On May 23, 2025, President Trump signed four executive orders (EOs) aiming to transform the U.S. nuclear energy sector. These directives, which involve targeting regulatory reform, fuel cycle revitalization, testing innovation, and national security deployment, constitute a notable nuclear policy shift. Together, they seek to reestablish U.S. leadership in nuclear technology, expand domestic capabilities, and strategically align nuclear energy with national security and export competitiveness.

Overall, key takeaways from the recent EOs include:

  • Revitalizing the Industrial Base: The administration seeks voluntary agreements under its Defense Production Act (DPA) authority with U.S. nuclear energy companies for nuclear fuel production and procurement.
  • Regulatory Reform: The Nuclear Regulatory Commission (NRC) must streamline licensing and modernize safety regulations.
  • Testing Acceleration: The Department of Energy (DOE) is mandated to expedite reactor testing outside national labs.
  • National Security Deployment: Advanced reactors will be deployed for military and artificial intelligence (AI) infrastructure resilience.
  • Export Strategy: The administration will pursue several new 123 Agreements, which are required by Section 123 of the Atomic Energy Act of 1954 for substantial exports of nuclear material or equipment from the United States.

Understanding Strategic Goals and Legal Authorities

To better understand the strategic objectives and legal foundations underpinning each executive order, let's examine them in detail:

Executive Order 14302

Reinvigorating the Nuclear Industrial Base, invokes §708(c)(1) of the DPA (50 U.S.C. 4558) and empowers the DOE to forge voluntary agreements with qualified companies to secure fuel supplies.

Key provisions of this order include:

  • Targeting 5 gigawatts of power uprates and beginning construction on 10 new large reactors by 2030
  • Prioritizing DOE loan support for advanced nuclear projects
  • Evaluating the feasibility of reactivating closed plants for military microgrid support
  • Expanding domestic uranium conversion and enrichment capacity
  • Halting the surplus plutonium dilute and dispose program (except for South Carolina commitments)

Executive Order 14299

Next, Deploying Advanced Nuclear Reactor Technologies for National Security directs:

  • The U.S. Army to operate a reactor on a domestic base by September 30, 2028
  • DOE to designate sites for AI-related infrastructure and deploy a nuclear reactor at the first site within 30 months
  • The Secretary of State to pursue at least 20 new 123 Agreements by January 2029
  • Identification and release of at least 20 metric tons of high-assay low-enriched uranium (HALEU) for eligible private projects
  • Legal authorization for privately funded fuel recycling and fabrication facilities on DOE/DOD-controlled sites

Executive Order 14300

The third executive order, Ordering the Reform of the Nuclear Regulatory Commission, mandates structural and cultural reform of the NRC. It imposes deadlines of 18 months for new reactor licenses and 12 months for renewals. Among its key reforms:

  • A shift from the linear no-threshold model toward “science-based” radiation exposure standards
  • Streamlining of the Advisory Committee on Reactor Safeguards
  • High-volume licensing processes for microreactors and modular designs
  • Accelerated approval processes for DOE/DOD-tested reactor designs that meet safety standards
  • Revisions to the public hearing and environmental review processes

Executive Order 14301

Finally, Reforming Nuclear Reactor Testing at DOE, establishes a pilot program for building and operating reactors outside the national lab network. It requires:

  • DOE to define “qualified test reactor” within 60 days
  • Expedited review of applications for pilot reactors with a target of achieving criticality by July 4, 2026
  • Prioritization of environmental review streamlining, including categorical exclusions for reactors on existing sites

Departures from Previous Policy

While pursuing an ambitious revitalization agenda, the executive orders also signal notable shifts from established policies and practices, as highlighted below:

The executive orders mark a clear divergence from longstanding U.S. nuclear policy:

  1. Fuel Recycling Authorization: For the first time in decades, commercial fuel recycling is encouraged. DOE must identify uranium and plutonium inventories suitable for conversion to fuel and support related private-sector efforts.
  2. Reduced NRC Independence: Some commentators have suggested that requiring NRC to be subjected to oversight by the Office of Management and Budget could potentially affect its traditionally independent and autonomous role.
  3. Environmental Exemptions: The orders authorize categorical exclusions from National Environmental Policy Act (NEPA) reviews for many federal nuclear projects, marking a departure from typical permitting practices.
  4. Defense Integration: The use of advanced reactors for powering AI data centers and military installations formalizes the link between nuclear energy and national security policy.

Timelines and Implementation

To ensure the effective execution of these policy directives, the administration has outlined specific timelines and implementation milestones across short, medium, and long-term horizons:

Short-Term (0–6 months):

  • DOE to define “qualified test reactors” and issue reactor site designations
  • Identification of usable DOE uranium/plutonium stocks
  • Updated excess uranium management policy
  • Voluntary agreements under the DPA initiated

Mid-Term (6–18 months):

  • NRC to issue proposed rules within 9 months and final rules by 18 months
  • DOE to complete environmental reform and initiate pilot reactor projects
  • Industry consortia to form under DPA guidance

Long-Term (through 2030):

  • 5 gigawatts of uprates to existing reactors
  • 10 new large reactors under construction
  • First operational advanced reactor at a military base by 2028
  • Expanded deployment at AI and defense-critical DOE facilities

Implications for Industry

These sweeping policy changes are poised to have far-reaching implications for the nuclear industry across multiple fronts, and the collective impact of these directives is broad:

  • Supply Chain Reconstitution: Voluntary DPA agreements and investment support will stimulate domestic fuel processing infrastructure.
  • Licensing Certainty: Fixed timelines for NRC reviews provide long-sought predictability for investors and developers.
  • Innovation Incentives: New testing pathways under DOE jurisdiction and NEPA streamlining reduce entry barriers for advanced reactor developers.
  • Export Opportunities: With a target of at least 20 new 123 Agreements, the administration aims to nearly double the current number of agreements (25, as of December 2024) and open new markets for U.S. firms, leveraging multilateral financing tools like the U.S. International Development Finance Corporation and the Export-Import Bank.
  • Guaranteed Demand: Designation of advanced reactors for powering critical national security and AI facilities could help developers overcome commercialization bottlenecks, securing early revenue streams.

President Trump's four executive orders represent a sweeping reorientation of nuclear energy policy toward national security, commercial competitiveness, and industrial revitalization. While their ambition is clear, execution will hinge on interagency coordination, legal durability, and sufficient appropriations. Industry participants should anticipate accelerated timelines, evolving licensing expectations, and a government eager to collaborate on fuel security and reactor deployment. For those navigating this dynamic regulatory environment, legal and strategic counsel will be essential in adapting to the new nuclear landscape.

As the only law firm with a former General Counsel of both the National Nuclear Security Administration (NNSA) and the Defense Nuclear Facilities Safety Board (DNFSB), Fluet has one-of-a-kind experience in Nuclear Law and continuously stays abreast of the latest developments to provide legal and strategic counsel that helps clients adapt to the dynamic nuclear ecosystem. To learn more about Fluet’s Nuclear Law capabilities, click here.