NARA reports that 40 percent of federal agencies have not completed the transition to electronic records management required by OMB/NARA M-23-07, jeopardizing historical preservation and FOIA response capabilities.
The National Archives and Records Administration reported that 40 percent of federal agencies have not completed the transition to electronic records management required by OMB/NARA Memorandum M-23-07, which mandated the elimination of paper-based records management by December 31, 2025.
Non-compliant agencies include 12 cabinet-level departments and 28 independent agencies spanning a wide range of missions and sizes. NARA attributes failures to inadequate funding, insufficient trained personnel, and the complexity of migrating historical paper records to digital formats.
The compliance failure has operational consequences: agencies with incomplete electronic records transitions report FOIA response times 2.4 times longer than compliant agencies. Several agencies face legal sanctions in ongoing litigation related to their inability to produce records in required timeframes.
NARA has established a Records Management Compliance Assistance program providing non-compliant agencies with technical assistance, digitization guidance, and access to federally negotiated digitization contracts.
GovAcademy's Records Management and Digital Archives course (GA-030) covers NARA-compliant records management practices, M-23-07 transition requirements, and Federal Records Act obligations. The course is particularly relevant for Records Officers at non-compliant agencies developing remediation plans.
The course addresses digitization standards (FADGI, ISO 19264) for paper records, disposition scheduling in the Comprehensive Records Schedule, and metadata requirements that ensure digital records remain legally admissible.
NARA has indicated it will begin formal non-compliance actions against agencies that have not submitted acceptable remediation plans by June 2026, creating urgency for training and modernization investments.