By Angus Harley

There are some texts that are really difficult to understand. Add to this that the apostle Peter said that Paul writes some things that are hard to comprehend (2 Pet.3:16), and you begin to appreciate how awkward and problematic Romans 2 is as a text. For decades I held to the traditional reading of Romans 2:14, that it referred to pagan Gentiles, and that they ‘performed’ their form of the Law of Moses, given to them at creation, to the great shame of the Jews who did not keep Moses’ Law. This current article completes a series that puts forward a new view of Romans 2, and which argues that the Gentiles of Romans 2:14-15, 25-29 are not pagans but Christians.[1] Even though my position is similar to Simon J. Gathercole’s, it is distinct, in that mine is a NCT interpretation of Romans 2, and Gathercole’s is not. He says the Christian Gentiles keep an internal form of the Law of Moses; I argue that it is the New Covenant law, not the Law of Moses, that the Christian Gentiles fulfill.


Starting from the perspective that the Gentiles of Romans 2 are Christians, Gathercole maintains that these Gentiles keep the Torah, so that nomos “here refers to Torah, not generic ‘law’ ”.[2] Plainly, Gathercole is giving to “Torah” a specific meaning. What is it? It is the Mosaic Law:

νόμος here refers to Torah, not generic ‘law’. Considerable burden of proof rests with the commentator who argues against νόμος meaning Torah. The argument originating with Origen (ad Rom. 3.21, cited in Sanday & Headlam, Romans, p. 59) that, if Paul had meant Law of Moses, he would have added the article cannot be sustained. ‘The lack of the article is without significance’ (E. Käsemann, Commentary on Romans [Grand Rapids: Eerdmans, 1980], p. 62).

Consequently, “[c]onsiderable burden of proof” lies on those who do argue that nomos does not refer to Torah.[3] He then adds to this, in interpreting 2:13, that these Gentiles are justified by the works of the Torah on Judgment Day, “the Gentiles who carry out the Torah as Christian believers, and thus to be justified on the final day.”[4] It is this Torah that is written on their hearts, with the result that “these Gentiles incarnate the Torah in their persons”.[5] This is offset against the Torah disobedience of the Israelites, “This time, however, the cardiac inscription is a work of God rather than the activity of active memorization of and obedience to Torah by Israel.”[6]

Golden rule #1

Gathercole’s reading is, in my opinion, automatically crippled by its main assumption that the Gentiles possess the internal form of Torah. There are six main arguments in this criticism.

First, or ‘Golden rule #1’- if I may be allowed a smidgeon of embellishment here- Paul’s immediate argument is that the Gentiles do not have the Torah. He is so adamant on this that he writes it four times in the immediate context:

12All who sin apart from the law will also perish apart from the law, and all who sin under the law will be judged by the law. 13For it is not those who hear the law who are righteous in God’s sight, but it is those who obey the law who will be declared righteous. 14(Indeed, when Gentiles, who do not have the law, do by nature things required by the law, they are a law for themselves, even though they do not have the law.

Gathercole has wrongly equated “doing the things of the Law”, etc., with doing the Mosaic Law itself. Yet, it is incontrovertible that to do the Mosaic Law, one needs to possess it to do it. Therefore, he maintains that the Mosaic Torah is written on the heart; it is Spiritualized and internalized in form. 

Golden rule #2

The second golden rule is that the Old Covenant and its Law were temporary, given for a period, entirely external in function and behavior, created for the flesh, and, consequently, fading in nature (Heb.8:13). The Old Covenant was at “fault”; it had an innate weakness built into it: it could not transform the flesh, nor could it fulfill the conditions it called for due to the flesh’s weakness (Heb.8:7-8; Rom.8:1-3). Which is to say that, the weakness of the flesh corresponded to the innate weakness of the Law of Moses itself. This is to be expected as both were external, physical, material, and entirely lacking the Spirit’s presence and internalizing power. This theology is the reason why, throughout Paul’s writings, and as commonly recognized by scholars, the Spirit is contrasted with the flesh, and is at war with the flesh.

