Seems like they become de facto law at that point.

Not at all. A "law" is where the government tells you or I what to do in its capacity as the government. These directives are where the government leadership tells its own organs and employees what to do in their capacity as leaders of a large organization.

Right, I know how the legalistic mind works. My point is about where "its own organs and employees" meets the citizenry. Leadership means these things permeate the org chart, and you can't segregate this stuff into a closed box of "their capacity as leaders."