Evaluating the New Perspective on Paul (17) “Justification and a Final Judgment According to Works” (Part Three)

There are two passages in Paul’s epistles that are of special importance to the question of justification and a final judgment according to works. The first of these, 1 Corinthians 3:10-15, is especially pertinent to the question of the nature of the reward that will be granted to believers for their works. The second of these, Romans 2:13, is the one passage in Paul’s epistles that might appear to teach something like a future justification that will be based upon good works. Before drawing a conclusion on the subject of Paul’s teaching on justification and the final judgment, then, we need yet to examine these passages.

1 Corinthians 3:10–15

The context for this passage is the apostle Paul’s sharp rebuke to the Corinthians for their unspiritual treatment of those who are ministers and teachers of the gospel. The chapter begins with the apostle noting that he could not address them “as spiritual people, but as people of the flesh, as infants in Christ” (v. 1). The problem in Corinth was that there was an unseemly factionalism that expressed itself in terms of some saying, “I follow Paul” or “I follow Apollos.” This party spirit was rife among the Corinthians.

In his rebuke to them, Paul argues that it betrays a fundamentally wrong view of those who are servants of Christ. As he reminds them, ministers of Christ, though they may plant and water the seed of the Word of God, are utterly dependent upon God. In the strongest possible language, he reminds them that ministers are nothing by themselves: “So neither he who plants nor he who waters is anything, but only God who gives the growth” (v. 7).

After this reminder of the impropriety of a false boasting in those who are merely servants of Christ, the apostle raises the subject of the respective reward that they will receive for their work. Comparing the church to a building, he describes ministers as God’s workers, each of whom will receive his wages according to his labor (v. 8). Speaking of himself as a “skilled master builder,” Paul notes that his labor within God’s building was based upon the one foundation, the Lord Jesus Christ. If he or anyone carries out his ministry on behalf of the Lord with the proper materials— gold, silver, and precious stones— his work will endure the fiery purification that will occur on the “Day” when each one’s work will become manifest. The work of Christ’s ministers that properly builds upon the foundation of Christ will issue in the granting of a reward. However, those who build upon the foundation in an improper manner, using materials that are like wood, hay, or straw, will witness the fiery destruction of this work. Such inappropriate work will not receive a reward. Nevertheless, those whose work is unworthy of a reward will be saved, though only after having passed through the fiery judgment.

The significance of this passage for our consideration of the question of justification and a final judgment according to works is transparent. All servants of Christ are reminded to labor within God’s building in a way that builds upon the one great foundation, Jesus Christ. They are reminded that the quality of their labor depends upon the means that they utilize in their church-building efforts. Some means, which conform to the nature of the gospel they minister, are like precious, abiding materials that, even when tested by fire, will endure in the day of judgment. Other means, which are not conformed to the gospel, are like worthless and fleeting materials that, when tested by fire, will be utterly consumed.

This passage, accordingly, is a clear affirmation of Paul’s teaching that Christ’s servants will undergo a judgment or testing that will be according to their works. What is particularly striking about this judgment-testing, however, is that it will not issue in the irrevocable loss of salvation for those who belong to Christ. The respective rewards that will be granted to those who labor in God’s building do not include the reward of salvation or eternal life, which is a gift of God’s grace (cf. Romans 6:13), but that praise and honor that are consistent with the quality of the work performed. Though this passage does not expressly address the subject of justification, it is certainly consistent with the idea that the reward associated with a final judgment according to works ought not to be understood as the gift of salvation itself. As it stands, there is nothing in the passage that contradicts the historic reformational teaching that free justification secures the believer’s salvation and inheritance of eternal life, though it does not mitigate the reality of a future judgment according to works. Furthermore, despite the particular focus of this passage upon judgment according to works of the labor of those who are ministers of Christ, there this does not prevent an application of its teaching that extends to all believers.



What about Romans 2:13?

The most significant passage in Paul’s writings regarding the subject of justification and a final judgment according to works may be Romans 2:13: “For it is not the hearers of the law who are righteous before God, but the doers of the law who will be justified.” On one reading of this passage, the apostle Paul could be understood to affirm a positive connection between good works and a future, final justification or vindication that is presumably associated with the final judgment. When it comes to the ultimate justification of believers in a future judgment, it is only those who do what the law requires who will be justified. Without further qualification, this could be interpreted to mean that the final phase of the believer’s justification, which will occur in connection with a final judgment according to works, will be one in which works, and not faith alone, will be the basis for acquittal. Upon this reading, we might conclude that the apostle Paul taught that the believer’s initial justification, which is by means of faith and apart from works, needs to be completed by a future justification, which is by means of the works of faith. If this is indeed the teaching of this verse, it seems to contradict Paul’s teaching elsewhere that the believer’s justification is by faith and not by the works of the law (cf. Rom. 3:28).

