AC 31.2025

Date: August 7, 2025

Memorandum to Federal Records Management Contacts: Reminder About Resubmitting an NA-1005 Form

This is a reminder to those agencies that have an approved NA-1005 form, Verification for the Use of GRS 6.1, Email and other Electronic Messages Managed Under a Capstone Approach:

Pursuant to NARA Bulletin 2022-02, NARA requires all agencies who are using GRS 6.1 to resubmit their NA-1005 form(s) every 4 years. This next resubmission cycle will be in early 2027.  

The bulletin also outlines scenarios for when an agency should submit an updated form outside the regular cycle. Specifically, a “major agency reorganization” is one scenario requiring an agency to submit a new form. 

If your agency has completed a major reorganization, submission of a new form is appropriate. Agencies currently undergoing reorganization should wait until reorganization is complete before submitting a new form. A properly updated form will assist with implementation and reduce the possibility of unauthorized disposals.  

As an additional reminder, agencies using GRS 6.1 have the responsibility to track position changes as part of Capstone implementation. More information on this may be found in the FAQs for GRS 6.1, question 3.  

If you have any questions about whether or not it’s appropriate for your agency to submit a new NA-1005 form before the next government-wide resubmission cycle in 2027, please reach out to the NARA GRS Team at GRS_Team@nara.gov.

William Fischer   
Chief Records Officer 
for the U.S. Government (Acting)