The Modernizing Retrospective Regulatory Review Act (SB644) codifies a multi-stage modernization of how federal regulations are reviewed after they are issued. It defines key terms (including the Administrative Committee of the Federal Register, the Administrator, and what qualifies as a retrospective review) and sets out a structured timeline for data availability, technology-enabled analysis, and agency planning.
The bill’s core idea is to embed a formal process so agencies routinely reassess regulations, using machine-readable formats and AI-assisted tools to identify obsolete rules, burdensome provisions, and errors, while ensuring staff are trained to use the tools.
Why this matters: if enacted, the bill would shift retrospective reviews from ad hoc efforts to a disciplined, agency-wide program with mandated milestones. By pushing for machine-readable regulations and guidance on technology use, it aims to improve transparency, speed, and consistency in rulemaking accountability, while giving agencies a clear path to modernize how they evaluate existing regulations over time.
At a Glance
What It Does
Not later than 180 days after enactment, the Director of the OMB must report on the availability of regulations in machine-readable format, with input from the Director of GPO, the Archivist, and the Director of the Federal Register. Not later than 18 months, the OMB Director must issue guidance on using technology (including AI) to conduct retrospective reviews and how to train staff. Not later than 2 years, each agency must submit a plan for implementing the guidance, and within 180 days of plan submission, implement the strategy.
Who It Affects
Federal agencies that issue regulations, the OMB (Office of Management and Budget) and its Administrator, the Director of GPO, the Archivist of the United States, and the Administrative Committee of the Federal Register. Also impacts agency regulatory policy teams tasked with performing retrospective reviews.
Why It Matters
It institutionalizes modern data and tech-enabled oversight of regulations, aiming to make retrospective reviews faster, more accurate, and more scalable across agencies, with a formal process for implementation and reporting.
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What This Bill Actually Does
The bill lays out a formal framework for how federal agencies should look back at their regulations after they’re issued. It creates specific definitions to standardize who does what (for example, what counts as a retrospective review and who coordinates the machine-readable publication of rules).
First, it requires a 180-day report from the Director of the Office of Management and Budget (OMB), in coordination with the Director of the Government Publishing Office (GPO), the Archivist, and the Director of the Federal Register, to assess how many agency regulations are available in machine-readable formats and how the Federal Register’s eCFR and the GPO’s CFR editions are recognized as the official legal editions.Second, not later than 18 months after enactment, the Director of OMB must issue guidance on using technology, including algorithmic tools and AI, to conduct retrospective reviews. The guidance should explain how to identify regulations that are obsolete, burdensome, or flawed, how to procure and apply the necessary technology, and how to train agency staff to use it effectively.Third, within 2 years, the head of each agency must submit a plan outlining a strategy to implement the guidance for their regulations and to identify which regulations (or categories) should be reviewed after issuance.
The plan must also specify any data or ex-post analyses the agency deems necessary. Finally, within 180 days after submitting the plan, agencies must implement the strategy for retrospective reviews of their regulations.Overall, the act signals a move toward more systematic, data-driven, and transparent retrospective reviews, leveraging machine-readable formats and AI-enabled analysis to sharpen regulatory quality over time.
The Five Things You Need to Know
The bill requires the Director of OMB, in coordination with GPO, the Archivist, and the Director of the Federal Register, to deliver a 180-day report on machine-readable regulations.
The Director of OMB must issue AI-enabled retrospective review guidance within 18 months, including training requirements for agency staff.
Each agency must submit a detailed retrospective review plan within 2 years and outline data or ex-post analyses needed.
Agencies must implement the retrospective review strategy within 180 days of submitting their plan.
The Administrative Committee of the Federal Register and the CFR editors are expressly involved through the bill’s machine-readable and official edition references.
Section-by-Section Breakdown
Every bill we cover gets an analysis of its key sections.
Definitions and key terms
This section defines terms used throughout the act, including the Administrative Committee of the Federal Register, the Administrator of OMB, the term 'agency,' 'appropriate congressional committees,' 'machine-readable,' and 'retrospective review of a regulation.' The definitions create a consistent framework for the subsequent requirements and establish the scope of what counting and reviewing entails.
Machine-readable regulations report
Within 180 days, the Director of the OMB must deliver a report on the progress of making agency regulations machine-readable, coordinating with the Director of GPO, the Archivist, and the Director of the Federal Register. The report must assess current machine-readability coverage and how the eCFR and official CFR editions are recognized as the official legal edition.
Guidance on technology use for reviews
Within 18 months, the OMB Director must issue guidance on using technology to perform retrospective reviews, including recommended uses of AI and algorithms, procurement approaches, and training plans for agency personnel. The guidance should reflect any findings from the 180-day report and address how to identify obsolete, burdensome, or erroneous regulations.
Agency retrospective review plan
Within 2 years, agency heads must submit a plan detailing how they will implement the guidance for their regulations, identify regulations or categories that should be reviewed post-issuance, and specify data or ex-post analyses that will support the review process.
Agency implementation
No later than 180 days after plan submission, agencies must implement the retrospective review strategy described in their plan, applying the guidance to actual reviews of agency regulations.
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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
- OMB regulatory policy staff gain clearer direction and data to assess regulatory burdens.
- Director of GPO benefits from streamlined, machine-readable CFR processes that align with official editions.
- Administrative Committee of the Federal Register gains clearer workflows and authority for CFR alignments.
- Agency regulatory program offices receive a defined pathway and resources to conduct retrospective reviews.
- Regulated industries’ compliance teams and researchers benefit from more accessible, machine-readable regulations.
Who Bears the Cost
- Federal agencies must allocate staff time and budget to develop, submit, and implement retrospective review plans.
- Agency IT and data management teams may incur costs to enhance machine-readable formats and AI-enabled tools.
- Omb and agency staff resources are diverted to prepare the 180-day report and ongoing guidance implementation.
- GPO and ACFR operations may require additional resources to maintain alignment with machine-readable standards.
- Procurement and maintenance of AI tooling and data analytics capabilities will impose upfront and ongoing costs on agencies.
Key Issues
The Core Tension
The central dilemma is balancing speed and consistency in retrospective reviews with the need for careful, human-validated judgments about which regulations truly merit revision or repeal, especially when algorithmic tools shape what counts as an 'obvious' improvement.
The bill’s push toward AI-assisted retrospective reviews raises questions about accuracy, governance, and oversight. Relying on technology to identify what is ‘obsolete,’ ‘burdensome,’ or ‘inaccurate’ in regulations could lead to misclassification if models are not properly trained or if data quality varies by agency.
The act does not specify funding mechanisms to support the new requirements, which could strain agency budgets and affect implementation timelines. There is also the risk that differences in agency capabilities could lead to uneven application of the guidance, creating a patchwork of retrospective practices rather than a unified federal standard.
Finally, while the bill emphasizes machine readability and ex-post analyses, it leaves open how to handle sensitive regulatory areas or exemptions where automation may not be appropriate. The central tension is whether the speed and uniformity gained through AI-enabled reviews justify the potential for errors or over-reliance on automated tools absent robust governance.
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