The bill adds section 3522 to chapter 35 of title 44, directing the OMB Director to update Information Quality Act guidelines within one year and to publish those guidelines online. Agency heads must then update their agency-specific guidelines, publish them, use the best reasonably available, fit-for-purpose evidence when developing or explaining rules and guidance, and make administrative correction mechanisms available for influential information.
Crucially, the bill requires agencies to put the ‘‘critical factual material’’ and citations that informed a rule or guidance into the rulemaking docket or the administrative record (and to provide notice-and-comment on that material when appropriate). Agencies must, where feasible and consistent with law and costs, make those materials available as open government data assets, describe when materials cannot be disclosed, and include complaint information in existing Information Quality Act reporting.
The Act authorizes no additional funds.
At a Glance
What It Does
The bill directs OMB to update existing Information Quality Act guidelines and requires agencies to rely on the best reasonably available, fit-for-purpose evidence when creating rules or guidance. It obligates agencies to publish the critical factual material and source citations in the rulemaking docket or administrative record and, where possible, to provide those materials as open government data.
Who It Affects
Rulewriters and evidence teams across all federal agencies, OMB’s Office of Information and Regulatory Affairs, providers of proprietary research and datasets used in rulemaking, and external stakeholders who track, comment on, or challenge agency evidence (researchers, industry compliance teams, and public-interest organizations).
Why It Matters
This statute shifts transparency standards for federal rulemaking by turning the supporting data and analyses into an explicit disclosure obligation and an open-data preference, which will alter how agencies procure, store, cite, and defend evidence—without new appropriations to support that work.
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What This Bill Actually Does
The bill creates a new statutory section that builds on the Information Quality Act and the Foundations for Evidence-Based Policymaking Act. Within one year of enactment, the Director of OMB must revise governmentwide guidelines to give agencies concrete policy and procedural guidance for ensuring the quality, objectivity, utility, and integrity of influential information used to develop rules or to explain their bases.
OMB must post those updated guidelines online.
After OMB issues updated guidance, each agency must revise its own Information Quality Act procedures to require reliance on the ‘‘best reasonably available’’ evidence that is ‘‘fit-for-purpose’’ when developing or explaining rules and guidance. Agencies must publish those updated agency-level guidelines on their websites, make available the administrative correction mechanisms referenced in the Information Quality Act for influential information, and include complaints tied to influential information in an existing report required under the Information Quality Act.The bill sets an explicit public-disclosure regimen: agencies must place the critical factual material they relied on into the rulemaking docket or administrative record at or before the time of promulgation, and if a matter is subject to notice-and-comment, agencies must give the public an opportunity to comment on that critical factual material.
If the material is revised in a way that could materially affect the outcome, agencies must post the revision in a timely way. Where permitted by law and feasible given costs, agencies are expected to make that critical factual material available as open government data; if full disclosure is precluded by statute, privacy law, FOIA exemptions, copyright, or practical constraints, agencies must document why the information cannot be posted and explain steps being taken to increase public access.The bill also governs format and third-party data: if an agency cannot publish underlying files (for example, because a private holder claims reproduction rights), the agency must maximize access, provide a citation or description, and identify the holder and how a member of the public may request a copy.
The statute defines ‘‘influential information or evidence’’ as information the agency reasonably determines will have a clear and substantial impact on important public actions or private decisions, and it cross-references the Act’s definition of ‘‘evidence.’
The Five Things You Need to Know
OMB must update Information Quality Act guidelines and post them within one year of enactment.
Agencies must place the ‘‘critical factual material’’ and citations that informed a rule or guidance into the rulemaking docket or administrative record at or before promulgation, and provide notice-and-comment on that material when applicable.
Unless barred by law or costs, agencies must make critical factual material available as open government data assets; if they cannot, they must explain why and identify any third-party holder of reproduction or distribution rights and how the public may request access.
Agencies must make available administrative mechanisms for seeking correction of influential information and include complaints about influential information in their Information Quality Act reports.
The Act contains no new appropriations—agencies must implement these duties within existing resources.
Section-by-Section Breakdown
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Short title
States the bill’s short title: the Information Quality Assurance Act of 2025. This is a standard caption provision that signals the bill’s focus on strengthening information quality obligations across the executive branch.
OMB to update and publish governmentwide guidelines
Requires the OMB Director to revise the Information Quality Act guidelines within one year to give policy and procedural guidance on ensuring the quality, objectivity, utility, and integrity of influential information used for rules and guidance. The revised guidelines must be consistent with chapter 35 and the Foundations for Evidence‑Based Policymaking Act of 2018, and OMB must publish the updates on its website so agencies and the public can find them.
