By Angus Harley

James’ teaching on the theme of the law is difficult for anyone to comprehend. NCTers are split as to James’ intent in using ‘law’. Is he referring to the Mosaic Law, or to the New Covenant law? Or does he flow from one law to the other? I argue that, by using our NCT bearings, we will see that James’ use of ‘law’ is invariably referring to the New Covenant law. To underscore this reading, it is imperative that the reader comprehend that the “word” James refers to in chapter 1 is the “law” of chapter 2. I will exegete the following contexts that contain “word” and “law”: 1:18-27; 2:8-13; 4:11-12.

James 1:18-27

18 In the exercise of His will He brought us forth by the word of truth, so that we would be a kind of first fruits among His creatures. 19 This you know, my beloved brethren. But everyone must be quick to hear, slow to speak and slow to anger; 20 for the anger of man does not achieve the righteousness of God. 21 Therefore, putting aside all filthiness and all that remains of wickedness, in humility receive the word implanted, which is able to save your souls. 22 But prove yourselves doers of the word, and not merely hearers who delude themselves. 23 For if anyone is a hearer of the word and not a doer, he is like a man who looks at his natural face in a mirror; 24 for once he has looked at himself and gone away, he has immediately forgotten what kind of person he was. 25 But one who looks intently at the perfect law, the law[1] of liberty, and abides by it, not having become a forgetful hearer but an effectual doer, this man will be blessed in what he does. 26 If anyone thinks himself to be religious, and yet does not bridle his tongue but deceives his own heart, this man’s religion is worthless. 27 Pure and undefiled religion in the sight of our God and Father is this: to visit orphans and widows in their distress, and to keep oneself unstained by the world.

V18. The “word” belongs to the divine operations of the new creation as the phrase “first fruits among his creatures” implies (see Rom.16:5; 1 Cor.15:20, 23; 1 Cor.16:15). Specifically, the word of truth “brought us forth” (apekuēsen). This phrase is contrasted to the same term used in v15, “brings forth” (apokuei), for the latter refers to sin bringing forth death. Sin is here personified and contrasted to God. Sin brings forth death; God brings forth first-fruits. However, God’s will and action is accomplished by means of the “word of truth”. The idea that the Mosaic Covenant and its Law are the word of truth does not fit, for they cannot create first-fruits of a new creation (Rom.7:7-13; 2 Cor.3; Gal.3:21-22; Heb.7-9). The way “word of truth” is functioning in context, it is very similar to, or the equivalent of, the Gospel itself. Whatever the specific identity of this word of truth, as truth it lies in sharp contrast to lying and self-interest (3:14). This is the truth that if a believer wanders from it, he will be swallowed up in death and his sins (5:19-20). These verses remind us of the contrast between 1:15 and 1:18. As “truth” contrasts sharply to sin and death, this confirms that the identity of truth does not lie in the realm of the Old Covenant and its Law. The phrase “word of truth” emphasizes that the truth is not just ethical or internal, as it is spoken or written, too. Given the immediate emphasis upon listening (1:19, 22, 23, 25; see 5:11), the word of truth was preached, or read out, or taught publicly.

V21. The assembly is told to put aside all filthiness and extreme wickedness, and in meekness receive “the implanted word”. This is the only time in the NT that “implanted” (emphutos) is used. This word can mean ‘inborn, innate’, or ‘implant’. In the non-biblical verse Barnabas 9:9, it is used in connection with the covenant, “He who placed within us the innate (emphutos) gift of His covenant knoweth” (see, Barn.1:2). The potential meaning ‘innate’ cannot convey the notion that Christians naturally had this word in their hearts. If ‘innate’ is to be used, it can be so only in the sense that God created something innate within a new heart during the act of new creation. Scholars prefer ‘implant’ because it comes away from any idea of something innate to man.

To be implanted, God must have put it there, since it was by an act of his will that the assembly were brought forth as first-fruits by the word of truth. He made them first-fruits, in other words, by internalizing, implanting, in them the word of truth.

