Policy as code

The tools now exist to close the gap between regulatory intent and machine execution. Readers can test one out below

Workers using keypunches at the Baltimore Social Security Office, Maryland (1965)

One day, we will look back and wonder how government was able to work effectively through PDFs

Title 12 of the Code of Federal Regulations (CFR) governs banks and banking. It has 18 chapters spanning multiple volumes and thousands of pages. Every proposed rule change — like the federal banking agencies’ recent Basel 3 reproposal — must be published in the Federal Register. When rules are finalized, Title 12 of the CFR gets updated.

All of those releases are all via PDFs.

The translation problem with PDFs

The Government Publishing Office’s adoption of PDFs in the 1990s coincided with the rise of the internet. In today’s day and age, though, the PDF is about as helpful as the punchcard.

For regs to be effective, they need to be able to be translated into verifiable actions, processes, and systems that match the requirements laid out in the rule. Traditionally, this has been done manually, with people readi…