---
name: regulatory-obligation-delta-analysis
description: "Load when a compliance, legal-ops or risk user pastes two editions of a regulatory instrument (the prior text and the new or amended text) and asks what changed at the obligation level, which changes need action, or whether a change is a new requirement or a clarification. Runs after applicability is settled, before evidence-gap or remediation work. Returns an orientation paragraph, a clause-by-clause delta table labelling each change (net-new, clarification, scope expansion, withdrawn or relaxed, no substantive change, ambiguous) with an action trigger, a count summary and the clauses flagged for human review. Stops if either edition is missing."
---

# Reading an obligation delta

A delta is a reading of two texts, not of a regulator's description of them. Every amendment is built from a few moves (a noun added to a list, a verb or interval that did not exist, a number moved in one direction, a definition that codifies or reaches, an exemption deleted, a clause inserted or removed with those behind it renumbered), and each move has a known effect on a firm already complying with the old wording.

## How the reading is done

**Align by subject before labelling anything.** Clause numbers are addresses, not identities. An inserted clause pushes every later clause up by one; a deleted clause pulls them down. The clause behind an insertion is the same clause under a new number: one row carrying both numbers, labelled as unchanged, never a deletion plus a new clause. A label describes what happened to a clause's own words: identical wording is no substantive change, whatever a summary says about restructuring and however far another clause's change now carries it; wider reach goes in its notes, never in its label.

**The deciding question is prior compliance.** Was a firm that fully met the old wording of this instrument, as the regulator was already applying it, already doing what the new wording demands? If so, the change restates or clarifies. If not, its kind depends on what is new. A verb of action, a review or testing cycle, a deadline, a clearance or a relationship with another party that the prior wording did not contain is a net-new obligation, even when it attaches to a duty that already existed; so is a new item a record, notification or submission must now contain. The same duty now reaching a new class of persons, or a new object or scenario added to its list, is a scope expansion. A figure that already existed and moved is a tightening or a relaxation, never net-new.

**Expansion has three signatures.** A new noun in a scope list or in the object of a duty widens who or what is bound; every clause whose own words now name the new class is an expansion row, a clause whose words are untouched is not. A deleted express exemption brings the exempted class inside the duties it used to escape: that expansion sits on the deleted clause's own row, and the duties themselves stay unchanged with a note on their reach. A tighter number, a shorter period, a lower trigger or a stricter standard binds sooner or harder.

**Direction decides, not the fact of a change.** A longer period before a duty bites, a higher trigger or a removed duty relaxes; a shorter period, a lower trigger or an added duty tightens. Settle the direction before the table is written so label and notes agree: a looser figure is withdrawn / relaxed, never expansion. A relaxation calls for a retention view grounded in the text's own transition language; where the text carries none, say so rather than invent one.

**Yes and Yes-doc are different kinds of work.** When the trigger and the process stay as they were and only the content of a record, notification or submission grows, or an existing practice must now be written down, the firm changes paperwork: Yes-doc. When the firm must start doing something new, an assessment, an audit, a clearance, a gate it did not run before, it changes operations: Yes; a periodic review, test or assessment cycle is an operation whatever its subject. A documentation clause beside an operational expansion elsewhere keeps Yes-doc on its own row. Yes-doc belongs to a firm already bound whose paperwork grows; a class bound for the first time gets Yes on every row that now names it, a record or retention clause included, because it starts from nothing.

**A regulator's summary is evidence, never the verdict.** Its proper work is on a clause whose prior wording already imposed a general duty on the same subject ("appropriate measures", a periodic assessment) and whose new wording spells that duty out. When the summary names a letter, guidance or circular of the same regulator that already required the listed items, that instrument is part of how the prior clause was applied, not something external: a firm meeting the prior clause under it was already doing the listed things, so the row is a clarification / restatement with Yes-doc and the notes cite the instrument by its reference. The summary cannot turn a new entity class, a deleted exemption or a moved figure into a clarification, because there the prior wording imposed nothing on the subject. Clauses the summary does not mention are read on their own, and the notes say the summary is silent on them.

**Definitions work in two ways.** A definition that only fixes the meaning of a term the operative clauses already used clarifies. A definition introducing a new term that an operative clause now uses to bind a new class expands scope twice: on the definition row and on the operative row that uses it. A clause that merely permits ("may") binds no one, so leaving it as it was is no change even when the class bound elsewhere has grown.

**Review is for a link the texts leave open.** When a new sub-item fixes a specific standard (a size, a language, a format) for a subject that a general word in another prior clause may or may not have governed, the two texts do not settle whether the old general word already reached that subject. A summary that calls such a new sub-item a clarification of the existing standard shows the link is contested, not that it is settled, because the prior text carries the standard's word only elsewhere. The analyst neither resolves it into net-new nor into clarification: the row is ambiguous — human review, with a specific question naming both clauses and both outcomes. Peripheral uncertainty is decided, not flagged.

**Two texts or no table.** A prior text reconstructed from memory or a sister regime is unreliable because near-identical wordings hide obligation shifts, so with an edition missing the reply stops and asks for it.

## Writing it down

**Missing edition first.** If either text is absent: no table, no provisional reading; a bold stop line, one or two sentences on why reconstruction is unsafe, and a request naming the missing edition.

**Orientation.** Two or three sentences, the last of which lists every changed, inserted or deleted clause with its move and, for a figure, its direction, marking a new sub-item whose link to an older general standard is open as open for review, then the clauses whose wording is identical, before any label is written.

**Rows and labels.** One row per clause of the new text in its order, unchanged clauses and separately printed sub-items included, then one per deleted prior clause; refs as the new text prints them, `Art. 7 (new)`, `Art. 8 (was: Art. 7)` only where the number changed, `Prior Rule 5 (deleted)`. change-type is exactly one of `net-new obligation`, `scope expansion`, `clarification / restatement`, `obligation withdrawn / relaxed`, `no substantive change`, `ambiguous — human review`; action-trigger exactly one of `Yes`, `Yes-doc`, `No`, `Review`. One row carries one label, the label its notes argue for.

**Notes.** Every changed row names the exact element from this input (the new noun or class, the old and new figures with their direction, the deleted exemption and its condition, the inserted verb, cycle or record item, the instrument the summary cites), answers the prior-compliance question in a few words and, on a relaxed row, states the retention position the text supports. Unchanged rows say `Wording unchanged.` plus how they are reached or renumbered where it matters. Nothing is cited that the input does not contain.

**Summary.** All six change-types in the order above, zeros included. For each, walk the table top to bottom, list every row carrying that label (a renumbered unchanged clause among the unchanged ones), then write `= ` and the number of refs listed; a type with no rows reads `0`.

Call read_reference for `references/reply-shape.md` and write the reply in that shape.