In the history of reflection upon this verse in the context of Paul’s argument in the early chapters of Romans, there have been a number of distinct interpretations. We will only consider the three most prominent views, especially as they relate to the question whether Paul taught a doctrine of a future justification by works.

The first reading of this text, which was common among representatives of the Reformation view of justification in the sixteenth century, argues that the apostle Paul is refuting the empty boast of those who seek to be justified by obedience to the law. In the context of Paul’s argument in the early chapters of Romans, he is not stating that there are those who do what the law requires and thereby obtain justification. Rather, he is stating a principle that is enunciated in the law of God, namely, that those who abide by its precepts will thereby possess a righteousness that would commend them to God (cf. Lev. 18:5). However, since it is not possible that anyone do what the law requires, the principle stated in this verse is hypothetical: if someone were to do what the law requires, then he would be righteous before God. But there are no such persons who do what the law requires and therefore no one can be justified by doing the law (cf. Romans 3:10). Calvin summarizes this view in his commentary on the book of Romans:

The sense of this verse, therefore, is that if righteousness is sought by the law, the law must be fulfilled, for the righteousness of the law consists in the perfection of works. … We do not deny that absolute righteousness is prescribed in the law, but since all men are convicted of offence, we assert the necessity of seeking for another righteousness. Indeed, we can prove from this passage that no one is justified by works. If only those who fulfill the law are justified by the law, it follows that no one is justified, for no once can be found who can boast of having fulfilled the law.

Among the arguments for this understanding of Romans 2:13, two stand out as of special importance. The first is an argument from the immediate context. In the verses of Romans 2 that precede verse 13, the apostle Paul is anxious to show that all people, Jews and Gentiles alike, are subject to God’s righteous judgment. All will be judged by God who shows no partiality (v. 11). Whether someone sins “without the law” as a Gentile or “with the law” as a Jew, no one who sins will escape the wrath and condemnation of God. To suggest that those who have the law are at a distinct advantage in distinction from those who do not have the law, is mistaken. For it is not enough to have or to be a “hearer” of the law; only those who do what the law requires will be justified. In this immediate setting of the argument of Romans, the apostle seems to be saying to his opponents who are boasting in their possession of the law, that this will be of no benefit to them since they are not doing what the law requires. Paul adduces the principle (“only doers of the law will be justified”) for the express purpose of refuting the empty boast of those who seek to be justified by their obedience to the law.

The second argument appeals to the broader context of chapters two through four of Romans. Since the burden of Paul’s argument in these chapters is to establish that “all have sinned and fall short of God’s glory” (Romans 3:23), and that justification is a free gift of God’s grace in Christ (Romans 3:24-26), it seems unlikely that the point of Romans 2:13 is to affirm a positive role for works in relation to justification. Throughout these opening chapters of Romans, Paul is making a case against any kind of self-justification, which would appeal to works or works of the law as the basis for the believer’s acceptance with God. Works of any kind are utterly excluded as a proper basis for justification (Romans 2:19-20), both because there are no persons who are righteous by the standard of the law and because God has now revealed a righteousness “apart from the law” that is “through faith in Jesus Christ for all who believe” (Romans 2:21-22). Thus, within the immediate and broader context of Paul’s argument in Romans, it does not seem likely that Romans 2:13 represents a positive statement regarding the role of good works in relation to justification.

A second reading of this text takes it as a positive description of believers whose faith is confirmed by their works of obedience. Though this reading does not claim that Paul is speaking of a final justification that is by works, it does view this passage as a description of the kind of believers who will ultimately be justified. Only those whose conduct confirms the genuineness of their faith will be justified. Because those who are truly joined to Christ are justified and sanctified by grace, there is a legitimate sense in which the works of faith are necessary to justification. Though the works of the believer are at no time the basis for their justification, this does not mean that the believer will be justified without having obeyed the law and thereby confirming the genuineness of their profession. The inseparable connection between justification and sanctification makes it possible for the apostle to insist that only those who do what the law requires (who are being sanctified) will enjoy the benefit of God’s justifying verdict. The good works of justifying faith, though not, strictly speaking, the basis for the justification of believers or their acquittal in the final judgment, are nonetheless necessary evidences of the genuineness of that faith. Though believers are not justified on account of their doing the law, they will not be justified without doing what the law requires, however imperfect their obedience may be.

