The Comment Integrity and Management Act requires federal agencies to implement human-verification processes and standardized management procedures for handling mass and computer-generated public comments during the regulatory rulemaking process.
Clay Higgins
Representative
LA-3
The **Comment Integrity and Management Act** aims to improve the federal regulatory process by requiring agencies to verify that electronic public comments are submitted by humans. The bill establishes new protocols for identifying and managing mass or computer-generated comments, ensuring they are handled efficiently while maintaining the public's ability to participate in rulemaking.
Comment Integrity and Management Act: New Rules for Online Public Feedback and AI Bots in Rulemaking
When the government proposes a new regulation—whether it’s about food safety, overtime pay, or environmental standards—they are legally required to listen to what you have to say. For years, advocacy groups have used 'mass comment' campaigns to flood these agencies with thousands of identical emails to show strength in numbers. The Comment Integrity and Management Act aims to overhaul this process by requiring agencies to verify that commenters are actually human and giving them the power to 'sample' mass feedback rather than listing every single entry in the public record.
The Bot Check at the Digital Door
Under Section 3 of the bill, federal agencies must now verify, 'to the greatest extent possible,' whether an electronic comment is coming from a human being. Think of it like a government-wide CAPTCHA system. If you’re a small business owner trying to weigh in on a new tax rule, you might have to jump through an extra digital hoop to prove you aren't a script. The bill also takes aim at the rise of AI, defining 'computer-generated comments' as those primarily produced by software. Agencies will have one year to set specific policies on how they’ll handle these AI-generated submissions, which could mean they are flagged or potentially given less weight than a note written by a real person.
Quality Over Quantity?
One of the biggest shifts involves how 'mass comments'—those identical forms you might sign onto via a non-profit’s website—are displayed. Instead of a digital docket showing 50,000 individual entries, agencies can now post a single representative sample and just note the total number of people who sent it. For a busy citizen, this might make the online docket easier to read. However, for the organizers of these campaigns, it means their 'wall of support' gets condensed into a single paragraph and a tally mark. The bill includes a 'Rule of Construction' stating this shouldn't change how agencies consider the comments, but in the real world, a single PDF with a number on it looks a lot different than 50,000 individual voices.
The Road to Implementation
This isn't happening overnight. The Office of Management and Budget (OMB) has 240 days to issue the rulebook on how to use software to spot bots and mass campaigns. Following that, the General Services Administration has 18 months to update websites like Regulations.gov. We’ll also see a deep dive from the GAO within two years to see just how much AI is actually influencing our laws. While the goal is to cut through the noise of automated spam, the challenge lies in ensuring that legitimate, organized public participation doesn't get buried under the label of 'mass comments' just because people are using a template to speak up.