Digital Twins of Legislation for Explainable Automated Decision-Making in Administrative Law

Florian Schnitzhofer, Anastasija Nikiforova, Christoph G. Schuetz

Keywords: Digital Twins of Legislation, Automated Decision-Making, Administrative Law, Law as Code

TL;DR: Based on expert interviews, we derive design principles and a four-layer architecture for a Digital Twin of Administrative Law (DTAL), comprising statutory text, ontology, configuration, and executable logic.

Abstract: Automated decision-making (ADM) in public administration must meet strict requirements of legality, transparency, and explainability. One potentially relevant but still underexplored route to achieve this is the Digital Twins of legislation, which can help synchronize legal texts, semantics, and executable decision logic. This paper investigates how such legislative digital twins can support explainable, rule-of-law–compliant ADM in administrative law. Based on grounded, inductive analysis of senior expert interviews, we identify four feasibility conditions for trustworthy ADM: (1) selective automation of deterministic sub-decisions, (2) semantic standardization and ontological alignment, (3) computable legal structures that link natural-language norms to machine-interpretable logic, and (4) drafting and governance adaptations enabling synchronized updates. Building on this, we derive design principles and a four-layer Digital Twin of Administrative Law (DTAL) architecture comprising statutory text, ontology, configuration, and executable logic. We illustrate the operation of the DTAL through a tourism contribution levy use case. This study contributes empirically grounded design principles, and a mid-range process theory explaining when and how administrative norms can be operationalized through digital twins. We propose an architectural approach that enables deterministic sub-decisions to be automated while preserving human oversight, legal traceability, and institutional legitimacy.

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Submission Number: 6