Circular A-4: A Comparison between the 2023 Draft and the 2003 Circular

June 16, 2023

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On April 6, the Office of Management and Budget (OMB) issued proposed revisions to Circular A-4. The current Circular, issued in 2003, has provided guidance to federal agencies on the development of regulatory analysis for 20 years. Pursuant to Executive Order 14094 (Modernizing Regulatory Review), OMB proposed to revise the Circular to reflect new developments in economic and other scientific understanding. The 91-page revised draft of Circular A-4, along with a preamble, includes revised and expanded guidance on various aspects of regulatory analysis, such as scope of analysis, alternative regulatory approaches, developing benefit and cost estimates, distributional effects, treatment of uncertainty, and discount rates. This Regulatory Insight provides a section-by-section comparison between the 2023 draft and 2003 Circulars and a descriptive discussion about major changes in each section.

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More coverage of the 'Modernizing Regulatory Review' actions from the RSC:


Public Interest Comments



Adding Engagement Upstream by Bridget Dooling considers the measures proposed in the Modernizing Regulatory Review actions designed to increase proactive outreach for the rulemaking process. Published in the Yale JREG Notice & Comment symposium.
June 2, 2023
In her post, Circular Reasoning?, Susan Dudley evaluates the OMB Draft Circular A-4 for the Yale JREG Notice & Comment symposium
May 25, 2023
Susan Dudley's analysis for Forbes digs deeper into definitional terms: Regulatory Review Revisited
April 13, 2023
Susan Dudley shares an initial take in Modernizing Regulatory Review Actions
April 7, 2023
Bridget Dooling introduces the EO and major themes for the Yale JREG Notice & Comment blog: White House Moves to Modernize Regulatory Review
April 6, 2023


June 12, 2023: Challenges With Distributional Weighting in the Draft Circular A-4. Mary Sullivan explains how weighting lessens transparency and creates trade-offs in economic efficiency of regulations.
April 26, 2023: What’s In the EO on Modernizing Regulatory Review? Mark Febrizio and Bridget Dooling unpack the highlights and discuss next steps in the proposal.

Additional Resources