Federal Records Management

A Management Guide

ATTENTION! This product is no longer current. For the most recent NARA guidance please see Guide to the Inventory, Scheduling, and Disposition of Federal Records.


National Archives and Records Administration
Management Guide Series


Determining Record Status
"Adequate and Proper Documentation"
Responsibilities of Program Managers
Responsibilities of Records Managers
Problem Areas in Implementing Recordkeeping Requirements
For Further Information and Assistance
     Appendix A. Recordkeeping Requirements Checklist
     Appendix B. Using Office Automation Applications:
     Records Management Guidelines
     Appendix C. For Further Information


The National Archives and Records Administration (NARA) Management Guide Series provides Federal agencies with guidance on the management of records and other types of documentary materials accumulated by Federal agencies and officials.

The guides are intended to assist senior agency officials, program managers, records officers, and information resource managers in creating and maintaining accurate and complete records of an agency's functions and activities and in ensuring the authorized, timely, and appropriate disposition of documentary materials that are no longer needed to conduct business. Particular attention is given to policies and procedures governing records of enduring value that are intended for transfer to the National Archives.


In conducting business, every Federal agency creates a great number of records in a variety of media. The quality of those records varies from agency to agency and program to program. This guide will help agencies improve the quality of their documentation by describing how Federal personnel should create and properly manage documentation containing important information. If information is not captured in records that are accessible in organized files or electronic recordkeeping systems, it will not be available when later needed. Poor documentation may result in an unresponsive Government or a Government that cannot account for its actions, or both.

Too often information resides only in the memory of Federal personnel. Even in the short term, the absence of documentation may affect the efficiency of agency operations, because personnel may need information that is not available in the files. Also, conducting Government business without adequate documentation increases the possibility that, in time, all relevant facts may be unavailable or interpretations may be distorted. As staff members leave, information that has not been documented will be lost to the agency.

Frequently, agencies become aware of inadequate documentation because of congressional inquiries, Freedom of Information Act requests, litigation, or through the news media. This problem can have serious ramifications.

The General Accounting Office (GAO) has found that failure to create or maintain complete and accurate records has caused the expenditure of millions of dollars for goods or services never received.
Destruction of drafts and working files has left agencies unable to justify controversial decisions because they no longer have documentation of proposals and evaluations of alternatives.

The term "recordkeeping requirements" as used by NARA applies to statements in statutes, regulations, or agency directives or other issuances specifying which records are to be created or received and maintained by agency personnel. For example, a procedures manual is likely to mention particular forms, reports, and correspondence that make up a case file.

The term electronic information system" means an automated system that contains and provides access to Federal records and other information. An "electronic recordkeeping system" is a specific type of electronic information system in which records are collected, organized, and categorized to facilitate their preservation, retrieval, use and disposition.

This guide is intended to assist agencies, and particularly their program managers, in establishing recordkeeping requirements. It supplements NARA regulations (36 CFR Chapter XII, Subchapter B) by providing further explanation of terms used in the statutes and regulations and by providing guidance on the application of these terms to the documentary materials that agencies accumulate in their daily operations. Without recordkeeping requirements, agencies cannot ensure that they are creating and maintaining accurate and complete documentation. Proper records are essential to a responsive and responsible Government. Establishing recordkeeping requirements also contributes to the legacy of Government service left by Federal officials and enhances the quality of those records that will be preserved by the National Archives for future research.

With the increase in office automation and the proliferation of "personal" computers (stand-alone or networked computers at individual work stations), individual staff members have increased control over the creation of some Federal records. This makes the need for recordkeeping requirements even more critical. Consequently, agencies must provide specific instructions to staff members on their responsibilities for ensuring that the Federal records they create on each computer application in their respective offices are properly identified and preserved in agency recordkeeping systems. Appendix A provides a checklist for compliance with basic recordkeeping requirements. Appendix B provides additional guidance for creation and preservation of records with personal computers. Appendix Cprovides points of contact for further information.


