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When does a new rule take effect?

Not when it is published, and usually not on one single date. A rule change

typically creates several dates, and they mean different things.

The dates a rule change creates

Comment deadline. Only on a proposed rule. The last day an objection

counts. Thirty days is common. After it passes the agency moves to adoption

and your chance to influence the text is over.

Hearing date. Some rulemakings hold one. You can usually speak or send a

written statement.

Effective date. The rule is now law. Often thirty to sixty days after

adoption is published, and sometimes the first day of the next quarter.

Compliance date. The date you must actually be doing the thing. Frequently

later than the effective date, which is the part that catches people out. A

rule can be in force in March with a compliance date the following January.

Phase-in dates. Larger employers first, smaller ones later, is a common

pattern. The date that applies to you depends on your headcount.

Sunset date. Some rules, particularly emergency ones, expire.

Why "effective" is not the date to diarise

If a rule takes effect on 1 July and requires annual training completed by

31 December, the date that matters to you is December. Reading only the

effective date and calling it done is how a business ends up compliant with

the existence of a rule and not with its requirements.

Emergency rules are the exception worth knowing. They can take effect

immediately on publication, with no comment period, and typically expire after

a set number of months unless made permanent.

Finding the dates for a specific rule

Every notice states them, though rarely in one place. Look for a section

headed "Effective date", "Compliance", or "Dates" near the top or the very

end. Where the notice says something like "180 days after publication", the

date is calculated from the publication date printed on the issue.

If the dates are genuinely unclear, the notice names a contact at the agency.

They answer.

What we do

Regulatory Update extracts every date a change creates, labels which kind it

is, and sends each one as a calendar invite attached to your digest. If an

agency moves a date, the invite updates the event already in your calendar

instead of adding a second one. $5 a month.

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