Large Language Models (LLMs) are increasingly integrated into real-world decision-making, including in the domain of public policy. Yet, their ability to comprehend and reason about policy-related content remains underexplored. To fill this gap, we present PolicyBench, the first large-scale cross-system benchmark (US-China) evaluating policy comprehension, comprising 21K cases across a broad spectrum of policy areas, capturing the diversity and complexity of real-world governance. Following Bloom's taxonomy, the benchmark assesses three core capabilities: (1) Memorization: factual recall of policy knowledge, (2) Understanding: conceptual and contextual reasoning, and (3) Application: problem-solving in real-life policy scenarios. Building on this benchmark, we further propose PolicyMoE, a domain-specialized Mixture-of-Experts (MoE) model with expert modules aligned to each cognitive level. The proposed models demonstrate stronger performance on application-oriented policy tasks than on memorization or conceptual understanding, and yields the highest accuracy on structured reasoning tasks. Our results reveal key limitations of current LLMs in policy understanding and suggest paths toward more reliable, policy-focused models.
Figures & tables
Figure 1: Three levels of evaluating LLM in PolicyBench .
Figure 2: Selected examples from PolicyBench spanning three levels and two languages.
Level
ID
Task
Number
CN
US
Mem.
1-1
Article/Date Memorization
4,498
3,351
1-2
Terminology Recognition
237
126
1-3
Organization Identification
268
228
Und.
2-1
Idea Understanding
1,219
1,013
2-2
Interest Understanding
1,145
996
Table 1: Task list of PolicyBench and respective numbers (“Mem” = Memorization, “Und” = Understanding, “App” = Application).
Level
Region
GPT-4o
o4-mini
Gemini-2.5
Gemini-2.0
Claude-3.7
Claude-3.5
LLaMA-4
Gemma-3-27B
QwQ-32B
Deepseek-V3
Deepseek-R1
Level 1
CN
46.01%
45.93%
54.06%
47.87%
55.29%
53.77%
49.81%
41.75%
55.87%
48.61%
62.02%
US
52.69%
54.90%
57.73%
53.71%
58.68%
58.76%
52.55%
49.91%
46.40%
50.12%
59.33%
Level 2
CN
56.34%
55.81%
60.57%
56.39%
60.47%
59.74%
56.56%
55.56%
59.79%
55.51%
62.92%
US
63.40%
64.71%
64.91%
62.25%
68.23%
68.95%
61.17%
62.17%
57.71%
58.62%
65.37%
Level 3
CN
70.24%
79.49%
76.18%
73.80%
73.82%
72.83%
68.54%
71.51%
80.34%
72.33%
73.78%
US
68.13%
77.00%
69.44%
66.55%
68.28%
68.47%
66.41%
68.37%
69.90%
69.39%
74.60%
Table 2: Performance (accuracy) of all models on different levels and regions. Gemini-2.5, Gemini-2.0, Claude-3.5 and Claude-3.7 denote Gemini-2.5-Flash, Gemini-2.0-Flash, Claude-3.5-Sonnet and Claude-3.7-sonnet respectively. Red and blue represent the highest and lowest scores in each row respectively.
Region
GPT-4o
o4-mini
Gemini-2.5
Gemini-2.0
Claude-3.7
Claude-3.5
LLaMA-4
Gemma-3-27B
QwQ-32B
Deepseek-V3
Deepseek-R1
Chinese
57.53%
60.41%
63.60%
59.35%
63.19%
62.11%
58.30%
56.27%
65.33%
58.82%
62.24%
US
61.41%
65.54%
64.03%
60.84%
65.06%
65.39%
60.04%
60.15%
58.00%
59.38%
66.43%
Average
59.47%
62.98%
63.82%
60.10%
64.13%
63.75%
59.17%
58.21%
61.67%
59.10%
64.34%
Table 3: Average accuracy (%) of all models across Chinese and US (red and blue represent the highest and lowest in each row).
Figure 3: Model performance in 10 subtasks (ID and the specific task are shown in Table 1 ).
