Policy output and outcome shortfalls are often attributable to deficits in implementation. Drawing on data collected from multi‐level governmental documents and in‐depth interviews regarding the ongoing reforms of the use of 'administrative approval intermediaries' in China, we identified a genre of policy implementation in which the policy implementers themselves are targets of reform. These implementers swing between fulfilling tasks and deviation from formal requirements. By illustrating how the implementation gap in the reform widened as the implementation moved downstream and the exercise of centralized authority deteriorated, we found that the implementation deficits worsen as the targets' interests were increasingly undermined by the policy. This was largely due to an administrative design in which the objective was established at the top, implementation depended on change by the bottom and coordination was horizontal across the middle.

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