In 2 Corinthians 3, Paul contrasts this physical, external, fleshly Covenant, whose Law was represented by the Ten Words that were written on two material stone-tablets, with the New Covenant and the internal Spirit that was in the hearts of believers. More specifically, Moses, the mediator of the Old Covenant and its Law, is contrasted in glory with Jesus’ glory in the believer through the presence of the Spirit. Moses had a form of glory on his physical face, his external appearance. It was temporary, fading, external, and fleshly. His fleshly glory corresponded to the external, material, stone tablets, and to a fleshly, faithless people, Israel. Whereas, the true believer has a permanent glory that images Christ, and these believers love one another, and rebuke one another (Rom.2:15); moreover, the believer changes from glory to glory to become more and more Christ-like in internal, Spiritual appearance. This is the New Covenant ‘law’ in action:  

Are we beginning to commend ourselves again? Or do we need, as some, letters of commendation to you or from you? 2 You are our letter, written in our hearts, known and read by all men; 3 being manifested that you are a letter of Christ, cared for by us, written not with ink but with the Spirit of the living God, not on tablets of stone but on tablets of human hearts.4 Such confidence we have through Christ toward God. 5 Not that we are adequate in ourselves to consider anything as coming from ourselves, but our adequacy is from God, 6 who also made us adequate as servants of a new covenant, not of the letter but of the Spirit; for the letter kills, but the Spirit gives life. 7 But if the ministry of death, in letters engraved on stones, came with glory, so that the sons of Israel could not look intently at the face of Moses because of the glory of his face, fading as it was, 8 how will the ministry of the Spirit fail to be even more with glory? 9 For if the ministry of condemnation has glory, much more does the ministry of righteousness abound in glory. 10 For indeed what had glory, in this case has no glory because of the glory that surpasses it. 11 For if that which fades away was with glory, much more that which remains is in glory. 12 Therefore having such a hope, we use great boldness in our speech, 13 and are not like Moses, who used to put a veil over his face so that the sons of Israel would not look intently at the end of what was fading away. 14 But their minds were hardened; for until this very day at the reading of the old covenant the same veil remains unlifted, because it is removed in Christ. 15 But to this day whenever Moses is read, a veil lies over their heart; 16 but whenever a person turns to the Lord, the veil is taken away. 17 Now the Lord is the Spirit, and where the Spirit of the Lord is, there is liberty. 18 But we all, with unveiled face, beholding as in a mirror the glory of the Lord, are being transformed into the same image from glory to glory, just as from the Lord, the Spirit.

For those reasons, the NT is unequivocal: Christians are not “under the Law”, nor do they keep it (Rom.6:14, 15; 1 Cor.9:20; Gal.3:23; 4:4, 5, 21: 5:18). The Mosaic Law requires of the human flesh a standard that it cannot perform: unremitting obedience to its external, in stone, fleshly, commandments (Rom.10:5; Gal.3:10-13; see Lev.18:5). Which is to say that, the flesh has no power to pull this feat off, nor does the Law have in itself the power to give to the fleshly sinner to bring forth obedience. In radical, black and white, contrast, Christians fulfill the “law of Christ” (Gal.6:2), which is to say they ‘keep’ the commandment to love in a cruciform and Spiritual fashion, by loving sacrificially God, their enemies, and their fellow Christians (Matt.5:43-48; Luke 9:23; John 13:34). This is a ‘law’ that has replaced this-world concerns, ethnic and sexual identities, normal worldly behavior, fleshly outcomes, external blessings and curses, and geographical boundaries, with the core of love, righteousness, peace, and other such Spiritual and kingdom values (Gal.3:23-29; Col.3:10-11; Rom.14:17, etc.). It is a law that is active and reveals itself in self-evaluation and reflection in the midst of the assembly, wherein Christians weigh up one another in the light of the Gospel and its New Covenant, internal, Spiritual, life.[7]

Replicating Moses’ Old Covenant Law

Gathercole’s reading has a third insuperable problem: it entails that Moses’ Old Covenant Law is duplicated and replicated in the hearts of Christians. To insist that the Mosaic Law is written on the heart is necessarily to demand that Christians keep the Law of Moses in its entirety. One cannot pick and choose which commandments to discard. It’s all or nothing.

Better Mosaic Law

The fourth major reason to cite against Gathercole is that he gives to the Gentiles a ‘superhero’ version of the Mosaic Law that far outstrips the ‘boring’ stone version that was given to Moses. Israel received a Law that was, by implication, valuable as part of God’s wider word (see Rom.3:2), and one of the many blessings, along with the Messiah, given to Israel of the flesh (Rom.9:4-5). Yet, this Law was not written on the heart! The Gentiles’ version was written on the heart and came with a guarantee of obedience (Jer.31:31-34). No competition!

