The Durability of Governance Reform

A Two-Wave Audit of Notice and Comment Policymaking in China
June 13, 2022

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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 notice and comment policymaking 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 governance reforms in China. Nevertheless, the audits—which the authors carried out in 2014 and 2021—demonstrate that, subject to a number of constraints, notice and comment policymaking was routinely implemented by government organizations throughout 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 the procedure brings more than a veneer of transparency to Chinese policymaking.