Specifically, the assembly is told to receive this “implanted word”. It was internalized and implanted by God, but now it must be received and constantly adhered to. This word is now ‘naturally’ in the new-creation hearts of the assembly of first-fruits. It is not a matter of mere hearing, which is external, but of doing, which is from the heart, internal. This is to say that, James is deliberately calling on the assembly as first-fruits to follow the word in its internal and implanted form, to receive it, so as to be obedient to it, and, by extension, to God.

The implanted, or innate, nature of the law draws our attention to the central blessing of the New Covenant, that God will write his law on his people’s hearts (Jer.31:33; Rom.2:15-16, 26-29). So, is the word of truth the Gospel, or the New Covenant law, or both? I prefer that it is the New Covenant law, not the Gospel per se. The epistle of James does not spend any time on what we call the ‘Gospel’ of Jesus’ death and resurrection, but he moves right into Christian living. The whole letter is taken up in this theme.

For this implanted word, as internal, is able to save the soul, presumably because it was God’s means to create the first-fruits, and now because it is embedded in their hearts. It saves not in the sense of bringing a sinner to faith in Jesus for the first time, for these first-fruits were already a new creation. It saves, rather, in the sense that it delivers those who are first-fruits from the dangers of trials of the flesh and even death, but also from God’s righteous judgment on sin, in the here and now, due to foolishness and sin on their part. Of someone ill in the assembly, James writes, “and the prayer offered in faith will restore (sōdzō) the one who is sick, and the Lord will raise him up, and if he has committed sins, they will be forgiven him” (5:15). There’s a very thin line, here, between a believer who is ill in the normal way of things and facing death, and a believer who is ill because of his sin and facing a divine judgment of death. James warns the assembly, “There is [only] one Lawgiver and Judge, the One who is able to save and to destroy; but who are you who judge your neighbor?” (4:12). Brothers were judging brothers, thereby judging the ’law’, and were not doers of the law (4:11). They were immediately to desist from this form of judgment, so that God would save them and not destroy them (4:12), which destruction was probably in the form of death. And of a brother who has strayed from the truth, James asserts, “19 My brethren, if any among you strays from the truth and one turns him back, 20 let him know that he who turns a sinner from the error of his way will save his soul from death and will cover a multitude of sins” (5:19-20). See how death is again the form of divine judgment.

These things entail that it is the New Covenant, internalized, law that ‘saves’ those who are already believers. It does so as God’s instrument, remember, not as something in and of itself, as if it were our Savior. In casting our minds back to Jeremiah 31:31-34, Jeremiah taught that the Old Covenant failed, for Israel sinned against God and did not know him. To remedy this, there was a new covenant and a new law, one written on the heart, thereby guaranteeing obedience and faithfulness to God. This law does not fail to ‘save’. It is 100% successful. However, Christians sin. This is not due to any failure in the internal law, but in the Christian himself, as is recorded in 1:14, “each one is tempted when he is carried away and enticed by his own lust.” The amazing thing is, that even such a sinful one is, nonetheless, still a first-fruit who by faith will persevere in obeying the will of God, for he has the implanted will in his heart.

V22. James commands the assembly of first-fruits to “be” (ginesthe) doers of the word. If they are, indeed, true first-fruits of the Lord, they will “be” doers of his word. It will be impossible for them to be anything other. They will not be only hearers of the word. To be a mere hearer is to deceive oneself (see Col.2:4); it is to persuade oneself that everything is ‘ok’ with merely hearing, and that doing is not such a big thing! In James’ equation, 1+1=2: hearing + doing = obedience to God. Mere hearing, mere ‘faith’, is not an option in James’ way of looking at the first-fruits of the assembly in their lives before God (2:14-26). A true first-fruit will “be”, therefore, both hearer and doer of the word. It is an inevitable outcome.

Vv23-24. Anyone who is a mere hearer, says James, is like someone looking in a mirror, seeing himself, and then forgetting what he looks like. What does this mean? It indicates that when one “hears” the taught word, it functions to remind the assembly of first-fruits that they are true new creations internally, and who have the same word implanted in them internally. The external word functions, in other words, to confirm the internal word.