Of course, Gathercole’s position flies in the face of the entirety of Hebrews. For it does not compare Mosaic Law with Mosaic Law, but Mosaic Law with a New Covenant law (to speak theologically) that is entirely heavenly, with a new mediator, new sacrifices, new location, new people, and, new covenant. All things New Covenant!

No mixing

The penultimate argument is that in Romans, faith and the Mosaic Law do not mix. What has faith to do with this Law (Rom.3:27)? It is not the Law of Moses and works that it is promoted, but the ‘law’ in the sense of faith and Spirit (3:31; 8:1-4). Paul is adamant, “But now apart from the Law the righteousness of God has been manifested, being witnessed by the Law and the Prophets” (3:21). Faith and Law do not mix- period!

There is a counter-argument to this, namely, that the OT saints loved the Law and kept it. However, I will address this subject in another article. Our concern here is what Paul argues in Romans 2. I have already addressed the subject of the Jewish believers and the internalization of the Mosaic Law in another place,[8] and will come back to this subject in my final article on Romans 2.

Not a renewed covenant

Lastly, Gathercole’s broad assumption is that the New Covenant is merely the renewal of the Old Covenant, “This is because of the covenant renewal whereby God writes Torah on, or circumcises, the heart”.[9] To be fair to Gathercole, this is probably the majority reading within scholarship. However, it does no justice to Jeremiah 31:31-34, nor to Hebrews 8:8, 13; 9:15; 12:24, which are firmly rooted in the position that the Old Covenant is discarded, and there is a completely new covenant, which does not continue the old, but replaces it entirely.

Furthermore, as NCTers we cannot accept that a wooden interpretation of the OT text is our guide to the NT teaching. It is the NT that teaches us how to interpret Jeremiah 31:31-34 as to its fulfillment, not Jeremiah 31:31-34 in itself. Moreover, Gathercole’s reading of the OT is suspect. He thinks it certain that Jeremiah 31:33 is the Mosaic Law. As said before, it cannot be. A new covenant (Jer.31:31-32) implies a new law, new people, and a new mediator. These are facts that come with the OT ‘territory’, and are not dependent at all on the NT. Moses was dead, for one thing. And Israel was divorced by God via the exile (Jer.3:1, 8-10). It was a new, righteous ‘Israel’ that was to return from exile. Patently, these prophecies were fulfilled not at the time of the return from exile, but in Jesus Christ’s death and resurrection.

Identifying the ‘law’

Both Gathercole and Moo operate on the basis that Paul’s statement in Romans 2:13- “for it is not the hearers of the Law who are just before God, but the doers of the Law will be justified”- is the interpretive control of verses 14-15, which say that the Gentiles keep ‘law’. Gathercole takes this to mean that these Gentiles keep the Mosaic Law that is internalized in the heart, and that on Judgment Day, God will judge them, and, due to their obedience to the internal Torah on the heart, he will declare them to be obedient sons, thereby justifying them as righteous.[10] Whereas, Moo says that no one can keep the Law of Moses to perfection, and that because of this, Paul is patently conjuring up a hypothetical scenario wherein some pagan-Gentiles’ obedience to a natural, internal, creational law behave in an upright manner, but the Jews, who hold to the Law of Moses, cannot keep it. This creation law is “God’s “law” in an extended sense”.[11]

Platonic model. It would seem that Moo’s reading necessitates a third law, almost in a Platonic sense, for there is the written version of ‘law’ and then its innate, creational version. This reminds me of the Reformed idea of one covenant, two administrations: one law (the ideal, ‘Platonic’, law) with two manifestations. As said in response to Gathercole, Paul’s point is that there are two distinct laws, for they are not the same. 

No Mosaic Law! Another major feature that is problematic is both scholars think that vv14-15 explicate verse 13. This goes against Paul’s polemic. His aim in Romans 2 is to expose the hypocritical standard of the Jews. To counter their hypocrisy, in vv12-13, Paul exposes it by the argument that demonstrates that they- the Jews alone- do not keep the Mosaic Law. Paul could not have been clearer: 

12 For all who have sinned without the [Mosaic] Law will also perish without the [Mosaic] Law, and all who have sinned under the [Mosaic] Law will be judged by the [Mosaic] Law; 13 for it is not the hearers of the [Mosaic] Law who are just before God, but the doers of the [Mosaic] Law will be justified.

