In this Special Analysis Edition of The Federal Daily, we examine the Supreme Court’s February 20, 2026 decision holding that the International Emergency Economic Powers Act does not authorize the President to impose tariffs.

This episode moves beyond the daily authority audit format to provide a structured review of the Court’s reasoning, including the role of the major questions doctrine, the constitutional allocation of taxing power, and the division between executive flexibility and legislative authority.

We also discuss the administrative and business implications of the ruling, including the mechanics and uncertainty surrounding potential tariff refunds, and assess alternative statutory pathways such as Sections 232, 301, and 122.

The decision narrows one asserted lane of executive trade authority while reinforcing the Court’s demand for clear congressional delegation in matters of major economic consequence.

The day’s federal activity centered on a Supreme Court ruling redefining executive trade authority and the Treasury’s articulation of economic policy priorities.

The United States Supreme Court held that the International Emergency Economic Powers Act does not authorize the President to impose tariff duties. In a majority opinion, the Court clarified the statutory limits of executive authority under IEEPA, vacated one lower court proceeding for lack of jurisdiction, and upheld another related ruling. The decision constrains presidential discretion over tariff measures and shifts structural leverage over trade policy back toward Congress.

The Treasury Secretary delivered remarks before the Economic Club of Dallas outlining departmental priorities related to economic security, illicit finance, market resilience, and emerging technologies. While not a binding regulatory action, the speech signals Treasury’s supervisory and enforcement posture, shaping interagency coordination and compliance expectations within the financial sector.

Executive branch regulatory and enforcement actions drove institutional authority movement, with shifts concentrated in financial supervision and sanctions execution.

Sudan Sanctions Designations
The Department of the Treasury designated Sudanese paramilitary commanders under existing sanctions authorities. The action imposes binding financial restrictions and reallocates enforcement leverage to the executive branch in response to documented atrocities, directly affecting transaction prohibitions and compliance obligations.

OCC Appeals Rule Proposal
The Office of the Comptroller of the Currency advanced a notice of proposed rulemaking to modify the bank supervisory appeals process. The proposal would alter procedural pathways available to regulated institutions challenging supervisory determinations, affecting administrative review structure within federal banking oversight.

Federal Reserve Regulatory Review
The Federal Reserve approved a banking application and announced a hybrid outreach meeting as part of its regulatory review under the Economic Growth and Regulatory Paperwork Reduction Act. The approval confers operational authority to the applicant institution, while the review process signals potential recalibration of supervisory frameworks and regulatory burden across the banking sector.

Federal institutional movement occurred primarily through administrative channels as Congress remained procedurally inactive.

Congressional Inactivity
The House and Senate convened only in pro forma sessions, with no floor debate, procedural votes, or committee activity. No authority shifted legislatively, reinforcing continued reliance on executive and regulatory processes for near-term policy movement.

NASA Categorical Exclusions
As published in the Federal Register, NASA adopted categorical exclusions under environmental review law. This expands the agency’s discretion to proceed with specified projects without full environmental impact statements, accelerating internal timelines and narrowing procedural constraints.

SEC Exchange Fee Rule
The Securities and Exchange Commission filed a notice of immediate effectiveness regarding exchange connectivity fees. Acting under its oversight authority of self-regulatory organizations, the SEC preserved discretion over market infrastructure costs, affecting trading participants and exchange operations.

Federal institutions operated through procedural continuity and administrative action, with limited legislative output but ongoing regulatory and executive activity.

Congressional Pro Forma Sessions
Both the House and Senate convened brief pro forma sessions, as recorded in the Congressional Record and reflected in legislative calendars. No votes or substantive floor business occurred. These sessions preserved each chamber’s formal status as in session, maintaining constitutional continuity and affecting appointment and oversight authority.

Federal Register Rulemaking Activity
The Federal Register published more than one hundred notices and multiple proposed and final rules across agencies. Ongoing rulemaking, including updates affecting health and safety programs and regulatory requests for information, illustrates continued administrative implementation within existing statutory frameworks.

Executive Order Publication
Executive Order 14386 was published, addressing national defense and energy policy considerations. Publication formalizes executive direction within the administrative process and signals continued executive engagement in industrial and energy policy through established legal mechanisms.