Within the framework of administrative law theory, archival openness review is an internal administrative act, serving as a discretionary process prior to the final openness decision. Its regulation should be addressed from three aspects: basis, subject, and procedure. Current archival law norms primarily target traditional review methods and struggle to meet the demands of digital-intelligentization transformation. Regarding the basis: While the technology-encouraging provisions in Archives Law of the People's Republic of China can provide authorization for digital-intelligentization review, they are overly broad. It is essential to ensure "human-in-the-loop" to prevent abdication of discretion. Regarding the subject: AI technologies used in intelligent review are predominantly provided by private enterprises. Existing regulations lack clear delineation of authority and responsibility between these private entities and public authorities. Subsequent legislation should be arranged based on the state guarantee theory, while procurement contracts can help fill gaps in practice. Regarding procedure: Norms for ex-ante review and dynamic assessment should be added to prevent and control algorithmic risks. By requiring intelligent review systems to maintain audit trails and mandating users to provide explanations for both the algorithms and their outputs, subsequent supervision and review can be facilitated.