Previous context. Up unto v13, the Gentiles Paul has spoken of are all the moral reprobates and idolaters of Romans 1- an exceptionally important point in context. These reprobate Gentiles are simply not part of the judgment according to the Mosaic Law, for they do not have this Law. Therefore, it is impossible for them to attempt to do it, so as to be judged according to it on Judgment Day. They will be judged based on their innate knowledge of the Creator and of their duties to the Creator and to the creature, as Romans 1 implies. More to the point, these pagan Gentiles will not be judged by ‘law’ of any kind. Romans 1 does not mention it, and there is no need to create a new version of law just to suit theological presuppositions. It is the Jews alone who fail to reach the ‘prize’ of justification on the Final Day that is based on obedience to the Law of Moses. Paul’s simple summary of the pagan Gentiles is that they will be judged by their works done outside the Mosaic Law and apart from any kind of ‘law’- for this, see Romans 1:18ff..

New development. This theological arrangement is the background for what Paul then develops in vv14-15. It is entirely critical to understand that Paul’s argument takes a new spin in v14 concerning Gentile obedience. The Jews were so obsessed about their fake faithfulness to the Mosaic Law that Paul’s penultimate counter-argument is to present a different class of Gentiles who are law-men. These Gentiles are still without the Mosaic Law, and so in that sense are ‘true Gentiles’; yet, Paul astonishingly says they are a “law unto themselves”! They break the mold of the whole ‘keeping the law’ paradigm, for they are in and of themselves ‘law-men’. Nothing of this sort was said of any Jew in the OT, except in a few instances, as I said in another place, where David refers to the law in his heart, and where New Covenant language intervenes.[12]

These Gentiles in vv14-15 are patently of a completely different stripe to the previous ones, for they are obedient to God. They are not God-fearers such as attached themselves to the way of Israel and to the Torah, for Paul has made it abundantly plain that the Gentiles do not have the Law. No, these are not ‘natural’ Gentiles, or ‘Jewish Gentiles’; they are New Covenant Gentiles, for they have “the work of the Law written on the heart”.[13]

Judgement Day. Paul’s final ‘dagger in the heart’ of the Jews is to imply that these Gentiles who are currently a “law unto themselves” will be manifested as faithful law-men on the Day that God judges all, and this will be according to Paul’s Gospel, for these men are New Covenant believers (v15). All bases are therefore covered: law, justification, work, covenant, judgment, Final Day. Almost as if to say, ‘You name it, Jews, these law-men Gentiles have it covered!’

Internalization of in-person law

Let’s take a moment to ponder this distinct New Covenant law and its internal nature. It is New Covenant in nature, for its work is in the heart of man, in harmony with Jeremiah 31:33. Also, it is embodied in people, for these Gentiles were a law unto themselves.[14] Paul’s interpretation of the same law’s existence in 2 Corinthians 3:1-2 is quite remarkable, for he writes that the Corinthians were written on his heart (and the hearts of the apostolic band). Which is to say that Paul teaches that New Covenant love is internalized in ‘person’ form, wherein love to one’s neighbor is internalized as people dwelling in the heart. This is reflective of Jesus’ teaching in John’s Gospel, for example, in which he declares that he and the Father will come to dwell with those whom they love and who keep his commandments (John 14:2; 17:23, 26). This internalization of persons that comes from love also sheds additional light on Jeremiah’s further comments:

33 …”and I will be their God, and they shall be My people. 34 They will not teach again, each man his neighbor and each man his brother, saying, ‘Know the Lord,’ for they will all know Me, from the least of them to the greatest of them,”…. (Jer.31:33-34).

The two great duties of man- to love God and to love one’s neighbor- are therefore fulfilled in an intimately personal fashion wherein the persons who are the object of this love are ‘written’ on the hearts of those loving, so that they “know” God and “know” one another as God’s people.

