NLRB Memoranda API: General Counsel and Division of Advice Memos, Queryable

Short answer: the NLRB publishes two document sets that tell you what labor-law theories the agency is about to press, and Vaquill AI's US primary law API serves both as structured JSON. 301 General Counsel memoranda (1973 to present, source=nlrb_gc_memo) and 340 Division of Advice memoranda (source=nlrb_advice_memo) sit under corpusType=AGENCY_GUIDANCE, which GET /boards lists on a monthly cadence. GC memoranda are the prosecutor's public statement of what he intends to charge. Advice memoranda are that theory applied to one employer's real facts. The catch is the Advice set: it is a rolling 10-year window, not the full archive, so pre-window historical research won't be complete here.

Reviewed and corrected on 12 October 2026. Counts are from the published coverage documentation. This is general information, not legal advice.

TL;DR

• The NLRB General Counsel is the agency's prosecutor. Under 29 U.S.C. 153(d) the GC has final authority over whether an unfair labor practice complaint issues. A GC memorandum announcing a theory is therefore a forecast of charges, not commentary.
• nlrb_gc_memo holds 301 documents, 1973 to present. Cited as "NLRB General Counsel Memorandum GC 22-04".
• nlrb_advice_memo holds 340 documents and shows the theory applied to concrete facts. Cited as "NLRB Division of Advice Memorandum, Case No. 13-CA-182757 (Savage Fueling)".
• The Advice set is a rolling 10-year window, not the full archive. If your question is about a 1998 Advice memo, this corpus is the wrong tool and we won't pretend otherwise.
• GC memoranda get rescinded in bulk when the General Counsel changes with an administration. A memo's current status is a live question, so each memo carries actStatus, rescindedOn and supersededBy, and change monitoring matters here.
• Both sets come from the NLRB's own publication pages, and every result carries the publisher's own URL so a reviewer can check the original.

The labor entry in our federal agency guidance series.

For related coverage, see Federal Agency Guidance API: 53 Sub-Regulatory Sources in One Endpoint for the corpus these memos sit in, DOJ Justice Manual API: Over 1,500 Sections of Federal Prosecution Policy for the other place a federal prosecutor writes down what he will charge, and HIPAA Guidance API: HHS OCR FAQs, Guidance, and Enforcement Actions.

What these two document sets actually are

Most labor-law tooling starts and stops at Board decisions. That is the record of what already happened, sometimes years after the conduct.

The memoranda are earlier in the pipeline. They are where the agency says out loud what it plans to do before any decision exists.

Both live inside the same federal agency guidance corpus of 96,966 sections, which spans 53 named sources. The source filter is what keeps an NLRB query out of IRS revenue rulings and USCIS policy chapters. The corpus types reference lists every token.

Why a GC memorandum predicts your exposure

29 U.S.C. 153(d) gives the General Counsel final authority "in respect of the investigation of charges and issuance of complaints". The statute leaves that call to the General Counsel, not the Board.

So when the GC publishes a memorandum saying a category of conduct violates Section 7 or Section 8(a)(1) of the NLRA, that is the office describing what it will charge. A Board decision arrives after somebody has already been the test case. A GC memorandum can arrive before it. That is a different kind of document, and it is worth treating differently in your product.

A short history: a prosecutor with the last word

The General Counsel's office is younger than the Board. The NLRB's own Acting General Counsel told a House committee in 2011 that the office "was created by the Taft-Hartley Amendments of 1947," and that the statute gave it the independence and resources to make final decisions in heated labor and management disputes (Lafe Solomon testimony, June 17, 2011). The statute behind that, the Labor Management Relations Act, was approved June 23, 1947 (61 Stat. 136).

Section 3(d), as codified in 29 U.S.C. 153(d), makes the General Counsel a presidential appointee confirmed by the Senate for a four-year term, with final authority on behalf of the Board over investigating charges and issuing complaints. Four-year terms matter for this post. A new President can mean a new General Counsel, and a new General Counsel can mean a new set of priorities.