Often that is where the line is drawn by commentators. However, there is a surprising, yet more fundamental, aspect that is often passed over. In hearing the word, the believer sees his new-creation ‘self’ in this word, for the word of truth is acting like a mirror. James expects the believer to follow through on the sight of his new-creation identity as reflected in the external word, by being that person in action, by doing. The New Covenant word of truth or law that is spoken externally conveys the high (royal) imagery of a person, not mere commandments; and it is this New Covenant ‘person’ that is supposed to reveal himself in action by obedience to God. Put another way, James does not think of a list of commandments that a believer/person is meant to do, as in the Old Covenant model, for the New Covenant model is that the believer ‘becomes’ or ‘is’ the law. When God implanted the New Covenant ‘law’ or ‘word of truth’, he was, in effect, implanting a new person, a new creation, who inevitably did embody God’s will in action.

I wrote about the same theology of ‘law embodiment’ in a different place. For exactly the same theology is brought out in Romans 2:14-15 and 2 Corinthians 3:

“These NC Gentiles were a “law to themselves”, a condition similar to that describing other believers in the NT. In the OT, the Jews ‘wore’ the Mosaic Law on their flesh, meaning that it was all about their external, material, fleshly condition. They were physically circumcised, the Ten Words were written on physical stones, they physically tied commandments to their arm, the Jews were born according to the flesh, they lived in a physical land, were rewarded with material blessings, cursed with material and physical curses, worshiped through the human senses of the body, used literal animal sacrifices, and worshiped within a literal ‘bricks ‘n’ mortar’ temple. Thus Moses ‘wore’ the temporary divine glory on his actual physical face (2 Cor.3: 7-11). By sharp contrast, the believers in Christ, even those who were Gentiles, were Spiritual beings, whose “inner man” was glorified with the permanent and growing glory of the Christ (2 Cor.3:16-18; 4:6, 16). Their glory was not, in other words, in the flesh. 


A similar condition to the Gentile believers is found in 2 Corinthians 3. Paul writes that the Corinthian believers were written on the hearts of the apostolic band, and that this is in direct contrast to the letter of the Ten Words that were written in stone (2 Cor.3:1-3). By implication, Paul is teaching that the New Covenant model is that people are the embodiment of the law and letter of Christ. The law of God is metaphorically incarnated, fixed in the realm of the “inner man”, not of the flesh. This is in direct opposition to the actual written precepts of the Mosaic Law that were on stone, on two tablets. It is not commandments and precepts that constitute the law of Christ, therefore, it is the Spirit’s glorifying presence in believers’ inner man [sic] turning them into the very image of the Christ himself (see Rom.8:1-4).”[2]

Even though James does not describe this new-creation, or New Covenant, law in its union with the Spirit, or Jesus Christ, theologically, as Paul’s teaching indicates, it is proper to mark those relationships.

Vv25-27. These verses flow from the previous two, but we will separate them because of the use of “law”. Herein lies confirmation that the “word of truth” is not the Gospel as such, for the Gospel is never called “law”. It was not the Mosaic Law of the Old Covenant, which was external, on stone, and could not save anyone. This is law on the heart, internalized, implanted there by God himself, making a new creation of first-fruits. It is the New Covenant “law”.

In continuation of the previous two verses, James refers to those who take an intense look (parakupsas) (cf., Luke 24:12; 20:5, 11; 1 Pet.1:12) into the law must follow this through with doing it. The external function of the word or law, as something to be listened to, must give rise to the internal word kicking-in and giving way to obedience.

James specifically calls the word of truth the “perfect law” (nomon teleion), and adds in explication, “that of freedom” (ton tēs eleutherias). It is called “that of freedom” (see 2:12) because as law it innately brings with it freedom from death, temptation, and sin, and, therefore, the power to both hear and obey. That this is the New Covenant law is marked out by its “perfect” nature. God creates only that which is perfect: the perfect man (1:4; 3:2), and the perfect gift (1:17). Specifically, the law’s ‘perfecting’ property lies in it inevitably resulting in doing and works, “You see that faith was working with his works, and as a result of the works, faith was perfected” (2:22). This is to say that, it is not only divine law- as was the Mosaic Law- but it is law that must result in obedience (2:8)- unlike the Mosaic Law.

