Request for Comments from February 2026 Draft Recommendation
Hello! I am responding to the request for comment on a February 2026 draft recommendation from the committee:
https://www.archives.gov/files/ogis/documents/foia-log-affirmative-disclosure-recommendation-feb.-2026.pdf
Suggested revision:
Congress should amend FOIA mandate regular publication of agency FOIA logs as open data online.
Every agency subject to FOIA should be proactively disclosing FOIA logs at least once every year, on Sunshine Week, but it's become abundantly clear over the past 60 years that the American people cannot depend on disclosure being discretionary or standardized.
Congress should amend FOIA’s affirmative disclosure provisions to:
1) require the Office of Information Policy to create a standardized schema for FOIA logs, just as the Treasury Department was required to create a schema for the federal spending data in the DATA Act of 2014.
2) mandate the ongoing publication of agency FOIA logs on *at least* a quarterly basis, unless the agency receives fewer than 100 requests per year, in which case it could publish them semi-annually. Agencies should aim for a monthly and then weekly cadence. The eventual goal should be for FOIA logs for ALL agencies to be automatically posted daily by modernized systems.
These logs should contain the following meta data:
1) the tracking number of the request,
2) the date of the request,
3) the name of the requester, unless the requester is a first-person
requester seeking access to their own information,
4) the organizational affiliation of the requester, if identified in the
request,
5) the subject matter of the request,
6) the status of the request,
7) the date the request was perfected,
8) the result of the request (if closed),
9) all exemptions cited, if any,
10) the date on which the request was resolved,
11) the fee category assigned to the request,
12) whether a fee waiver was requested,
13) if a fee waiver was requested, whether it was granted,
14) fees charged to the requester, if any, and
15) whether the request was also processed under the Privacy Act.
The Committee should recommend to Congress that all FOIA logs should be published as open government data, as defined under the OPEN Government Data Act (Title II of the Foundations for Evidence-Based Policymaking Act of 2018, Public Law 115-435), “which requires federal agencies to publish their information online as open data, using standardized, machine-readable data formats, with their metadata included in the Data.gov catalog.” https://data.gov/open-gov/
In the interim, the Committee should recommend that the Office of Information Policy issue guidance in an interagency memorandum to all agencies that FOIA logs should no longer be posted as PDFs.
The OIP at DoJ should collect and make open data of these logs accessible on foia.gov and an open data set that is discoverable on Data.gov, where foia.gov/wizard.html can put them to work informing the American people.
Explanation: FOIA logs have proven useful to government policymakers, reporters, and academics alike.
Sometimes the use is one that promotes FOIA efficiency:
-searching the logs can help a requester make a more precise request or request
-records already produced that would be readily available to the FOIA office.
In other instances, the logs have promoted improvements to FOIA administration. The logs are maintained by the agency as part of their responsibilities to track requests and meet statutory deadlines, as well as to report aggregate processing statistics to Congress and the DOJ each year. While most agencies post some form of the logs already, there is no standardization, disclosure is uneven and in PDFs, and some do not.
On the basis of the prior research supporting these conclusions, it seems entirely feasible for agencies to publish logs on an ongoing basis in a standardized form.
This recommendation was made by prior terms of the federal FOIA Advisory Committee and the details of the recommendation are drawn directly from that work.
See Final Report and Recommendations, 2016-2018 FOIA Advisory Committee; Federal Advisory Committee Recommendation, 2022-10.