You can see how final that authority is in how people describe it. In a February 2018 discussion of a Division of Advice memo on a high-profile charge, one Hacker News commenter explained the process and ended with: "If the General Counsel upheld the decision to dismiss the charge, that decision would not be appealable to any court" (bradleyjg, Hacker News, February 2018). That's the commenter's account of how it works, so check the statute and recent case law before you build advice on it. It does explain why lawyers watch the General Counsel's memos so closely.

The dotted lines are the honest part of that diagram. The corpus covers the guidance layer, plus the statute and the CFR beneath it. Board and ALJ decisions are a separate universe and aren't what these two sources contain.

Advice memoranda: the theory meeting facts

A Regional Office that gets a novel or contested charge can send it to the Division of Advice. The Division writes back on whether a complaint should issue.

That memo is unusually useful because it does the thing policy documents never do: it applies the rule to a specific employer's handbook, discipline, or social media policy. You get the theory and the fact pattern in the same document.

For an HR compliance platform this is the closest public analog to "here is a company that looked like ours, and here is what the agency concluded."

Rescission: why status is a live question here

GC memoranda have a property that most primary law doesn't. When the General Counsel changes with an administration, the incoming office can rescind a batch of its predecessor's memoranda, as GC 25-05 did in February 2025.

The text of a rescinded memo doesn't change. Its operative status does, and the status and currency reference describes the fields that carry it. A tool that only checks whether a document's text is current will report that everything is fine while serving a memo that the office has disavowed. The memoranda here carry that status as data (see below), but a cached copy goes stale when the status changes.

This is the single strongest argument for wiring change detection into an NLRB feature rather than caching the set once and moving on.

A quick story: what February 14, 2025 looked like

Here is how fast status can move. On February 14, 2025, Acting General Counsel William B. Cowen issued Memorandum GC 25-05, "Rescission of Certain General Counsel Memoranda." His reason, in his words: "if we attempt to accomplish everything, we risk accomplishing nothing." He pointed to a backlog of cases that had grown "to the point where it is no longer sustainable" (GC 25-05 on the NLRB site).

The memo is a lesson in how many kinds of "rescinded" exist, because it sorts about thirty memos into five groups:

• Rescinded. These include memos on non-compete agreements (GC 23-08), student-athletes (GC 21-08) and electronic monitoring and algorithmic management (GC 23-02).
• Rescinded pending further guidance. These include the memo responding to inquiries about the Board's Cemex decision (GC 24-01) and a memo on new casehandling processes (GC 25-03).
• Rescinded as no longer relevant after a Board decision, here Amazon.com Services LLC, 373 NLRB No. 136 (2024). That group holds GC 22-04, the captive audience memo.
• Rescinded, with an older memo restored (GC 23-03, with GC 18-01 coming back).
• Rescinded because the facts behind it ended, as with the COVID-era mail ballot memo (GC 21-01).

Six months earlier a Hacker News commenter had summed up the non-compete memo's status carefully: "That article says that is the opinion of the NLRB General council but not yet a rule or precedent." (advisedwang, Hacker News, August 2024). The commenter was right then, and the memo was rescinded about six months later. Notice also that the citation example in this post, GC 22-04, is on the list. A memo can be a perfectly good example of a citation format and a poor guide to current enforcement at the same time.

What the data says about GC 25-05

Checked against the API on 12 October 2026:

• GC 23-08 (non-compete agreements) returned actStatus: "rescinded", goodLawStatus: "not_good_law", rescindedOn: "2025-02-14" and supersededBy: "GC 25-05".
• GC 24-01 (the Cemex guidance) and GC 22-04 (captive audience meetings) returned the same status fields. GC 25-05 files GC 24-01 under "rescinded pending further guidance" and GC 22-04 under "no longer relevant"; the API reports one status, rescinded, so read GC 25-05 for the reason.
• GC 18-01, which GC 25-05 restores, returned actStatus: "in_force", and so did GC 25-05 itself.

