Asaf Eckstein (Hebrew U. Jerusalem), Ziv Granov (Hebrew U. Jerusalem) & Ariel Shillo (Hebrew U. Jerusalem), Leave the Door Open? Towards a Context-Based Approach to the Revolving Doors, __ Ari. St. L.J. __ (forthcoming 2026) (with a related post at the CLS Blue Sky Blog):
Policymakers and academics have extensively debated the extent and the nature of the revolving door phenomenon—the interchange of personnel between the government and the private sector. Proponents claim that the transition of former regulators into commercial firms fosters compliance with regulation and encourages aggressive enforcement practices. On the other hand, critics argue that the interchange of personnel exposes public officials to regulatory and cultural capture. The revolving door debate, which has only gone and intensified in recent years, still remains largely binary, treating the revolving door as a single undifferentiated practice.
This Article aims to reconcile these different viewpoints by showing that not all interchange is the same. We argue that the revolving doors are context-dependent—meaning that their extent and nature vary based on the circumstances—and that regulation and discourse surrounding the phenomenon should be adapted accordingly. To do so, we provide a comprehensive, hand-collected analysis of 6,430 directors and executive officers that serve the current S&P 500 companies, using DEF-14A filings published in the fiscal year 2024. Through extensive empirical analysis of the U.S. market’s largest public firms, we show that the revolving doors manifest differently based on the agency or department from which revolvers came, the level of seniority that they held within the agency or department, the sector within which they worked, the positions that they currently hold in the private sector, and the length of time between their exit from the public sector and their entrance into S&P 500 firms. In addition, we show that the phenomenon is prescribed different normative desirability in academic literature based on these same criteria.
To connect our theoretical discussion and empirical findings, we offer a novel framework for contextualizing the regulatory approach to the revolving doors. Regarding the public-sector side of the phenomenon, we argue that federal regulations should differentiate between executive agencies and departments when implementing post-employment restrictions for public officials. With respect to the private-sector side, we offer a unique regulatory approach that focuses on differentiating regulation according to the destinations of the revolvers. Afterwards, we explain that a context-based approach to the revolving doors encourages agencies and departments to collect data regarding former employees who transition into the private sector. Finally, we discuss the underexplored role that public firms should play in self-regulating the revolving doors, in light of their increased commitments to act as good corporate citizens in the modern era of stakeholderism.
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