Those phrases

Moo and Gathercole. They also differ on how to understand Paul’s phrases “things of the Law” and “work of the Law”. Moo separates the phrase “the things” from “of the Law” and “work” from “of the Law”, saying that “the things” and “work” do not denote the Mosaic Law but its standard, or things, or work. The Law of Moses called for love to God and to one’s neighbor. The pagan Gentiles were able to perform part of this standard, or righteousness, by keeping to their internal, creational law that was on their hearts.[15] Gathercole says that to divide “work” from “of the Law” is to “split hairs”, for the phrase “work of Law” denotes the Mosaic Law.[16] Similarly, the entire phrase “the things of the Law” simply means the Mosaic Law.[17]

NCT model #1. NCT has the best model for interpreting these phrases. In addition to them, we can include “requirements of the Law” (2:26) and “fulfill the Law” (2:27, ERV). There are two NCT approaches to these phrases that are viable. The first uses a part of both Moo’s and Gathercole’s arguments. Paul is referring to the Mosaic Law most of the time (similar to Gathercole), except when he says that the Gentiles are a “law unto themselves”, for it refers directly to something similar to the New Covenant “law of Christ” (Gal.6:2). In this particular NCT view, instead of positing that the Mosaic Law is being kept, it is its “things”, and its “requirements”- similar to Moo’s position. It is its work, not the Mosaic Law itself, that is written on the heart. In other words, the “requirements”, “work”, and “things” of the Mosaic Law are not its commandments, but the two main principles of love to God and to one’s neighbor. The Mosaic Law is discarded entirely as belonging to the Old Covenant, but the New Covenant nevertheless utilizes the Old Covenant Law as being like a prophetic document that indicated a superior Law, ala the book of Hebrews. So, the phrase ton nomon telousa in Romans 2:27 is not about keeping the Law, but of fulfilling (teleo) it, in the sense that its two great expectations of love to God and love to man were absorbed by the NC and embodied in its people.

NCT model #2. I prefer the second NCT reading. It cuts the tie completely with the Mosaic Law, and says that the Christian Gentiles are following the “law of Christ” only, and deduces these things within the hermeneutical framework of the interpretive priority of the NT over the OT. I have already labored to show that the Gentiles throughout Romans 1 and 2 do not have the Mosaic Law. It would be counter to Paul’s reasoning to attach them to this Law, even if it were merely to do its “things”. Moreover, faith and the Law as simpatico destroys Paul’s teaching that faith and the Mosaic Law do not mix. In Romans 3:21-24, it is not the Mosaic Law itself that is prophetic, but it is the Scriptures as a whole (“Law” being the Pentateuch, and the “Prophets”). Therefore, Gathercole’s insistence that a “[c]onsiderable burden of proof” is on those who dispute that nomos always means the Law of Moses in Romans 2, ought to be turned on its head in reference to the Gentile Christians. For Paul is a New Covenant apostle-theologian (Rom.1:1) set apart to the Gospel; not a rabbi, or priest, set apart to parse the Law of Moses. New Covenant priority alone accounts for the Gentiles being called a “law unto themselves”, which was, as said before, unheard of in OT times for different reasons. For the NT is reinterpreting OT categories and terms to suit its own New Covenant agenda. Just as Christ incarnated the New Covenant- it was in his blood (Luke 22:20; 1 Cor.11:25)- so the New Covenant law and its dynamic of love and obedience is incarnated in God’s New Covenant people. The New Covenant law internalizes people/persons through love within the heart. It is a moving, vibrant internal law that propels the New Covenant community to assess one another out of love and from fidelity to the Gospel (Rom.2:15).

The second NCT reading better accounts for Romans 3:27; 7:14-25; 8:1-4, wherein the New Covenant and its law are contrasted with the Mosaic Law of the flesh, similar to 2 Corinthians 3. If the section in Romans 7 is objected to, this text must be interpreted in the light of Paul the Jewish Christian speaking to Jewish Christians (7:1). Paul’s Jewishness is tied to his flesh and body, as they represent the old man that battles with the new man, which is not Paul himself, but Christ in Paul the Christian (Rom.13:14; Gal.2:20; 5:16-17; Eph.4:22-24).[18]

The similarities in language between Old Covenant Law and New Covenant law are deliberate, for Paul is setting out his stall that the New Covenant and its law replaces the Old Covenant and its Law. This does not mean that the Old Covenant and its Law had no connection with the Gospel. For the Law condemned men in sin in preparation for the coming of the Gospel (Rom.3:9-20; 5:13; Gal.3:21-22; 2 Cor.3).