The term "records" used in this guide means records as defined in 44 U.S.C. 3301. As defined in the law, documentary materials are Federal records when they are made or received by a Federal agency in connection with the transaction of Government business, and they are maintained or should be maintained by the agency to document how it was organized, what functions it performed, how it carried out those functions, how it related to other agencies and to the public, or because the materials contain information of value to the agency. "Documentary materials" is a collective term for Federal records, nonrecord materials, and personal papers that refers to all media containing recorded information, whatever the method(s) or circumstance(s) of recording. Federal records may be created on any physical media including, paper, film (microfilm, photographic film, x-ray), disk (optical, magnetic, video, audio), and tape (magnetic, video, audio). The method of recording information may be manual, mechanical, photographic, electronic, or any combination of these or other technologies.

In developing recordkeeping requirements, Federal agencies should determine which documentary materials need to be identified as records and preserved to ensure complete and accurate documentation. Agencies preserve records by filing, storing, or otherwise systematically maintaining them. Absent formal recordkeeping requirements, records that should be preserved because they contain evidence of agency activities or information of value to the agency may not be systematically maintained.

Agencies need to apply the definition of Federal records to distinguish between records and nonrecord materials. One of the problem areas in distinguishing records from nonrecord materials is determining the status of drafts and other working papers. This issue is discussed in the section entitled "Problem Areas in Implementing Recordkeeping Requirements." Applying the definition of records to most documentary materials created or received by agencies presents few problems when agencies have established and distributed recordkeeping requirements for records in all media throughout the agency.


The creation and maintenance of complete and accurate records are basic aspects of records management. Based in statute, the practice of ensuring "adequate and proper documentation" contributes to efficient and economical agency operations by guaranteeing that information is documented in official files, including electronic recordkeeping systems, where it will be accessible to all authorized staff who may need it. In addition to paper textual files and electronic recordkeeping systems, official files may be comprised of or contain audiovisual, cartographic, or architectural materials. The availability of complete and accurate documentation allows Federal agencies to:

protect the legal and financial rights of the Government and of individuals directly affected by Government activities; preserve institutional memory so that informed decisions are possible and thus facilitate action by agency officials and their successors in office; and
be held accountable through the proper scrutiny by the Congress and oversight agencies such as GAO, the Office of Management and Budget (OMB), NARA, and the General Services Administration, as well as agency auditors and inspectors general.

Agencies should foster a climate that encourages good recordkeeping by employees. To manage their records, agencies should establish formal files with documented classification schemes or electronic recordkeeping systems with full records management functionality. Formal files and electronic recordkeeping systems should be designed to maintain all records relating to a specific transaction, project, study, or subject to preserve the context of the records.

Additional measures to ensure creation and maintenance of accurate and complete documentation are needed for records created or received through office automation applications. Use of electronic communications tools and personal computers has changed the procedures for creating many types of records in Government offices. These procedures have removed support staff from the traditional recordkeeping process. Widespread use of facsimile machines, electronic mail systems, and word-processing, database, and spreadsheet programs enables officials and staff to create and transmit documents directly. Before the proliferation of personal computers, written communication was more formal, and clerical staff routinely made and filed copies of outgoing records. Direct creation of records by executive, professional, and technical staff increases the likelihood that file copies will not be prepared. Automation has, therefore, made it even more important for program officials to ensure that they and the staff members under their direction create adequate documentation. Consistent and proper implementation of recordkeeping requirements will ensure the accuracy and integrity of documentation created and transmitted electronically within the agency, among agencies, and between agencies and the public.

Agency files and electronic recordkeeping systems must be available to all authorized staff members. Consequently, Federal records in electronic form should not be maintained solely on a staff member's computer hard disk, diskettes, or directories assigned only for an individual's use. This would be the electronic equivalent of maintaining agency paper records in an individual s locked desk drawer. Nor should agencies establish a recordkeeping system, either hard copy or electronic, for the maintenance of electronic mail messages, word processing documents, spreadsheets, data base reports, or other computer-generated records, unless these files can be linked, such as through automated indexing. See Appendix B for further guidance on creation and preservation of records with personal computers. NARA has found that documentation practices are often weakest in the following areas:

policy and decision making, particularly oral decisions and commitments;
board, committee, and important staff meetings;
drafts and working papers or files;
electronic information systems; and
contractor records.

Each of these is discussed further in the section entitled "Problem Areas in Implementing Recordkeeping Requirements." Also see Appendix A,

Recordkeeping Requirements Checklist.