Level
Region
Original
Training
Δ
Level 1
CN
36.85%
41.83%
↑ 13.51%
US
23.35%
35.43%
↑ 51.73%
Level 2
CN
45.68%
47.02%
↑ 2.93%
US
42.31%
42.78%
↑ 1.11%
Level 3
CN
64.73%
69.12%
↑ 6.78%
US
46.65%
57.48%
↑ 23.22%
Table 4: Qwen2.5-7B-Instruct performance across levels and regions before and after training (%)
Figure 4: Routing distributions over three experts for each level.
Figure 5: Human accuracy on three levels (%).
Appendix figures & tables21 assets
Supplementary material from the paper’s appendix.
Appendix
Figure 6: Categories of Chinese Policy Documents and Representative Keywords (Partial List).
Figure 7: Screenshot of human evaluation interface.
Language & Content Type
Primary Collection Websites / Platforms
US Sources
Official Policies
https://www.transportation.gov
https://www.hhs.gov
https://www.va.gov
https://www.commerce.gov
https://www.usda.gov
Appendix
Table 5: Sources for Policies and Supplementary Materials (By Language)
Model
Developer
Open-source
Version
Role
GPT-4o
OpenAI
/
Evaluated model
o4-mini
2025-04-16
Evaluated model; Judge (Level 3)
Gemini-2.5-Flash
Google DeepMind
preview-04-17
Evaluated model; Judge (Level 3)
Gemini-2.0-Flash
/
Evaluated model
Gemma-3-27B
27B Instruct
Evaluated model
Claude-3.7-Sonnet
Anthropic
20250219
Evaluated model; Judge (Level 3)
Appendix
Table 6: Overview of models evaluated or used as judges in this study.
Dimension
ID
Definition
Article/Date Memorization
1-1
Tests memory of specific articles, dates, numbers, etc. in the policy.
Terminology Recognition
1-2
Tests ability to recognize and understand policy terminology.
Organization Identification
1-3
Tests ability to identify organizations mentioned in the policy.
Idea Understanding
2-1
Examines the ideological foundation and value orientation behind the policy.
Interest Understanding
2-2
Assesses the identification and analysis of key stakeholders affected by or involved in the policy.
Institution Understanding
2-3
Evaluates understanding of the formal and informal rules, organizations, and mechanisms shaping policy implementation.
Appendix
Table 7: The detailed introduction of 10 dimensions.
Figure 8: Representative error cases across three cognitive levels in PolicyBench .
Level
Region
Clarity
Relevance
Faithfulness
Avg.
Level 1
CN
99.20%
98.01%
98.78%
98.66%
US
99.15%
98.25%
97.94%
98.45%
Level 2
CN
98.86%
98.00%
98.12%
98.32%
US
98.76%
97.60%
97.22%
97.86%
Level 3
CN
99.16%
96.02%
96.14%
97.11%
US
97.66%
95.64%
96.32%
96.54%
Appendix
Table 8: Human evaluation results across levels and regions.
Annotation Dimension
Kappa ( κ )
Agreement Level
Bloom Classification (L1/L2/L3)
0.856
Strong
Clarity (Pass/Fail)
0.841
Strong
Relevance (Pass/Fail)
0.877
Strong
Faithfulness (Pass/Fail)
0.827
Strong
Appendix
Table 9: Inter-Annotator Agreement statistics. Quality scores were binarized for κ calculation.
Metric
Score
Correctness Verification
96.1%
Content Validity (Rated “Appropriate”)
94.5%
Bloom-Label Agreement (Krippendorff’s α )
0.86
Appendix
Table 10: Expert Validation Results ( N=120 ).
Level
Expert Accuracy
Comparison vs. SOTA LLM
Level 1 (Memorization)
82.3%
Comparable
Level 2 (Understanding)
88.4%
Significant Gap
Level 3 (Application)
90.1%
Significant Gap
Appendix
Table 11: Human Expert Performance (Open-Book) vs. Models.
Model
Baseline
Single-Examiner Setting
LOEO Setting
Avg.
