Meet the think tank planning a second Trump administration. (It’s not Project 2025.)

Planning for a second Donald Trump White House has been years in the making.

Key members of the former Trump administration diaspora have been quietly poring over Biden administration regulations, interviewing hundreds of former officials, and drafting executive actions for the launch of Trump’s next term if he wins. The goal: Stand up a professionalized administration that can move quickly to undo President Joe Biden’s legacy, avoiding the chaos that bogged down the Trump team after 2016.

It’s not the high-profile Project 2025 initiative from the Heritage Foundation, which has drawn condemnation from Trump — and become a bogeyman for the left. The transition planning is coming, instead, from a different conservative think tank: America First Policy Institute.

That planning has taken place largely outside the official Trump campaign, whose own transition planning is months behind the schedule of his first bid for the White House. But Trump and top aides are aware of the outside effort, and many Republicans view it as a key supplement to the formal Trump transition effort, as long as it stays out of the spotlight — and avoids angering Trump.

The America First Policy Institute, filled with Trump loyalists and insiders, was blessed by Trump before it was founded in 2021. Its CEO, Brooke Rollins, has had a close relationship with Trump for years and has discussed the think tank’s transition plans with him, according to two people familiar with the meeting; this month, the former president named the group’s board chair, Linda McMahon, to co-lead the official transition team.

“For three and a half years, AFPI has focused on personnel and policy. It was formed by and is teeming with senior staffers from the first Trump Administration whose goal is to be ready on day one,” said Kellyanne Conway, the former Trump adviser who chairs AFPI’s Center for the American Child. “Linda McMahon, Brooke Rollins and the team have planned with precision and executed with put-your-head-down type humility.”

Lobbyists have taken note and are directing their clients to meet with AFPI or suggesting policy. The think tank has an emphasis on deregulating the federal government and limiting its reach. It has been “drinking from the fire hose,” said one lobbyist who has been asked to advise AFPI and emphasized that the think tank sat “in the driver seat on transition.” (Like most others interviewed for this article, the lobbyist was granted anonymity to discuss sensitive dynamics in Trump’s orbit.)

AFPI, as a 501(c)3 non-profit, cannot support a candidate for office. The group is careful to note that it is unaffiliated with any specific campaign or candidate, and so far, it has avoided a cardinal sin in Trump’s world: publicly asserting proximity to or influence with Trump it does not have. The group has sought to avoid public attention — or the kind of firestorm that has engulfed the Heritage Foundation’s Project 2025.

AFPI staffers “have been quietly focused on helping current and future leaders at the local, state and national level enact policies to reverse the damage caused by the radical left and put the interests of the American people first,” the think tank said in a statement. “AFPI does not speak on behalf of any officeholder or campaign.”

But the think tank’s connections — and access — to Trump and his allies run deep. And some Republicans see it as a key player in the potential preparations for 2025, especially as the campaign itself has not built out a robust transition plan.

“AFPI is not becoming the transition,” said a person familiar with the Trump campaign’s transition prep, granted anonymity to discuss private plans. “But by virtue of how they are situated and that we are in a very late timeline for this work, AFPI and the transition may be a distinction without a difference.”

The think tank has drawn criticism from the left for its association with 2020 election denialism, including its participation in a Georgia lawsuit over the power of local officials to contest election results certification .

The group is well-funded, though as a 501(c)(3) “dark money” nonprofit, it does not disclose its donors. In 2022, it brought in $23.6 million in revenue, according to a recent tax filing , and paid a number of former Trump administration officials hundreds of thousands of dollars in compensation. The Trump loyalists inside the group, sometimes dubbed the former president’s “White House in waiting,” include Rollins — Trump’s former Domestic Policy Council director — and Larry Kudlow, his former National Economic Council director.

Trump has hosted fundraisers for AFPI at his Mar-a-Lago club, his PAC Save America donated to the group, and his first major speech in Washington since leaving the White House was at an AFPI event.

“They got permission from Trump,” said Bryan Lanza, a lobbyist who served on Trump’s first transition team. “Linda’s a former Cabinet official, she’s now in the transition. I think that sort of shows that there’s some connective tissue.”

AFPI has yet to release any final materials that will define its “America First Transition Project” for Trump’s next term. But the group’s broad publicly released agenda focuses on deregulation of the federal government, greater rights for religious groups and an aggressive crackdown on crime, among other issues. It supports greater oil and gas production, the completion of the border wall and the limitation of federal spending. It has also expressed support for declaring Antifa a domestic terrorist group and making Trump’s tax cut legislation permanent.

Its staffers have conducted extensive research with a goal of going deep into what an early memo described as the “management, personnel, policy, financial, and administrative” strategies to run the federal government.

AFPI has held more than 1,000 interviews with former administration officials and analyzed every Biden administration executive order, according to a person familiar with its work, and is drafting more than 100 proposed executive actions. Lanza said the group has compiled the titles of key jobs to prioritize filling in the next administration.

As AFPI has worked to build its plans for a second Trump White House, lobbyists have seized on the opportunity to influence its agenda. Some said they have pushed clients to meet with its staff. One Republican lobbyist said they had pushed the think tank to focus on undoing Biden’s labor policy, an issue of particular import to their clients.

There’s a common misconception, one lobbyist said, that the best way to influence a Trump White House is to get to Trump himself. But that’s actually not the case on detailed policy issues, the lobbyist said: “On economic issues, regulatory matters, policy issues, it’s not that straightforward, right? In fact, most of the time, you have to work bottom up.”

One Republican lobbyist was asked to review detailed plans for federal departments. Another said AFPI had asked for recommended actions for their former office for Day 1, the first 100 days, and the first 200 days.

“Their goal is … to get a structure in place that will allow for the correct formula of personnel and pursuing the right policy early on,” said one Republican lobbyist who worked for the Trump administration. “They have stuff ready to go off the shelf that they can present as options.”

Its efforts are intended, in part, to ensure a smoother start to the next Trump administration. Trump’s unexpected win in 2016 scrambled a tumultuous transition project that was initially led by former New Jersey Gov. Chris Christie — until Trump fired him days after he won the election.

"We have announced a transition leadership team and expanded the team this week,” said Trump campaign spokesman Brian Hughes in a statement. Both the transition team and campaign are preparing “for the hard work of undoing the failure and chaos” of the Biden-Harris administration, he said: “Transition efforts, as with the campaign, implement President Trump's agenda, and after a victory in November it will be President Trump who leads the work to build the team for an historic next term leading our nation."

The current official transition effort is still being built out, according to a person familiar with the plans, who said that vetting for potential cabinet positions — or even the initial brainstorming of those names — has not begun in earnest, although Trump has already floated different names for certain positions.

In mid-August, Trump announced that his transition team will be led by McMahon and Howard Lutnick, the CEO of Cantor Fitzgerald and long-time friend and donor of Trump. Trump’s two adult sons, Eric Trump and Donald Trump Jr., along with Trump’s running mate Sen. JD Vance , were named honorary co-chairs of the transition operation.

Trump this week added Robert F. Kennedy Jr. and Tulsi Gabbard as honorary co-chairs, although it is unclear exactly how much influence they will have on personnel or policy.