This article explores how administrative agencies determine whether to apply new laws retrospectively. The prohibition of ex post facto laws is in high connection with the protection of reliance interest. Both are significant legal principles with constitutional status and therefore bind the administrative agencies, the courts, and the legislature alike. By “change of laws", the author indicates both the “formal" and “substantive" changes of laws. In addition to the enactment, amendment, or repeal of legislations or regulations through formal processes, it also includes the case that the administrative agency changes its previous interpretations of laws. In this vein, the traditional dichotomy between the “real retrospective application" and the “non-real retrospective application" remains making sense. To the contrary, the arguable theory distinguishing “retrospective applications of legal effect" from “retrospective applications of legal facts" is too formalistic. It ignores the specific facts in concrete cases, and thus has no practical benefit. This article advocates for defining the notion of “retrospective application of laws" in terms of substantive respects, i.e. to determine the means to protect the reliance interest in light of the practical implications led by the new laws. Also, in order to avoid misunderstanding that no reliance interest exists, certain kinds of descriptions such as “there is no retrospective application of laws" should be employed more prudently. In figuring whether a specific legislation or regulation could be applied retrospectively, the agency must take the following factors into account: (1)whether the new laws have negative impact on individuals; (2) the pattern of the cause of the reliance; (3) the specific performance because of the reliance; (4) whether the reliance is deserving of legal protection; (5) the legal status that the individual has already got; (6) the degree that the retrospective application makes impact on the party; (7)the public interest led by the retrospective application; and (8) whether there is a grace period for the new law to take into effect.