At the end of November 28, the federal government published Decree number 10.139/2019, requiring a review of all regulatory acts in the country within a period of 18 months. What at first appears to be merely another administrative act without any great importance, could, in fact, have serious effects on the entire federal apparatus.
The decree forces federal government agencies to revise and consolidate all normative acts currently in force which are inferior to decrees. In other words, all ordinances, resolutions, notices, normative instructions, letters, guidelines, directives—among others—will be reviewed and may have their wording modified, be merged with other administrative acts, or simply be revoked entirely.
Simplification is a good thing, and there is no doubt that there are a number of very old rules in place that have the potential to create problems and need to be revised. However, the risk of being forced to revise absolutely everything, without any transparent planning or strategy, is to make any hope of adequate and qualified analysis of what is being revoked or changed impossible. As they say in programming, for the government, this is a feature, not a bug.
The size of the job at hand
The first problem is the volume of administrative acts that exist: there is not even an accurate estimate of how many there are in total. In a preliminary survey of some agencies that actively make data available, we found that the Department for the Improvement of Higher...
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