Richard Velkley, in Freedom and the End of Reason, p. 50, maintains that “the Remarks can be assigned its date of composition more securely than any other part of Kant's Nachlass.” Taking cues from the location of certain reflections, differences in ink quality, and textual content, Erich Adickes concluded that Kant must have written, in succession, on the interleaved sheets between January of 1764 and the fall of 1765. He claims that only thereafter, between the middle and end of 1765, did Kant write on the margins and printed pages the short observations associated with (but not corrections of) the text of the Observations. In the Akademie edition (1942), Lehmann followed Adickes in believing that the Remarks was most likely written between 1764 and 1765. Maria Rischmüller, in her introduction, p. xvii, offers the date of no later than the publication of Dreams of a Spirit-Seer (Träume eines Geistersehers) in 1766.

Clemens Schwaiger, in Kategorische und Andere Imperative: Zur Entwicklung von Kants praktischer Philosophie bis 1785 (Stuttgart: Frommann-Holzboog, 1999), pp. 66ff., argues that it is likely that the notes were written during different periods. He cautions against canonizing the view that all of the notes were written in a single, continuous period of time, since this view is doubted even by Adickes. In particular, Schwaiger correctly points out that the notes that are written in Latin contain a conceptually advanced position in Kant's ethics.