These are the API's reading of the NLRB's own documents. Not verified in our October 2026 review: every one of the other memoranda in GC 25-05's list.

That mechanism starts at GET /boards, which is free and returns each watchable source with a cadence and a lastRetrievedAt. Check there first to see whether the source you care about is watchable, then create a watch and poll its changes rather than re-crawling the corpus yourself, a flow set out in the alerts documentation. More on that at the law change alerts page and in the law change webhooks guide.

Querying it

Base URL is https://api.vaquill.ai/api/v1. Auth is a bearer key with a vq_key_ prefix. Statutes routes are mounted under /us/statutes/*.

A search costs 4 credits. GET /us/statutes/coverage and GET /boards are free. Failed calls aren't charged.

One GC memo query

curl -s https://api.vaquill.ai/api/v1/us/statutes/search \
  -H "Authorization: Bearer vq_key_..." \
  -H "Content-Type: application/json" \
  -d '{
    "query": "employer work rules that chill protected concerted activity",
    "corpusType": "AGENCY_GUIDANCE",
    "source": "nlrb_gc_memo",
    "limit": 10
  }'

Both sets at once, then split by source

curl -s https://api.vaquill.ai/api/v1/us/statutes/search \
  -H "Authorization: Bearer vq_key_..." \
  -H "Content-Type: application/json" \
  -d '{
    "query": "confidentiality and non-disparagement terms in a severance agreement",
    "corpusType": "AGENCY_GUIDANCE",
    "source": ["nlrb_gc_memo", "nlrb_advice_memo"],
    "matchType": "any",
    "limit": 20,
    "excerptChars": 600
  }'

Each hit carries a stable actId and the official NLRB URL for the publisher's own copy. Take the actId from the response and fetch the full document with GET /us/statutes/section/{actId} or /section/{actId}/body.

Filters that matter for this corpus

Two behaviors worth knowing. Unknown filter values return 422 instead of silently matching nothing, which turns a typo into a loud failure instead of a quiet wrong answer. And the source filter's error message lists every valid code, so a single bad request tells you the whole vocabulary.

Citation formats to render

Get these right or your output won't survive a partner's review.

• GC memorandum: NLRB General Counsel Memorandum GC 22-04
• Advice memorandum: NLRB Division of Advice Memorandum, Case No. 13-CA-182757 (Savage Fueling)

Advice memos are identified by their case number, not a sequential publication number, and the case caption is what a human recognizes. Carry both. Dropping the case number makes the citation unresolvable by anyone who wants to verify it.

How this corpus is built

Worth stating, because it is the part buyers actually diligence.

• Official source. Both sets come from the NLRB's own publication pages, and each result links to the NLRB's copy.
• One document, one citable item. A "document" is one item with a stable actId. Long memoranda split into several retrieval passages, which is why the passage count across the wider corpus runs about four times the section count.
• Monthly cadence for the AGENCY_GUIDANCE board that NLRB sits on, with lastRetrievedAt on GET /boards showing the last check.
• The ingestion pipelines are open source (Apache-2.0) at github.com/Vaquill-AI/open-us-law, alongside the published dataset and its schema. See open-us-law.

What is not in these two sources

Say this to your users before they discover it themselves.

• Board decisions. Not in these two sources, which are the guidance layer. NLRB Board decisions are a separate source, nlrb_board_decision under AGENCY_ADJUDICATION: 66,597 decisions from 1935 per the coverage documentation. ALJ decisions are not among the sources the coverage documentation names.
• Pre-window Advice memoranda. The 10-year roll is real.
• A final word on status. actStatus and rescindedOn are the API's reading of the NLRB's documents. The NLRB is the authority on what is in force, so confirm there.
• State labor law. Public-sector and state-level labor rules live in the state statutes and state regulations corpora, which is a different query with corpusType=STATE or REGULATION.

Who should build on this, and who should not

Good fit: an HR compliance platform that flags handbook and severance language against current enforcement posture. An employment-law research tool that wants a layer earlier than Board decisions. An in-house team that needs a regular signal on what the GC's office is pursuing.