The inability, then, for believers to bridle their tongues, their lack of compassion toward orphans and widows, and their worldly lifestyle (1:26-27), highlight that they are not acting as first-fruits, they are not showing that the New Covenant law set them at liberty to obey, and that it, in the hands of God, created a perfect man- a New Covenant man who does obey.

James 2:8-13

8 If, however, you are fulfilling the royal law according to the Scripture, “You shall love your neighbor as yourself,” you are doing well. 9 But if you show partiality, you are committing sin and are convicted by the law as transgressors. 10 For whoever keeps the whole law and yet stumbles in one point, he has become guilty of all. 11 For He who said, “Do not commit adultery,” also said, “Do not commit murder.” Now if you do not commit adultery, but do commit murder, you have become a transgressor of the law. 12 So speak and so act as those who are to be judged by the law of liberty. 13 For judgment will be merciless to one who has shown no mercy; mercy triumphs over judgment.

It is assumed by most that James calls Leviticus 19:18 “the royal law” as part of the Mosaic Law. So it is said that, the Mosaic Law is therefore still functioning today as it did back in the day, yet in a new and spiritual fashion. For in the New Covenant era, the Law has been modified and perfected for the assembly due to Christ’s perfect teaching on it, and his fulfillment of it, by which its ‘true’ Christological and moral essence is now in operation in the New Covenant. In this way the Law of the Old Covenant becomes the new law of the New Covenant (see John 13:34).

The above view is a misdirected mixing of both Old and New Covenants, Old and New laws. The reader would have perhaps seen the move from “word” in James 1 to “law” in James 2. It is called “word” in James 1 because, like the word of God in creating the universe, it is spoken and it gives life- spiritual, internal life. It is law because, like the Old Testament view of law, it demands and commands according to Scripture. However, it is not mere law, mere commandment, mere Scripture, for it is New Covenant law of action in the heart that prevails and gives rise to true obedience. This change from “word” to “law” is vastly important because in 2:8-13, James does not have at all in mind the Mosaic Covenant or its Law as a control of God’s New Covenant assembly of first-fruits, but only the New Covenant word or law.

Furthermore, it is essential to bear in mind that the Mosaic Law and its Decalogue were the essence of the Mosaic Covenant. You cannot have one without the others (2 Cor.3). The fall of the Old Covenant meant the end of the Law and its Decalogue.

V8. In response to the traditional view, James does not cite the Decalogue in regard to Leviticus 19:18. This is a fact that gets forgotten due to the reductionist mode that the traditional model operates with. Nor does he imply that the citation of Leviticus 19:18 summarizes the Decalogue. To think it does, once more reads into the text.

Perhaps, then, he is summarizing the Mosaic Law? Again, he is not. Although Leviticus 19:18 was in what was called ‘the Mosaic Law’, it is no longer relevant as Mosaic Law. That Law is over, along with its Covenant. That is why James distances himself from the Mosaic Law by referring to “Scripture”.

More pointedly, it is not the written commandment as recorded in Leviticus 19:18 that is James’ proper focus- although the hearing of the written commandment is certainly the first step-  for the New Covenant law centers on doing- the actual doing of love toward your neighbor. It is this action of loving- not the written commandment as such- that is the “royal law”. We know this because the law of love is perfected (teleō), not ‘kept’ or even ‘fulfilled’, by one who does love, and who does not merely hear. It is one thing to hear the written word, to understand its preaching, to know or hear about loving one’s neighbor, but quite another to do this very command. Only by doing it is the way of love that is spoken of in Scripture perfected.

It is called the “royal law” because it is the New Covenant law of God, who is King, but more pertinently to the context, it is due to its regal nature as the perfect law of actual doing and loving in action, and not merely the act of hearing a commandment. It is, in other words, the perfect law that is expressed in the loving behavior of heirs of the kingdom (2:5). It is no surprise that the Old Covenant, Mosaic, Law by contrast is nowhere called the “royal law” or “law of liberty”, for it was a ministry of death that killed and brought condemnation (2 Cor.3).