Thomas Schreiner is an able exponent of this second reading of Romans 2:13. In his treatment of this text, several arguments are adduced to show that Paul is enunciating a positive principle, namely, that only those who do what the law requires by the Spirit will be justified. First, there is evidence in the context that Paul speaks positively about the actual obedience of Gentile believers, who are “doers of the law” in contrast to those Jews who “hear” the law but do not do what it requires. Of particular significance to Schreiner is the description offered at the close of Romans 2 regarding the obedience of such Gentile Christians. In verses 26-27, Paul contrasts the conduct of uncircumcised Gentiles who “keep the precepts of the law” with that of circumcised Jews who have the “written code … but break the law.” Since Paul appeals to the actual (and not merely hypothetical) obedience of such Gentile Christians in the context of his sustained argument for the righteousness of God’s judgment upon Jew and Gentile alike, the assertion that “doers of the law will be justified” likely refers to the vindication of believers who obey the law. Second, in the verses preceding Romans 2:13, Paul has described the judgment of God as an event in which God “will render to each one according to his works” (v. 6). This judgment will have a twofold outcome: some who “by patience in well-doing seek for glory and honor and immortality” will receive “eternal life,” others who “are self-seeking and do not obey the truth” will receive only “wrath and fury” (vv. 7-8). The distinct outcome of God’s judgment for believers on the one hand and unbelievers on the other, suggests that Paul believed that only believers who do good will receive eternal life in the context of God’s righteous judgment. And third, Schreiner appeals to the frequent emphasis in Paul’s writings upon a final judgment that is according to works. This emphasis is fully compatible with a view of Romans 2:13 that takes it as a positive affirmation of God’s approval/ vindication at the final judgment of the those who do good.

Though he defends the view that Paul is stating a positive principle in Romans 2:13, Schreiner insists that Paul is not thereby contradicting his clear teaching that believers are justified by faith (alone) apart from works. In the opening chapters of Romans, Paul emphatically rejects the idea that anyone, whether Jew or Gentile, can obtain justification on the basis of the works of the law (cf. Rom. 3:20, 28). We should not take his language that “only the doers of the law will be justified,” therefore, as a description of the basis or ground for the believer’s justification. Like those who take the first view of this text, Schreiner rejects the idea that Paul is teaching a future justification that is based upon works and that completes a present or initial justification. Rather, Paul is reminding his readers that true faith produces good works by the Spirit of Christ, and that these works are a significant confirmation of the genuineness of faith. Indeed, such works, though imperfect, are a necessary part of the salvation of believers so that no one will be justified without them. Summarizing this view, Schreiner notes that we should understand the good works that do lead to an eschatological reward in different terms. They are the result of the Spirit’s work in one’s life, as the connection forged between verses 26–27 and 28–29 demonstrates. The Spirit’s work on the heart logically precedes the observance of the law by the Gentiles. Autonomous works are rejected, but works that are the fruit of the Spirit’s work are necessary to be saved. Paul is not speaking of perfect obedience, but of obedience that clarifies that one has been transformed.…The good works done are not an achieving of salvation, then, but the outflow of the Spirit’s work in a person’s life.

The third reading of this text claims that the apostle Paul is affirming that the final, eschatological justification of believers will be based upon their works. This understanding is the view of some contemporary theologians, including proponents of the new perspective on Paul. In this interpretation of Romans 2:13, Paul is understood to teach that justification has a present and future phase. Though believers enjoy an initial justification by faith apart from works, there is a yet future justification that will be upon the basis of those works that belong to true faith. On this reading of the text, the apostle Paul is not speaking hypothetically but of actual believers whose works not only prove the genuineness of their faith but also constitute the ground for their final vindication or justification. Justification, according to this view, has both an initial and a final stage.

There is no uniform understanding of this view among its proponents. Some suggest that Paul is engaging in a polemic against the boast of some Jews that they, unlike the Gentiles, were given the Mosaic law. To refute this boast, Paul reminds his readers that it is not enough to hear the law, since only those who do what the law requires will be justified. E. P. Sanders, for example, maintains that Paul affirms in this verse that the Gentiles who do the law will be justified upon that basis, an affirmation that contradicts Paul’s teaching elsewhere that no one can be justified by the works of the law. As we noted earlier, N. T. Wright also appeals to this text to support his claim that Paul taught a doctrine of final or eschatological justification that is based upon the believer’s works.

This view had proponents at the time of the Reformation, and has been suggested by interpreters of Romans at various times since. At the end of the nineteenth century, F. Godet, in his commentary on the book of Romans, maintained that Paul speaks in this verse of a yet future justification that will be based upon works. Godet cited Paul’s use of the future tense in Romans 2:13, when he says that only doers of the law “will be justified.”