Specific phrasing. Having said these things, there is value in the specific wording of Paul’s phrases concerning the New Covenant law in Romans 2. Each phrase should not be reduced to saying, essentially, “New Covenant law”. Indeed, Gathercole’s view reduces “Law” phrases to mean merely “Mosaic Law”, for he does not fully appreciate the wording of each phrase. Moo attempts to address the specific wording, but takes us away from the New Covenant import. To stress the “work” of the law and not the “works” of the Law is a crucial distinction. For to use the “works of the Law” would undoubtedly signal Paul’s rejection of doing the Law of Moses and its works (Rom.3:20, 27, 28; 4:2, 4, 6; 9:12, 32; 11:6). Whereas, “work” (ergon, singular) signals the presence of the internal Spirit, in whom the Gentiles received the circumcision of their hearts (see ahead), which produces a life- that of Christ- that infallibly and inexorably executes the one divine will, so that the New Covenant is never violated, “for it is God who is at work in you, both to will and to work for His good pleasure” (Phil.2:13). For the emphasis is not on man’s works (unlike the Jews, their flesh, and the Mosaic commandments), but on God’s work in the hearts of Christian men via his divine presence in the Christ-Spirit (see 2 Cor.3:17).[19] Similarly, “the things” (ta tou nomou) of the New Covenant law is a deliberate abstract phrase used, once again, to avoid any connection with the Mosaic Law. The New Covenant law’s “requirements” uses the plural of dikaioma to convey the contrast, in context, between the various failed attempts of the Jews to accomplish righteousness, contrasted to the 100% success rate of an infallible New Covenant in the heart and life of Gentiles. For a core tenet of the New Covenant law is that the New Covenant cannot be broken (Jer.31:31-34). Finally, Paul’s use of teleo in Romans 2:27 is preferably rendered “fulfill”, not “keep”, because Paul is, once more, contrasting the Jewishness of failing to keep the Mosaic Law’s letter by the circumcised ones with the fulfilling of the New Covenant law by uncircumcised ones. The aspect of fulfilling, although undoubtedly conveying an act on the part of the Gentile Christians, is suggestive of the Spirit’s work in the believer to bring about New Covenant perfection (such as described above) (Jam.2:8).

In anticipation of an objection, the New Covenant model does not remove the presence of sin in the believer. Nonetheless, it does say that Christ’s life in the believer, which is the sole source of every obedient act, has a 100% success rate, and never fails to achieve its goal of righteousness. It is the flesh of the believer that gets in the way of the perfection of Christ’s Spirit manifesting itself in us.

In-Spirit circumcision

I spoke before of who the ‘true Jews’ were of Romans 2, namely the Gentiles of faith who fulfilled the law of Christ.[20] Internal circumcision of the heart is in the Spirit, by God. The Spirit is not the one who circumcizes the heart; it is “of God” (ek tou theo) (2:29). Instead, the type of circumcision is indicated: it is not in the flesh, revealing the letter of the Mosaic law, but it is in the heart, revealing the Spirit. The lives of the Gentiles was an ”in-Spirit’ one (en pneumati) (2:29). Paul uses the same phrase in Romans 8:9 to denote the status and life of the believer, “you are not in the flesh but in the Spirit”. Christians belong to, and live in, the ‘sphere’ of the Spirit, not of the flesh, “for the kingdom of God is not eating and drinking, but righteousness and peace and joy in the Holy Spirit [en pneumati hagio]”. Likewise, Romans 15:16 ought to be interpreted “sanctified in the Holy Spirit [en pneumati hagio]” not “by the Holy Spirit”, for the context is about the type of offering that the Gentiles were: a Spiritualized one, not one of the flesh that was according to the letter. As Paul’s contrast between flesh and Spirit everywhere declares, it is the New Covenant lifestyle and status that the Spirit’s presence indicates. His presence in and with the resurrected Christ marked out his Sonship (Rom.1:4; see Gal.4:6, 29). True Jews (sons) are Spiritual, for Christians are Spirit-men. Paul indicates the same thing by the phrase “baptized in one Spirit” (en eni pneumati) (NET), not “baptized by one Spirit”.