By this point, the reader will be fully aware of the unity and diversity of this word of truth, aka, the royal law. Although the word of truth, or royal law, is a unit, a whole, it has two aspects: it is in the form of explicit words in the Scriptures that are read and preached; but it is also ‘written’ into the heart in the form of actual doing and perfecting. Both are two sides of the same ‘law’ coin. You can’t have one without the other. Or, at least, the New Covenant assembly should not have mere hearing without doing. The teaching about love as given in Leviticus 19:18 is not enough in itself. Love-in-action, and not a mere commandment, was embedded in the heart by God, so that his assembly of first-fruits could and do obey the call to love.

Vv9-10. The traditional view says that these verses must be the New Covenant version of the Old Covenant duty to obey the holistic nature of the Mosaic Law, because if one breaks one commandment, one breaks them all (Rom.2:25; Gal.3:10; Deut.27:26).

As we have seen, James is not concerned with any rendition of the ‘Mosaic Law’. It is the New Covenant law that is his sole concern. The whole of the OT testifies as “Scripture” to the two sacred and central principles of loving God and loving one’s neighbor (Matt.22:40; Rom.13:8; Gal.5:14). Failure to actually ‘do’ love, to love others, is now ‘on the cards’ within the New Covenant assembly precisely because, unlike the Old Covenant people, the New Covenant law is on their hearts and is alive and active and able to save. It is not acceptable by this standard of perfection (actually loving one’s neighbor and actually loving God) that someone can be a mere hearer who does not love God or one’s neighbor. To forget what one looks like (1:23-24) by not doing, by not loving, but by showing partiality, is to egregiously violate the royal law. This, the royal law of perfection, holds him to account, judging him, and convicting him as a transgressor.

Let’s look at the “perfect man” who could bridle his tongue (3:2) as an example of the difference in outlook and interpretation. Some who hold that James is advocating the Mosaic Law in a New Covenant form, allow that 3:2 implies it is still impossible to obtain, or reach, perfection. The best one can do as a Christian is attempt to hit the height of perfection. However, this is to reverse the polarity of the laws or the Covenants, even. The nature of the Old Covenant and its Law was that it was a series of external commandments that could not transform and give life (Rom.8:1-3; Heb.8:7-8). The Jews broke the Mosaic Covenant on its very first day! Perfection was always the New Covenant norm (Jer.31:31-34), as our Lord explicitly commands (Matt.5:48). The New Covenant and its law, by radical contrast, were not only written and heard, but were implanted and enacted. Thus, the “perfect man” is not an unattainable aim, but a is a reality that is lived out, demonstrating the success of the New Covenant and its implanted law. Perfection in the sense of doing is the norm, not some ideal that can never be attained!  To sum up, it is not the inability to do the (Mosaic) Law that James has in mind, but the intrinsic power to ‘do’ the New Covenant law.

The standard model of holiness is that it is something that grows in incremental stages, step-by-step, a bit here and a bit there, until, one day, we will be made perfect. This is true on a certain level, for as long as we are in the world of the flesh, sin will pull us down, and our likeness to Christ will often be strained as it grows. Even so, James’ thinking does not seem to operate in that manner. To him, perfection is not a height to hit, but, as said before, it is the norm, the New Covenant lifestyle. How is this possible? Because to James, the believer in his life in this “world” is assailed by his own lusts and sins (1:14, 27; 2:5; 4:1-4). For that reason, a new creation was required, divine and implanted life by God himself, no less, to transform a sinner into an obedient follower. This internal, new, life is not an extension of life in the world that the Christian often gives in to and lives out. Nor are they opposite ends of some moral scale. They are, rather, two different lifestyles, from two different worlds: one from above, one from below (1:15-18). So that, when the Christian engages in lusts, or lacks faith, he is behaving as a “double-minded” man who is meant to be single-minded in obedience, but gets swallowed up in disobedience and doubt (1:5-8).

Within this world: lust, sin, murder, mere hearing; double-mindedness

From above: perfection, doing, loving, true religion; single-mindedness

From this we see that, perfection is not something that we try to aim at, for mere trying is the life of the world that is failure, and leads to sin and death. The New Covenant life is that of perfection, of doing, of loving and of showing mercy. It is to “be” these things. This is why the NT writers not only expect believers to be obedient, but demand it as a ‘natural’ way of heavenly sons. In other words, James’ form of perfection does not mean that the believer is sinless, for the world assails him, but that in functioning truly as a new creation, he will do and obey, for the life in him is God’s life of perfection, of true love. God’s love and will are never vitiated or powerless, but inexorable, 100% effective, and bring forth love in the believer. God’s law in us, is God’s life in us. Can God sin, or even tempt to sin (1:13)?

