The first sentence of your abstract starts by defining a label, so it seems fair game to comment on it! Sometimes definitions do matter - definitions in the law certainly matter a lot when writing Rules as Code models for them.
I think there’s so much potential for Rules as Code beyond the narrow exclusionary view that it’s only to be done by governments and only while co-drafting new law. This narrow view is not-infrequently promoted in the RaC movement. My guess is it’s pushed for rhetorical purposes, to argue for the special importance of RaC that narrow context, and to emphasise that it’s not just a technical/computational issue but also needs other methodological foundations (and perhaps policy foundations). You can agree with both of those points (I do!) without excluding other useful applications of Rules as Code. I agree computational law is traditionally very focussed on technical issues, tools, logic, … and the RaC movement usefully emphasises the broader issues related to using those technological elements in practice.
I agree a narrow focus helps, but new legislation won’t narrow your focus in the right way in my view. One reason for that is that new legislation frequently amends or references old legislation to build on it. Another reason is that the expected interpretation of new legislation is normally impacted by the same “maze” you mention, even if there’s no case law established on it specifically. I think a better approach is to narrow focus by targeting a specific purpose for each RaC model - focus on narrow slices of law (new law, old law, case law, consensus expert views, …) that collectively bear on specific business/personal problems or policy questions.
Finally, while it would be great for government to create and publish RaC models (and we have argued for that in submissions to goverment), there is sometimes naive thinking in the RaC movement about the kind of authority that those models would have. I think it is unlikely that RaC models will in our lifetimes be published by governments as law or with the force of law. In general, it’s best to think of RaC models as tentative descriptive models of the law. Even governments don’t always get the interpretation of their own laws right! This is demonstrated when governments lose court cases for this reason. Businesses/citizens often have an interpretation of the law that is different to governments’. The RaC approach may help to reduce ambiguity, but it won’t eliminate fundamental interpretative differences. If a court later tells you that the interpretation you have modelled is wrong, or if your model has conclusions that are legally invalid, then you try to correct your model. Rinse, repeat.
This is one major reason why RaC is not just for governments. It’s also for businesses/citizens, so that they can express their legal viewpoint, and perhaps more clearly compare it to that of government.