The directive must suspend, pause, or cease the agency's normal work as a whole. This includes: instructions that require employees en masse to not report to the physical office (e.g. "the office is closed" or "access is denied"), where such closure is meant to stop operations rather than merely shifting them to a remote setting; directives that en masse order employees to stop, pause, or suspend all work-related duties—such as halting its regulatory, enforcement, or administrative functions—even if exceptions exist for a small number of essential roles; and orders that effectively place the agency in a state of operational pause by instituting widespread furloughs or firings.

If a directive specifies limited closures with narrow exemptions (e.g. only for a specific department), it qualifies only if those exemptions are strictly defined and do not allow the agency's core functions to continue normally. If the directive includes waivers for certain tasks, the order qualifies provided the waivers are limited in scope and do not cover the agency's primary, core, or most functions. If a directive exempts a small cadre of essential staff while halting nearly all routine operations, the order qualifies as long as the exemptions do not enable the agency to perform its principal functions. Waivers that allow limited back-office tasks or non-critical work to resume will not disqualify the order if the overall operational capacity remains suspended.

If the agency is a sub-agency within a larger organization and a qualifying directive is issued to the parent agency covering operational suspension, then that directive is deemed to apply to the sub-agency as well.