The point of making the above distinction is to bring to our focus the common theme in Romans 2 concerning these Gentiles, that God and his people are internalized in their hearts. This could never be achieved by fleshly circumcision, or in the letter. It was accomplished solely through Jesus’ death and through the subsequent gift of the Spirit, which the believers walk according to:

Therefore there is now no condemnation for those who are in Christ Jesus. 2 For the law of the Spirit of life in Christ Jesus has set you free from the law of sin and of death. 3 For what the Law could not do, [b]weak as it was through the flesh, God did: sending His own Son in the likeness of sinful flesh and as an offering for sin, He condemned sin in the flesh, 4 so that the requirement of the Law might be fulfilled in us, who do not walk according to the flesh but according to the Spirit. (Rom.8:1-4; see Rom.8:5-16, 23, 26-27; Gal.5:16-18, 22, 25; 6:8).

Paul draws out further what he means by his comment in Colossians 2:11, “and in Him you were also circumcised with a circumcision made without hands, in the removal of the body of the flesh by the circumcision of Christ”. It is not the Spirit who circumcizes, but God, and he does it via faith in the circumcision of Christ, which we ‘wear’ or put on by faith, aka, the baptism of Christ (Rom.6:3-6). It is by the cross that God removes sin- circumcision- and in the resurrection that the Spirit is given (adoption as sons).


Gathercole’s reading of Romans 2 is both exciting and immensely frustrating. It wonderfully highlights the Christian nature of the Gentiles of vv14-15, 25-29, only to counteract this interpretation with the position that New Covenant Gentiles receive the Law of Moses on the heart. Paul is perfectly clear in context: the Gentiles do not have the Law of Moses. This theme drives us to the conclusion that the NCT view that argues that the standard (“things”/”work”/”requirements”) of the Mosaic Law are kept but not the Mosaic Law itself is incorrect, for it inadvertently bypasses Paul’s divide between the Mosaic Law and the New Covenant Gentiles as being “law unto themselves”, and makes the Mosaic Law compatible with faith and true obedience. If Paul’s whole argument in Romans 2 is seen as founded upon Romans 1:1-17 and its belief in the New Covenant Gospel, then there is no issue with Paul introduces Christian Gentiles and the New Covenant law into Romans 2.

I am aware that I have not addressed in full Romans 2:13 and the issue of justification by works. Nor did I provide a fuller answer to the issue of OT Jews who were Christian, had an internalized version of ‘law’, and of those OT believers who ‘kept the Law blamelessly’. This article is already way over what I originally aimed at, so I will, with some reluctance, write a final ‘final’ article on Romans 2. Let’s hope it will be the actual real deal!

[1] Angus Harley, “Some comments on phusei in Romans 2:14”, All Things New Covenant, May 9, 2023,; “Some more comments on Romans 2:14,” All Things New Covenant, May 10, 2023,; “The New Covenant Gentiles of Romans 2:14-15,” All Things New Covenant, May 13, 2023,

[2] Simon J. Gathercole, “A Law unto Themselves: The Gentiles in Romans 2:14-15 Revisited,” in Journal for the Study of the New Testament 85 (2002): 33.

[3] Ibid.

[4] Ibid., 29.

[5] Ibid., 37.

[6] Ibid., 42.

[7] Harley, “New Covenant Gentiles”.

[8] Angus Harley, “Psalm 5: a Model for Understanding the OT Law”, All Things New Covenant, February 12, 2023,

[9] Gathercole, 40.

[10] Ibid., 33.

[11] Douglas J. Moo, Romans, NIV Application Commentary (Grand Rapids, MI: Zondervan, 2000), 85-86.

[12] Harley, “New Covenant Gentiles”.

[13] Harley, “More Comments”, “Some Comments on Phusei”.

[14] Harley, “New Covenant Gentiles”.

[15] Moo, 85-86.

[16] Gathercole, 41.

[17] Ibid., 31.

[18] Contra Moo, Romans, 225ff..

[19] Paul is straining the Greek language to say that Jesus and the Spirit are one functionally, and this leads him to say that the “Lord is the Spirit”. Not that Jesus is the Spirit, or the Spirit is Jesus, but that they are entirely inseparable, and to see one is to see the other, where one is, then the other is there. Upon his resurrection, Jesus was given the Spirit and marked out as the Son of God. In that capacity he is the Spirit-Man, the Spirit-Lord.

[20] Harley, “New Covenant Gentiles”.