Since the justification of which Paul speaks is a future event, it does not likely refer to a hypothetical circumstance, namely, that anyone who does what the law requires will be justified though no such person exists. Godet also appealed to the language at the close of Romans 2, which speaks of Gentiles who “keep the law” (v. 27). This language indicates that Paul is speaking, not hypothetically, but of concrete instances of obedience to the law. Since Paul speaks in this verse of a future justification, and since he appeals in the subsequent context to the concrete obedience of Gentiles to the law, Godet concluded that we should distinguish between an “initial” justification and a “final” justification.

It will certainly, therefore, be required of us that we be righteous in the day of judgment, if God is to recognize and declare us to be such; imputed righteousness is the beginning of the work of salvation, the means of entrance into the state of grace. But this initial justification, by restoring communion between God and man, should guide the latter to the actual possession of righteousness— that is to say, to the fulfillment of the law; otherwise, this first justification would not stand in the judgment …. And hence it is in keeping with Paul’s views, whatever may be said by an antinomian and unsound tendency, to distinguish two justifications, the one initial, founded exclusively on faith, the other final, founded on faith and its fruits.

This brief overview of the three most important readings of Romans 2:13 illustrates the difficulty of determining precisely what Paul means when he says “only doers of the law will be justified.” While recognizing the difficulty of interpreting this verse in its context, I am persuaded that the first view remains the most likely reading of the text. There are several reasons that, on balance, support this understanding.

First, though the apostle Paul uses the future tense in this verse, it goes beyond the interest of Romans 2:13 to connect directly its language with Paul’s teaching in other places about a final judgment according to works, as though these good works are a basis for a final justification. We have noted that the subject of a final judgment according to works is a common one in Paul’s writings. However, neither in Romans 2:13 or in any text that speaks explicitly of a final judgment does Paul speak of it as another justification, which is to be distinguished from a presumably initial justification that occurs by faith apart from works. To be sure, the final judgment, like justification, is a judicial act that occurs within a legal setting. But Paul never explicitly speaks of the final judgment as an act that completes or fulfills an earlier justification. If he did so in Romans 2:13, this text would be a noteworthy exception to his usual pattern. Second, the argument from the immediate and broader context of Roman seems to support the view that Paul is speaking hypothetically. The one point that Paul wishes to make by the statement, “only the doers of the law will be justified,” is a negative one, namely, that those who boast of their possession of the law make an idle boast since they do not do what the law requires. Paul states a principle in order to reject those who claim to be justified by their works. However, this claim is belied by their failure to do what the law demands. As John Murray remarks in his comments on this verse,

It is quite unnecessary to find in this verse any doctrine of justification by works in conflict with the teaching of this epistle in later chapters. Whether any will be actually justified by works either in this life or at the final judgment is beside the apostle’s interest and design at this juncture. The burden of this verse is that not the hearers of mere possessors of the law will be justified before God but that in terms of the law the criterion is doing, not hearing.

The function of Paul’s appeal in this text to the principle that “only doers of the law will be justified” parallels his appeal elsewhere to the fact that justification by obedience to the law is precluded by the failure of anyone to do all that it requires (cf. Rom. 3:19–20; 10:5; Gal. 3:10; 5:1). Moreover, if the point that Paul makes in this verse were that those who do what the law requires will be justified on that basis, the inconsistency of his overall argument in Romans 2–5 would be rather striking. The burden of Paul’s case in the opening chapters of Romans is that the law, so far as justification before God is concerned, serves only to expose and aggravate the reality of human sin and guilt (Rom. 3:19–20, 28; Rom. 4:4). To maintain that Romans 2:13 states a positive connection between doing the law and justification seems inconsistent with this emphasis.

Third, the argument of Schreiner and others that Paul is enunciating a positive principle in this verse depends heavily upon the claim that Romans 2:27–29 describes Gentile Christians who “keep the law” by the working of the Spirit of Christ.

Though this is a possible interpretation of these verses, it does not seem finally to fit well with the argument of this section of Romans. Even if Paul alludes to the conduct of Christians in verse 29, when he speaks of those whose circumcision is a matter of the heart “by the Spirit,” his main point in these verses reiterates what he earlier argued in verses 14–15. Paul’s concern in these verses and throughout Romans 2, is to argue that the mere possession of the law of God (the Mosaic law) does not suffice to save anyone. Only those who do what this law requires can find salvation by means of the law. Verses 27–28 repeat a theme that was developed already at an earlier point in verses 14–15 of Romans 2, namely, the contrast between the empty boast of those Jews who possess the law but do not do what it requires, and the keeping of the law by Gentiles, who do not possess the law but (sometimes) do what it requires.

