What is the biblical basis against baptismal regeneration?

Your comments reflect a major misconception that evangelicals and the Reformed have of orthodox Christians. Lutherans do not believe that baptism is necessary (mandatory) for salvation. Not even the Roman Catholic Church believes this. All the saints of the Old Testament, the thief on the cross, and thousand of martyrs down through the centuries have been saved without Baptism. Baptism is not the "how" of salvation!

Lutherans believe that baptism is one of several possible "when"s of salvation, it is not the "how" of salvation. The "how" of salvation is and always has been the power of God's Word/God's declaration of righteousness.

A sinner can be saved by the power of God's Word when he hears the Word preached in a church, preached on TV or radio, reading a Gideon's Bible in a hotel room, or reading a Gospel tract that contains the Word. Salvation is by God's grace alone, through the power of his Word alone, received in faith alone. In each of these situations, the sinner is saved the instant he or she believes. Baptism is NOT mandatory for salvation to occur.

However, the Bible in multiple passages, also states that God uses his Word to save at the time of Baptism.

It is the work of the Holy Spirit, using the Word of God, that works salvation in the sinner's spiritually dead soul, according to the second chapters of Ephesians and Colossians, and the third chapter of Romans. Your "decision for Christ" does not save you, neither does your decision to be baptized.

God saves those whom he has elected, at the time and place of his choosing. Sometimes God saves them while hearing a sermon in church, sometimes at home reading the Word, and sometimes by the power of his Word spoken during Baptism.

God does 100% of the saving. The sinner is a passive participant in his salvation. There is no passage in the New Testament that asks sinners to make a decision for Christ. The Bible states that God quickens sinners, gives them faith, and they believe and repent.

The sinner does not decide to be saved. God decides to save the sinner!

Gary Luther, Baptists, and Evangelicals

There are a number of compelling arguments against baptismal regeneration, such as

• The lack of a Biblical basis for baptismal regeneration (relies solely on verses with natural, alternate interpretations)
• The absence of the mention of baptism in passages on how to become saved
• The contradiction with passages against works-based salvation

These are dealt with nicely in this answer and in Waggers' answer to this question.

One additional argument against baptismal regeneration (copied from my answer here) is an examination of Acts 10:44-48 NASB (emphasis added):

While Peter was still speaking these words, the Holy Spirit fell upon all those who were listening to the message. All the circumcised believers who came with Peter were amazed, because the gift of the Holy Spirit had been poured out on the Gentiles also. For they were hearing them speaking with tongues and exalting God. Then Peter answered, “Surely no one can refuse the water for these to be baptized who have received the Holy Spirit just as we did, can he?” And he ordered them to be baptized in the name of Jesus Christ. Then they asked him to stay on for a few days.

Notice from the passage that

(1) The listeners had not been baptized.

(2) The Holy Spirit fell upon the listeners as Peter was still speaking. Not during baptism.

(3) The circumsized believers were amazed that the Holy Spirit had been poured out on the Gentiles also. Some proponents of baptism-for-salvation claim that the Holy Spirit came upon the Gentiles in a special manner, not indicative of true salvation. This seems unlikely, considering the presence of spiritual gifts (speaking in tongues), and the use of the word "also".

(4) The circumcised believers were amazed that the Gentiles were able to be saved, because they were Gentiles (it is more clear, if you read the context around this passage, that this is the source of their amazement). However, if baptism was the means of salvation, wouldn't the circumcised believers have been equally amazed that the Gentiles were saved without baptism? Yet there is no mention of this incident being an anomaly with respect to baptism (it is an anomaly only because they were Gentiles).

(5) Peter seems to consider receiving the Holy Spirit a prerequisite for baptism. If Peter had believed that water baptism was the means of salvation, why would he see a need for their baptism? It seems to me that he would think: "Wow, what an interesting exception - these people were saved without even being baptized. Well, no sense baptizing them now. They are the saved, after all!" But instead, he instructed them to be baptized. This indicates that Peter saw baptism as a command for believers, and not as a means of salvation.

Baptism is not a part of our salvation, but it is an important command that, as believers, we should follow. It symbolizes the inward change that has already taken place in our lives: our death to ourselves, and resurrection in Christ. (Romans 6:3-4 NASB)