AC 34.2025
Date: September 25, 2025
Memorandum to Federal Records Management Contacts: Release of Checklist and Web Page to Support Agencies Undergoing Reorganizations or Other Major Changes
This communication is for federal agencies reorganizing, terminating, or transferring offices or functions to another agency. Through all of these changes, agencies continue to have records management responsibilities under the Federal Records Act (FRA).
The FRA, at 44 U.S.C. § 3101, charges agency heads with creating and preserving federal records that document the agency's activities so that the legal and financial rights of the government and individuals affected by the agency's activities are protected. This responsibility exists even if the functions of the agency have changed or moved (see 44 U.S.C. Chapter 31 and 36 CFR § 1231). Records management responsibilities include maintaining and preserving federal records until they meet their retention period. At that point, the records can be transferred to NARA or destroyed according to the NARA-approved records schedule.
As long as any part of an agency still exists, that entity is the legal custodian responsible for agency records. It is imperative that successor entities be identified for all discontinued functions to ensure records are not destroyed or alienated in violation of the FRA. The successor entities assume responsibility for records management and information requests and may apply existing records schedules unless the functions or nature of the records have changed [36 CFR 1226.14(b)]. Agencies must assign points of contact for ongoing records management and information requests. Please notify NARA about updates to agency contacts for records management
NARA has prepared a checklist and web page to help federal entities prepare for changes. Agency personnel should contact their agency records officer first. If you have questions, please send an email to rm.communications@nara.gov.
WILLIAM FISCHER
Chief Records Officer
for the U.S. Government (Acting)