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Abstract
The notice and comment process, in which government organizations make public draft laws and regulations and solicit feedback on these proposals, is a prominent governance reform in contemporary China. This article examines the durability of the notice and comment process as a policymaking innovation by conducting a pair of audits of the practices of dozens of central government ministries and provincial governments. There are a number of reasons to expect that it is difficult to sustain policymaking innovations in China. Nevertheless, the audits—which were carried out in 2014 and 2021—demonstrate that, subject to a number of constraints, the notice and comment process diffused across government organizations in the period under analysis. Although the notice and comment process is a durable governance reform, additional research is needed before it can be concluded that it brings more than a veneer of transparency to Chinese policymaking.