Administrative Rules in Wisconsin

Junjie Guo and Ananth Seshadri

Executive Summary:

  • A series of Acts and Executive Orders under Governor Walker limit the ability of state
    agencies in Wisconsin to promulgate administrative rules, including

    • Act 21 and Executive Order #50 in 2011. In particular, Act 21 limits agencies
      to only passing standards or regulations that are explicitly permitted or required
      under state law
    • Acts 39 and 57 in 2017. Known as the REINS Act, Act 57 requires state legislative
      authorization of administrative rules that carry compliance and implementation
      costs of $10 million or more over a two-year period
  • Using data from the Wisconsin Administrative Register, we find
    • a significant drop in the number of approved rules since 2011
    • no significant change around 2017 in either the number of proposed rules or the
      number of approved rules
  • The insignificant change around 2017 could be a result of two opposite effects of the
    REINS Act that we will investigate in the future

    • A decrease in the number of administrative rules that cost $10 million or more
      over a two-year period
    • An increase in the number of administrative rules that cost less than $10 million
      over a two-year period, which could happen if state agencies split some high cost
      rules into multiple low-cost rules to avoid legislative authorization

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