it and the candidate’s platform “tremendous.” Both things happened at once, on the record, and the disavowal did not slow the document down: federal agencies have since built more than half of it.
The Heritage Foundation was not contacted for comment on this piece.