FOIA Terms of Art: Not Reasonably Described and Unduly/Overly Burdensome

The Office of Government Information Services (OGIS) offers dispute resolution services to Freedom of Information Act (FOIA) requesters and agencies. This function allows OGIS to observe and examine the interactions between requesters and agencies across the federal government, and note common questions and issues that arise in the FOIA process. The FOIA Ombuds Observer addresses questions and issues frequently seen in our individual cases. Our goal is to increase efficiency and transparency in the FOIA process.

FOIA Terms of Art: Not Reasonably Described and Unduly/Overly Burdensome 

March 17, 2026
No. 2026-02

The Office of Government Information Services (OGIS) has observed that even the most seasoned Freedom of Information Act (FOIA) requesters can conflate various terms of art used in the administration of the FOIA, which can lead to confusion. This is one of four Ombuds Observers that explains FOIA terms of art that OGIS observes are often conflated. Knowing the definition of these terms can help everyone better understand and navigate the FOIA process. 

Unduly/Overly Burdensome versus Not Reasonably Described

Two common phrases used in the FOIA administrative process are “not reasonably described” and “overly/unduly burdensome.” Agencies often use one or the other when trying to work with requesters to clarify or narrow the scope of a request. They may sound similar, but they mean different things.    

Not Reasonably Described

FOIA requires that requests be “reasonably described,” and courts have ruled that to meet that requirement, requests must be written in such a way as to sufficiently describe the records sought. “Not reasonably described” requests are FOIA requests that do not provide enough detail for the agency to search for and identify responsive records.  

Examples include:

• Asking for documents about an issue without specifying a particular time frame, location of records, type of document, or relation to a specific project, program, or policy; 
• Requesting “all emails” without specifying the sender, recipient, or time frame; and 
• For a given request, not specifying a time frame, with the implication that all records from the creation of the agency are sought.

The key factor in determining if a request is sufficiently described is the ability of the agency’s staff to reasonably ascertain which records are being requested and then locate them.

Unduly/Overly Burdensome

A FOIA request is “overly/unduly burdensome” when it is so broad and complex that it would require an unreasonable amount of time and effort to search for and review records. For example, a request for "all documents related to a certain topic from the time the agency was created" would be overly/unduly burdensome because it would require a significant amount of resources to search for and review all responsive records.

Courts have found that FOIA was not intended to turn FOIA processors into full-time investigators on behalf of requesters; to allow requesters to conduct “fishing expeditions” through agency files; or to require FOIA processors to seek needles in haystacks.

The guiding principle is that an agency employee familiar with the subject area should be able to locate the records with a reasonable amount of effort.

Next Steps

If a request is “unduly/overly burdensome” or “not reasonably described,” the agency may ask the requester to narrow the scope or otherwise clarify the request. Agency FOIA Public Liaisons, who are tasked by the FOIA statute with assisting in resolving disputes with requesters, are in the best position to work with requesters to see how the scope of a request may be narrowed. 

At an impasse? Contact OGIS. We’re here to help.