A second error is that the traditional view forgets that the NT uses OT categories, terms, and models to convey what is exclusively New Covenant teaching. That both the Old Covenant Law and the New Covenant law function as a whole that is broken by failing to keep even one of the commandments, does not mean that it is the same law that is being referred to. The NT everywhere utilizes the OT and its entire content. Just as in Hebrews the OT cultic system pointed toward the greater and true cultic reality in Christ, so the OT Law was created as a mere ‘model’ of the heavenly reality. James and the NT writers give to us the true version of law, the perfect law and the perfect man who loves God and one’s neighbor, which was attested to in the OT Scriptures, that is, the Law and the Prophets (Matt.5:17; 7:12; 22:40; Luke 24:44; John 1:45; Acts 13:15; 24:14; 28:23; Rom.3:21; cf., Matt.11:13; Luke 16:16). Is this not the ‘man’ that Jesus was, as attested to by the OT?

V11. This verse is seen as a clincher for the traditional position because it does quote the Decalogue twice, and is said to clearly imply that the Mosaic Law is continued in the form of New Covenant law.

Yet again, this reading makes the mistake of interpreting James as stressing the mere commandment, and fails to recognize that these OT commandments are cited as New Covenant expectations of perfection and doing. James is not at all interested in preserving the Decalogue or the Mosaic commandments, which brought only death and were external. These two commandments (not to commit adultery, not to murder) were formerly part of the Ten Words, but they have been absorbed into the New Covenant law, and their Old Covenant, Mosaic Law, Decalogue setting has been cast aside. James is, therefore, teaching that the New Covenant law has prohibitions, such as found in the Old Testament. Merely ‘hearing’ them, and talking about them, is not the point. Rather, one must obey their content. This is why, as said before, James refers “to the Scripture” (v8), and not to these commandments as taken from the Mosaic “Law” as such.

So the reader understands, the whole of the OT, including what was formerly called the Mosaic Law and its Decalogue, are utilized merely as Scripture that was fulfilled in Jesus Christ, and which, in following that Christological exemplar of perfect love, express the new, heavenly Covenant and its law for God’s New Covenant assembly of first-fruits.

Vv12-13. This New Covenant law is ferocious, too. It judges as the law of liberty, for failure to be the perfect man of liberty, set free from death and sin, is an egregious transgression of this living law. For the Christian to be merciless is not a ‘sin’ by the standards of the Old Covenant law, which was external and could not produce mercy in the believer, but by the model of the perfect man of mercy of the New Covenant, who, as such a man, is the New Covenant norm for an heir of the heavenly kingdom.

James 4:11-12

11 Do not speak against one another, brethren. He who speaks against a brother or judges his brother, speaks against the law and judges the law; but if you judge the law, you are not a doer of the law but a judge of it. 12 There is only one Lawgiver and Judge, the One who is able to save and to destroy; but who are you who judge your neighbor?

By this point, the reader is in full possession of James’ understanding of ‘law’. Here it is directly implied that God is the lawgiver, and it is also implied he is the judge through the same law. He saves and destroys through this law, as we saw before. It is a law of salvation, for it is the power of perfection and doing that is 100% efficacious and successful as the divine life and will at work in us (see Phil.2:13). But woe to those who are mere hearers, who ‘talk the talk. but don’t walk the walk’. To attack a brother, to hate on another who bears the New Covenant likeness of an heir of the kingdom (3:9; 1:23-24; 2:5), is to attack God himself, the judge and lawgiver.

[1] This use of ‘law’ is added by the translators to the text.

[2] Angus Harley, “The New Covenant Gentiles of Romans 2:14-15,” All Things New Covenant, May 13, 2023, https://allthingsnewcovenant.com/2023/05/13/the-new-covenant-gentiles-of-romans-214-15/.