Bad fit: anyone whose core need is the historical Advice archive before the rolling window. Anyone who needs Board decisions as the primary object. Anyone who needs a legally authoritative "is this memo still in effect" answer without checking the NLRB, because actStatus reports the API's reading of the publisher's documents.

FAQ

What is an NLRB General Counsel memorandum?

It is a public memorandum from the NLRB General Counsel's office, usually addressed to Regional Directors, stating the office's position on a legal theory or setting a prosecution priority. Because 29 U.S.C. 153(d) gives the GC final authority over whether a complaint issues, the memo tells you what the agency intends to charge. It isn't binding law and doesn't decide any case.

What is a Division of Advice memorandum?

When a Regional Office receives a charge that is novel or contested, it can submit the case to the NLRB's Division of Advice. The Division writes back on whether a complaint should issue on those facts. The published memo shows the agency's theory applied to one employer's actual conduct, which is why it reads more concretely than a policy memo.

How many NLRB memoranda are in the API?

301 General Counsel memoranda covering 1973 to the present, and 340 Division of Advice memoranda. Both are served under corpusType=AGENCY_GUIDANCE and separated with source=nlrb_gc_memo or source=nlrb_advice_memo. Both sit on a monthly cadence.

Does the corpus include the full Division of Advice archive?

No. The Advice set is a rolling 10-year window of 340 documents. Research questions reaching further back won't be complete here, and an empty result should not be read as proof that no memo exists. Use the NLRB's own reading room for older material.

Are rescinded GC memoranda removed from the corpus?

No. Rescinded memos stay in the corpus, flagged: GC 23-08 returned actStatus: "rescinded", goodLawStatus: "not_good_law", rescindedOn: "2025-02-14" and supersededBy: "GC 25-05" on 12 October 2026. Every result also carries the NLRB's own URL, so confirm status there. Because incoming General Counsels can rescind predecessor memoranda in bulk, this is the corpus where you should wire change monitoring rather than caching once.

Can I get NLRB Board decisions from the same API?

Not from these two sources. nlrb_gc_memo and nlrb_advice_memo are the guidance layer, which sits earlier in the pipeline than an ALJ or Board decision. If Board decisions are your primary object, query the separate AGENCY_ADJUDICATION source nlrb_board_decision, which the coverage documentation lists at 66,597 decisions from 1935.

How do I cite a Division of Advice memo?

By case number and caption, in the form "NLRB Division of Advice Memorandum, Case No. 13-CA-182757 (Savage Fueling)". Advice memos don't carry a sequential publication number the way GC memoranda do, so the case number is the identifier that makes the cite checkable.

What does an NLRB search cost?

POST /us/statutes/search is 4 credits per call, whatever the corpus. GET /us/statutes/coverage and GET /boards are free. Failed calls aren't charged, and paging is cut from a single ranking, so a later page costs no more than the first and never repeats or drops a result.

Can I query these memos from an AI agent?

Yes. The same surface is published as an MCP server at mcp.vaquill.ai using the same vq_key_ credential, so an agent can run the search and section fetch as tools. See adding legal research to an AI agent over MCP and the Vaquill AI MCP server.

Is there a point-in-time query for how a memo read on a past date?

Yes, as a reconstruction. Send asOf=YYYY-MM-DD to the section body endpoint and the earlier text is rebuilt from the first change observed after your date. The asOf block names the engine that answered, and isBounded warns when the result rests on when capture began, so a date before that can come back unavailable. No published edition is held for these memos. Around it you have a yearFrom / yearTo currency filter, per-section amendment history, change events from each refresh, and per-section diffs on watched boards.

Priyansh Khodiyar

Co-Founder & CTO

Priyansh leads engineering and AI at Vaquill AI: the pipelines that pull statutes, regulations and court rules from every US jurisdiction's official publisher, and the REST API, MCP server and open dataset that serve them.