Given the cancellation of an expected meeting between President Trump and the congressional Democratic leadership, it appears there will not be any agreement about appropriations for fiscal year (FY) 2026 before the start of the new FY. Absent enacted funding past September 30, 2025, a federal shutdown will begin at 12:01 a.m. (EDT) on October 1, 2025.

Now What?

There was hope for a Continuing Resolution (CR) of some length that would have allowed negotiations to continue about funding the new FY. That appears not to be happening, and in fact, with a shutdown, it is not clear how long a shutdown might last or what kind of options (short of a full-year appropriations agreement) might be fashioned to allow the government to reopen.

Across the government, agencies have developed shutdown procedures that distinguish “essential” and “non-essential” personnel. Military defense, aircraft controllers, and various functions are maintained, while many other functions stop until funding is authorized (example — processing passport applications — which can interrupt trip planning with little recourse).

For the U.S. Environmental Protection Agency (EPA), some functions continue — such as keeping laboratory animals alive or ensuring safety at Superfund sites. EPA staff and functions generally are interrupted, and depending on the length of the shutdown, work of the programs can be seriously delayed.

For the pesticide program at EPA, with funding partially provided by the Pesticide Registration Improvement Act (PRIA), shutdown delays in the past have caused significant disruptions in processing registration submissions. The most recent legislation authorization of the fee program, PRIA 5, directs that “to the maximum extent practicable,” the pesticide program’s work continues during a shutdown. Some work is likely to continue, but delays are likely since, among other reasons, approximately two-thirds of the program budget is funded by appropriations that are subject to the shutdown.

Some staff is likely to remain on duty to conduct work supported by PRIA fees; those staff and functions are identified in the EPA Contingency Plan for Shutdown (Shutdown Plan). There can be indirect effects that are difficult to predict. For example, although certain staff is allowed to work, the office security or IT systems might be impacted in ways that hinder or block necessary activities needed by staff to work on registration actions. This would be part of the unknown implications of how the management defines “maximum extent practicable.”

EPA will be evaluating what level of PRIA funds are available and determine how long staff would be able to continue its work given other implications in the overall Shutdown Plan. The best guide to what the ultimate impact might be on program performance is a simple correlation between the length of any shutdown and the impact on Agency performance in any media program, with or without fee support such as PRIA. A longer shutdown will have a greater impact. A past shutdown that lasted more than a month led to delays in PRIA schedules for many months — much longer delays than a day-for-day tally of how long EPA was closed.

As events unfold in the next few days, there should be more information provided by EPA about any shutdown implications.