This contrast, especially if it is a contrast between Jews and Gentile Christians, might suggest that Paul believes that the latter would be saved on the basis of their keeping the precepts of the law. However, the whole thread of Paul’s argument in Romans 2 is tied together in Romans 3, where he insists that that no one, whether Jew or Gentile, can be saved upon the basis of their own works (verses 9–10). It seems unlikely, therefore, that Paul means to speak of the keeping of the law by Gentile Christians to confirm the point that “only doers of the law will be justified.” This would not seem consistent with the great theme of this section of Romans that all Jews and Gentiles are shut off from finding acceptance with God and salvation by means of the works of the law.

And fourth, Paul’s doctrine of justification amounts to the claim that believers have a final, eschatological participation in Christ’s death and resurrection, so far as this secures their acceptance and favor with God. Justification, in Paul’s teaching, is a thoroughly eschato-logical blessing. It represents the present, definitive declaration of God’s favorable verdict concerning those who are joined to Christ by faith. This verdict anticipates and secures the believer’s acceptance with God (Rom. 5:1; 8:1). If Romans 2:13 taught a future, eschatological justification, which is based upon the works of faith and not upon the work of Christ alone, the believer’s present justification would no longer secure a future reception of eternal life. Rather, the prospect of yet future justification (or condemnation) upon the basis of works would undermine the believer’s present persuasion of God’s favor, a persuasion that derives from the gift of free justification.

These considerations favor the first reading of Romans 2:13, though not in such a way as to rule out completely the second view. Because the second view does not claim that Paul is speaking in this verse of another, yet future justification, which is based upon works and not faith alone, it is does not imperil Paul’s teaching regarding justification as a free gift in Christ. Though I am not finally persuaded that it does justice to the place of this verse in the context of Paul’s teaching in the opening chapters of Romans, this second view rightly emphasizes the necessity of obedience as a confirmation and evidence of the genuineness of that faith that receives the grace of justification. This second view, though at variance with the common reading of Romans 2:13 in the reformational tradition, does not conflict with what we have represented as its consensus on the subject of justification and a final judgment according to works. What this second view suggests is that, because justification and sanctification are inseparable benefits of the believer’s union with Christ, no one will be justified who does not live by the Spirit.


In our review of Paul’s teaching regarding justification and a final judgment according to works, we have found nothing that conflicts with the historic view of the Reformed confessions. Paul clearly teaches that all believers, who are united with Christ by faith and indwelt of his sanctifying Spirit, are being renewed after the image of Christ. Salvation through fellowship with Christ involves not only the grace of free justification but also of sanctification or renewal in righteousness. Paul’s insistence upon the transformation of the life of the believer in union with Christ forms the background to his insistence that believers will be judged according to their works.

The critical question, as we have seen, is whether this final judgment amounts to a final or second justification on the basis of works. Does Paul teach that believers are initially justified and granted a status of acceptance upon the basis of Christ’s work alone, but that they are finally justified in the context of the final judgment upon the basis of their works? Our review of Paul’s teaching in his epistles argues against the claim that the final judgment amounts to a kind of further justification. The whole burden of Paul’s teaching regarding justification is that it is a definitive declaration of the believer’s acceptance with God. Justification is in the strictest sense of the term an “eschatological” blessing, a promise of final and sure acceptance with God. Those who are “in Christ” are no longer under condemnation, nor are they liable to any charge that could be brought against them. To regard the final judgment, accordingly, as a final chapter in the believer’s justification is tantamount to pulling the rug out from underneath the feet of those whose confidence before God rests upon the righteousness of Christ alone.

This does not mean that justified believers will not be judged, even acquitted publicly, in the context of the final judgment. However, that judgment will be “according to works,” not “on the basis of” works. Those good works that believers necessarily and inevitably perform, and that are produced by the working of Christ’s Spirit in them, will confirm and demonstrate the genuineness of their faith. Indeed, so inseparable are justification and sanctification that no one will be justified without good works, even though their justification is not on account of such works. Within the context of the final judgment, believers will be openly vindicated before others by their works, works that evidence the presence and working of the Spirit of Christ in them. These works, however, are not, and never will be, any part of the basis for the justification of believers before God. To suggest that the works of believers contribute to their justification not only fails to recognize that they are inadequate to the task, but that this would be tantamount to denying the sufficiency of Christ’s righteousness. These themes, which are found in Paul’s epistles, are themes that are nicely summarized in the historic confessions of the Reformed churches.

Dr. Cornelis P. Venema is the President of Mid-America Reformed Seminary. He is also a contributing editor to The Outlook.