Reinstate the PRO Good Guidance rule at DOL

Research notes

• “Moved the other way” under §3b: the Status stays not started and the contrary action carries the dated Primary Evidence. The PRO Good Guidance rule was a procedural commitment — publish guidance in a searchable database, take comment on significant guidance, treat guidance as non-binding — and the Department’s 2025-07-01 rule cuts procedural commitments rather than restoring this one.
• The adjacent proposal is https://www.federalregister.gov/documents/2025/07/02/2025-12314/statements-of-general-policy-or-interpretation-not-directly-related-to-regulations (RIN 1235-AA52, Final Rule Stage on the current agenda), which would remove 29 CFR chapter V subchapter B interpretive parts from the CFR and reissue them as sub-regulatory guidance. That moves material into guidance; the PRO Good Guidance rule was about how guidance is made and used. Adjacent, not this ask.
• Scan triage 2026-10-12 (fourteenth run): that adjacent proposal is withdrawn. The Wage and Hour Division withdrew the 2025-07-02 NPRM (90 FR 28985) on 2026-10-07 (FR 2026-20523, Statements of General Policy or Interpretation Not Directly Related to Regulations; Withdrawal of Proposed Rule). The interpretive parts of 29 CFR chapter V subchapter B stay in the CFR. This is not a reversal here, since the proposal never touched this item’s object. It does take one item off the “actions that touch guidance” list above. No row printed it. It was found by reading every new proposed-rule title in the round.
• The Chapter’s major ask on the same page, #1633 (amend the APA to limit guidance documents), is not started for its own reasons; the two do not share an instrument.