M-23-07

EXECUTIVE OFFICE OF THE PRESIDENT

OFFICE OF MANAGEMENT AND BUDGET

WASHINGTON, D.C. 20503

THE DIRECTOR THE ARCHIVIST

December 23, 2022

M-23-07

MEMORANDUM FOR THE HEADS OF EXECUTIVE DEPARTMENTS AND AGENCIES

FROM: Shalanda D. Young

Director

Office of Management and Budget

Debra Steidel Wall

Acting Archivist of the United States

National Archives and Records Administration

SUBJECT: Update to Transition to Electronic Records

Strong records management is necessary for transparency and accountability and

underpins our democracy. Transitioning Federal agencies

to an electronic — or “paperless” —

environment is a priority to enable and increase the ability of the public to engage with

Government in new and more efficient and effective ways. It is critical that Federal agencies

move beyond paper-based processes and embrace the opportunities afforded to improve

Government by transitioning fully to an electronic environment.

Memorandum M-19-21, Transition to Electronic Records, issued jointly by the Office of

Management and Budget (OMB) and the National Archives and Records Administration

(NARA), established several requirements to move Federal agencies to a fully electronic

environment, where appropriate. Agencies may have been delayed in their electronic records

transition process during the COVID-19 pandemic. This memorandum reinforces the

requirements established in M-19-21, reaffirms the underlying goal of the transition to electronic

records, and updates the previous target dates described in M-19-21. This memorandum also

describes NARA’s plans to issue updated guidance, as appropriate.

1.1 By June 30, 2024, Federal agencies must manage all permanent records in an

electronic format.

No later than June 30, 2024, all permanent records in Federal agencies must be managed

electronically to the fullest extent possible for eventual transfer and accessioning by NARA. As

This memorandum applies to “Federal agencies” as defined by 44 U.S.C. § 2901(14).

with the previous policy, permanent records accessioned into NARA or transferred for storage

into Federal Records Centers before June 30, 2024, are not required to be managed electronically.

1.2 After June 30, 2024, Federal agencies must transfer all permanent records in an

electronic format and with appropriate metadata.

After June 30, 2024, all agencies must transfer permanent records to NARA in electronic

formats and with appropriate metadata in accordance with NARA regulations and transfer

guidance. Agencies may request a limited exception to this requirement from NARA in

circumstances where replacing specific analog records with electronic systems would be

burdensome to the public, the cost would exceed the benefit, statutory or regulatory barriers

impede implementation, or there is exceptional intrinsic value in the original format.

1.3 By June 30, 2024, Federal agencies must manage all temporary records in an

electronic format or store them in commercial records storage facilities.

By June 30, 2024, all temporary records in Federal agencies must be managed

electronically to the fullest extent possible. Agencies may continue to produce and store certain

records in analog formats if they receive a limited exception from NARA for one of the reasons

established in paragraph 1.2, but all other inactive records eligible for transfer after June 30,

2024, must be stored in commercial storage facilities. This does not apply to temporary records

that are transferred for temporary storage into Federal Records Centers before June 30, 2024.

By June 30, 2024, all agencies must close agency-operated records storage facilities and

transfer inactive, temporary records to Federal Records Centers or commercial records storage

facilities. Temporary analog records that become eligible for transfer after June 30, 2024 must

be transferred to commercial storage facilities that meet NARA records storage requirements.

1.4 After June 30, 2024, NARA will no longer accept transfers of permanent or

temporary records in analog formats and will accept records only in an electronic

format with appropriate metadata.

After June 30, 2024, NARA will no longer accept new transfers of permanent or temporary

analog records unless NARA has provided a limited exception, as described in paragraphs 1.2

and 1.3. NARA will continue to store and service all analog records transferred to a Federal

Records Center by June 30, 2024 until their scheduled disposition date. Once those records

reach their disposition date, NARA will accept the permanent records into the National Archives

in their original analog format and will appropriately dispose of the temporary records. All

other legal transfers of permanent records must be in an electronic format, regardless of whether

the records were originally created in electronic formats. Starting on July 1, 2024, agencies will

be required to digitize permanent records created in analog formats before transfer to NARA.

Digitization and transfer must be made in accordance with NARA regulations and transfer

guidance, including metadata requirements.

1.5 NARA will issue records management regulations and guidance to support

Federal agencies' transition to fully electronic recordkeeping.

No later than June 30, 2024, NARA will issue updated regulations and guidance to

provide clear standards for fully electronic recordkeeping. NARA will also issue regulations

and clear policies that permit agencies to digitize permanent records created in analog formats

and, where appropriate, dispose of analog originals. NARA will issue updated regulations

providing agencies with guidance on electronic records storage, formats, and metadata, as well

as transfer guidance. NARA will provide guidance to efficiently schedule, transfer, and

accession permanent, electronic records through fully electronic processes.

No later than June 30, 2023, NARA will issue updated guidance clearly defining and

expanding the Capstone approach to include all types of electronic messaging in addition to

email, including ephemeral and encrypted messages. The updated guidance will incorporate

new statutory requirements codified in the Electronic Message Preservation Act (EMPA).

No later than December 31, 2023, NARA will issue guidance on managing Federal

records residing in collaborative working environments. The guidance will address ownership

of content by multiple Federal agencies across multiple platforms and will support efforts

already underway by the Chief Information Officer Council and the General Services

Administration (GSA).

1.6 NARA will establish Electronic Records Management (ERM) standards and

requirements for Federal agencies procuring ERM solutions and services.

No later than December 31, 2023, NARA will finalize ERM standards and

requirements for ERM solutions and services under the Federal Electronic Records

Modernization Initiative (FERMI), NARA’s comprehensive Government-wide strategy for

procuring records management solutions and services. Agencies should use FERMI

resources to comply with records management policies and mandates from NARA and

OMB, including the requirements above.

44 U.S.C. § 2912.