The durability of governance reform: A two‐wave audit of notice and comment policymaking in China

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 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.