Tick tock: NARA's electronic records management deadline is approaching

While agencies have largely passed previous deadlines, this could be the most difficult mandate to date.

electronic document (MaximP/Shutterstock.com)

We're past the midway point of 2019 and the next records management deadline is rapidly approaching.

Agencies have little time to ensure compliance with the mandates set by the National Archives and Records Administration (NARA) over six years ago. In order to reduce agencies' reliance on paper-based processes, NARA issued the Managing Government Records Directive (M-12-18), which specified that federal agencies have until December 31, 2019 to implement plans for managing all of their permanent electronic records in an electronic format. The clock is ticking.

While agencies have largely passed previous deadlines, this could be the most difficult mandate to date. This deadline, which applies to all permanent electronic records, is a considerable step forward from previous requirements. To be successful, agencies will have to undergo a digital transformation, one that will affect people, processes and technology, and one that should consider both electronic and physical records.

This will necessitate new approaches to traditional records storage and disposition methods and drive the need to adopt emerging technologies like AI and automation. To meet the digital transformation rallying cry, agencies are going to have to move quickly and decisively.

Building toward 2022

The deadlines laid out in the Managing Government Records Directive effectively function as the building blocks for NARA's FY 2018-2022 Strategic Plan. This plan aims to help agencies transition to fully electronic recordkeeping by default, and states that by 2022 NARA will no longer accept analog format records. This impending, wholly digital shift is foreshadowed in the Managing Government Records Directive's 2019 deadline, which recommends agencies don't stop with electronic records, but consider the benefits of digitizing hard-copy permanent records as well.

To ensure agencies are on the path to success in 2019, and by extension 2022, NARA's Success Criteria for Managing Permanent Electronic Records states, "To successfully manage permanent electronic records, agencies must address four key aspects of records management. They must have effective policies and systems, the ability to provide access to the records, and the ability to execute disposition." Let's take a look at each of these areas:


The first step for any agency looking to prepare for the 2019 deadline is to conduct a comprehensive records assessment that seeks to identify current records inventory and evaluate established records policies, programs and processes. This is instrumental to understanding which records are subject to which governance requirements. In this assessment, one of the key concerns for agencies should be their records schedules. Records schedules are living constructs, and change continuously, therefore a records schedule that has not been updated for several years is inefficient and could potentially lead to compliance violations. To combat this, agencies need to update their governance frameworks to ensure programs remain relevant while also warding off future complications.


More and more, agencies are implementing automation systems to manage workflows and storage processes. Automation capabilities can also be a crucial enabling factor for keeping identified records management policies up to date throughout their long lifecycles. The ability to manage records and information through the entire lifecycle – from creation, to use, to disposition – as well as incorporating proper storage capabilities will be essential for agency success.


Moving towards the future, one of the most important aspects of recordkeeping will be improving accessibility and searchability with metadata tagging and analytics. These capabilities have already been widely applied across the government, but they hold special value for records management. Analytics can help agencies to eliminate manual recovery inefficiencies; track and manage records in digital and physical formats; track inventory activity; monitor performance; and point to future needs. Improving searchability and access through implementation of analytics and proper use of metadata tagging decreases the average amount of time spent retrieving records, and therefore should be a key part of any agencies' arsenal. For any remaining physical records that aren't suitable for digital transfer to NARA, agencies should consider implementing analytics-based tracking solutions for agency records warehouses and off-site storage sites.


As agencies move towards 2022, they still assume the same responsibility for disposing of their end-of-lifecycle records. It is both costly and risky to hold on to records past their mandated lifecycle, which often happens when disposition dates cannot be definitively determined. As such, agencies need to be capable of identifying when records have exceeded their time-based or event-based need for retention. However, retention periods are even further complicated when considering the shift to fully electronic records transfer. Many existing applications will need to develop enhanced functionality to classify content according to the retention schedule, accommodate any required triggering events, and purge records in accordance with disposition eligibility dates. To ensure their retention periods are keeping pace with the generation of records, agencies should make sure they consistently engage in content reviews, refine event-based definitions, and define rules based on work process.

In many ways, 2019 will serve as an advance testing ground for NARA's digital strategy in 2022. As agencies look to meet the December deadline, they should be checking to ensure their roadmaps align with the four key areas that NARA has highlighted, while working hard to get ahead of the 2022 deadline.