(Consensus)
Claude-Only
GPT-Only
Qwen-Only
Wo-Claude
Wo-GPT
Wo-Qwen
Qwen-3
89.0
86.0
88.0
92.0
92.0
90.0
88.0
89.29
Llama-4
82.0
84.0
88.0
89.0
88.0
87.0
85.0
86.14
Qwen-2.5
83.0
81.0
85.0
90.0
83.0
86.0
87.0
85.00
GPT-4o-mini
66.0
59.0
74.0
85.0
74.0
71.0
67.0
82.67
GPT-4o
75.0
71.0
82.0
85.0
85.0
83.0
78.0
79.86
Appendix
Table 12: Complete Multi-Examiner Sensitivity Analysis. Scores represent accuracy (%). "Baseline" denotes the standard PolicyBench setting (3-Examiner Consensus). "Wo-X" denotes the Leave-One-Examiner-Out setting. The data reveals that relying on a single examiner (e.g., GPT-Only or Claude-Only) leads to drastic score fluctuations compared to the stable Baseline.
Model
Baseline Score
Own-Gen Score
Δ
Bias Type
GPT-4o
75.0%
82.0%
+7.0%
Self-Leniency / Pattern Matching
Qwen-3
89.0%
92.0%
+3.0%
Moderate Inflation
Claude-4-Sonnet
84.0%
69.0%
-15.0%
Self-Strictness / Hyper-Critical
Appendix
Table 13: Analysis of Self-Scoring Bias. The results show that single-examiner benchmarks suffer from extreme variance (from +7 inflation to -15 deflation).
Comparison Pair
Spearman ρ
Kendall τ
Interpretation
Baseline vs. Wo-Qwen
0.901
0.781
Highly Stable
Baseline vs. Wo-GPT
0.607
0.524
Moderately Stable
Baseline vs. GPT-Only
0.342
0.293
Unstable / Biased
Appendix
Table 14: Leaderboard Stability Analysis. High correlation in LOEO conditions confirms the robustness of the ranking system, while single-examiner rankings (especially GPT-Only) are highly unstable.
Case ID
Final Score (Run 1)
Final Score (Run 2)
Final Score (Run 3)
Mean
Std. Dev.
Case 1
4.00
4.50
4.00
4.17
0.29
Case 2
4.00
4.00
4.25
4.08
0.12
Case 3
3.00
3.25
3.00
3.08
0.12
Case 4
4.33
4.50
4.25
4.36
0.10
Case 5
2.25
2.25
2.50
2.33
0.12
Case 6
5.00
5.00
5.00
5.00
0.00
Appendix
Table 15: Stability analysis of the final LLM-as-a-Judge scores. The low standard deviation across three independent runs for each case demonstrates the reliability of our multi-judge evaluation protocol.
Metric
Value
Pearson Correlation ( r )
0.87
Mean Absolute Error (MAE)
0.42
Agreement Rate
94%
Appendix
Table 16: Human–Model alignment statistics. High correlation, low error, and strong agreement indicate that the LLM judge closely matches expert evaluation.
Model
MMLU-Pro
LegalBench
PolicyBench (Avg)
PolicyBench (L2)
DeepSeek-V3
81.9%
80.1%
59.10%
57.68%
GPT-4o
80.3%
79.8%
59.47%
56.08%
Claude-3.7-Sonnet
80.3%
78.1%
64.13%
58.48%
Gemini-2.5-Flash
77.9%
81.7%
63.82%
64.06%
Pearson Correlation ( r )
-0.69
-0.07
1.00
–
Appendix
Table 17: Performance comparison and correlation analysis across benchmarks.
Model
Level 1
Level 2
Level 3
Average
(Memorization)
(Understanding)
(Application)
Base (Qwen2.5-7B)
30.10%
44.00%
55.69%
43.26%
Standard LoRA
34.82%
44.51%
59.45%
46.26%
PolicyMoE (Ours)
38.63%
44.90%
63.30%
48.94%
Δ (MoE vs. LoRA)
+3.81%
+0.39%
+3.85%
+2.68%
Appendix
Table 18: Performance comparison between the base model, Standard LoRA, and PolicyMoE on a controlled training subset. PolicyMoE achieves larger gains on Memorization (L1) and Application (L3) tasks.
Institute for Smart Systems Technologies University of Klagenfurt Klagenfurt, Austria · University of Klagenfurt / Inst. f. Smart Systems Technologies, Austria & Facult´e Polytechnique Universit´e de Kinshasa, DR-Congo