Agency-level updates, publication, and reporting
Directs each agency head to update agency-specific Information Quality Act procedures to require reliance on the best reasonably available, fit‑for‑purpose information for influential information or evidence. Agencies must publish their updated procedures online, ensure the availability of administrative correction mechanisms referenced in the Information Quality Act, and include complaints about influential information in the statutory report (the subparagraph (C) report) required by the Information Quality Act.
Docketing critical factual material and timing
Mandates that agencies put the critical factual material and citations that informed a rule or guidance into the rulemaking docket or administrative record and directs agencies to provide the material to the public as soon as reasonably possible, and at minimum at the time of promulgation or issuance. If the agency is using notice-and-comment procedures, it must give the public notice and an opportunity to comment on the critical factual material; any revisions that could materially affect the action must be posted before final publication.
Exceptions, format, and open data preference
Requires agencies to implement disclosure consistent with other statutes (notably the Freedom of Information Act and Privacy Act, and relevant intellectual property statutes) and to consider costs. By default, agencies must make critical factual material available as open government data assets, but when legal or cost constraints apply they must maximize access, provide citation or description, and identify any third-party holder with rights to limit reproduction and how the public can request access. If material cannot be disclosed, the agency must explain why and describe steps being taken to increase access.
Definitions, table of sections, and funding limitation
Defines key terms: it adopts the statutory definition of 'evidence' from section 3561 and defines 'influential information or evidence' as information an agency can reasonably determine will have a clear and substantial impact on important public actions or private decisions. The bill also amends the subchapter table of sections and contains an explicit 'no additional funds' clause, meaning agencies must absorb implementation costs within existing budgets.
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Explore Government in Codify Search →Who Benefits and Who Bears the Cost
Every bill creates winners and losers. Here's who stands to gain and who bears the cost.
Who Benefits
- Researchers and independent analysts — they gain earlier and more complete access to the data, models, and citations agencies used, enabling verification, reproduction, and independent analysis that can shape public comment and litigation.
- Public-interest and oversight organizations — greater docket transparency and a mandate to post critical factual material improves watchdogs’ ability to hold agencies accountable for the empirical bases of rules.
- Regulated entities and compliance teams — clearer visibility into the factual bases of rules lowers information asymmetry and can make it easier to design compliance systems or to prepare technically informed comments during rulemaking.
Who Bears the Cost
- Federal agencies — they must change procurement, data licensing, citation, and recordkeeping practices, prepare data for public release (including metadata and formats), and field correction requests without extra appropriations.
- Third-party data and research providers (private firms and academic licensors) — required disclosures may force renegotiation of licensing terms or lead to loss of exclusivity if agencies press for open delivery, creating transaction costs and potential withholding of data.
- OMB — it bears the immediate burden of drafting and publishing detailed, governmentwide guidance within a one-year window and needs to provide clear direction that agencies must follow, a nontrivial coordination task.
Key Issues
The Core Tension
The central dilemma is transparency versus feasibility and confidentiality: the bill forces agencies to expose the data and analyses behind major rules to improve accountability and reproducibility, but doing so can be legally and technically costly—or impossible when evidence rests on proprietary, privacy-sensitive, or classified sources—yet Congress provides no new appropriations to cover that work.
The bill tightens transparency and evidence standards but does so without new funding, creating practical implementation risks. Agencies will often rely on third-party proprietary datasets or contractor analyses that are not currently formatted for public release; converting those materials into reusable open-data assets requires time, legal negotiation, and technical work (redaction, metadata, API access) that the statute does not fund.
The text anticipates some of these constraints by including exception paths and by allowing agencies to consider costs, but it leaves unresolved how agencies should weigh cost against disclosure obligations and who decides when full disclosure is infeasible.
The statutory phrases 'best reasonably available' and 'fit-for-purpose,' and the threshold for what counts as 'influential information or evidence,' are conceptually useful but practically indeterminate. They invite agency judgment calls that could yield uneven implementation across agencies and potentially generate litigation over whether an agency relied on sufficient evidence.
The requirement to identify third-party holders of reproduction rights and to explain steps to increase access may reduce opacity, but it also creates a new procedural box-checking exercise and could pressure agencies into choosing between using the best available proprietary data and avoiding the administrative burden of securing or transforming data for public release.
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