Program managers have primary responsibility for ensuring that complete and accurate records are created. Records managers assist program offices in developing standards, criteria, and procedures for adequate documentation. Once the records have been created and placed in official files, records management procedures for maintenance, access, and disposition can be applied. One of the basic documentation challenges for agencies is to commit all needed information to paper or electronic media in a way that ensures that it becomes part of the agency's files.

Agencies conducting business electronically, either internally or with other agencies, will have to ensure that the functional requirements for their systems incorporate records management concerns. Agencies should also ensure that data can continue to be accessed as systems evolve (i.e., that as changes are made to systems and equipment, older data remains accessible until the expiration of the scheduled retention period).


Program managers best understand the functions and operations of their office. They also have the authority needed to direct staff members to follow good documentation procedures. In addition, they are accountable for compliance with OMB Circular A-123, which requires managers to affirm the integrity of their files, both paper and electronic. They control and administer money and other resources and need accurate and complete records to support and document their actions.

Program managers must ensure that needed information is recorded and maintained in official files. To do so, they should issue procedures and guidelines for the creation and maintenance of records necessary to fully explain how decisions were reached and how business was conducted. Most offices are involved in projects or transactional processes that result in case files. In addition, offices commonly have correspondence or subject files for letters, memorandums, reports, and issuances. Generally, procedures manuals, which describe how projects or transactions are conducted, describe specific documents such as forms, reports, memorandums, or analyses that are part of the case file. Correspondence or subject files are normally the responsibility of a secretary or other support staff member who usually creates the outgoing correspondence, including file copies. For these traditional ways of creating records, the program manager should ensure that procedures manuals and file plans are accurate, thorough, and up-to-date and that manuals include clear instructions for submitting needed documents to official files.

Agency programs may also be supported by electronic recordkeeping systems, which may replace or supplement paper files. Program managers should ensure that requirements for records creation and recordkeeping are included in the design and implementation of electronic systems supporting their programs. Policy, procedures, and controls built into the system should ensure that only authorized users can create records and that no records are altered or deleted except as authorized. The systems should be accessible to all authorized staff members to enable them to do their jobs efficiently, and they should be designed to distinguish records from other information or to allow users to identify records. Agencies should develop and maintain clear and thorough documentation for electronic recordkeeping systems to support retrieval and use of the records for their entire life cycle from creation to final disposition (destruction or transfer to the legal custody of the National Archives).

As described above, electronic mail and other office automation tools have given program managers and their staffs tools that give them greater control over the creation and maintenance of records than when they depended on clerical staff. Agencies have indicated that electronic mail messages often replace more formal communications that would have been routinely captured in agency files. Documentation created with office automation applications may contain unique information needed by or useful to other agency personnel. Unless these documents are included in recordkeeping systems, they will not be available. Consequently, ensuring that Federal records created on personal computers, including substantive electronic mail messages and appropriate draft documents, are transferred to a recordkeeping system is essential.

When electronic mail is used to conduct Government business, agencies must develop and implement procedures for the management of those electronic mail messages that are Federal records. All agency staff must be able to identify those electronic mail messages that are Federal records and must be aware of the recordkeeping requirements that apply to electronic mail. (See 36 CFR Chapter 12, especially Parts 1222 and 1234.) Records created by contractors, which may supplement records created by agency personnel, also contribute to the adequacy and accuracy of agency documentation. Program managers should ensure that contracts for goods and services include specific requirements regarding records that must be made available or submitted to the Government. Often, exclusive rights to the data should be reserved for the Government.


Records managers are responsible for incorporating policies and procedures for the creation of adequate records into the records management program. The records management directive(s) should include guidelines for establishing recordkeeping requirements to ensure the creation of complete and accurate records. In addition, records management officials should be involved in developing or modifying systems, processes, and procedures to ensure that adequate recordkeeping requirements are established and carried out. Records managers should offer training for all agency personnel on policies, responsibilities, and techniques for developing and implementing recordkeeping requirements. Particular attention should be given to the training of program managers and first-line supervisors.

Guidance issued by records managers should include the following:

criteria for identifying specific categories of documentary materials to be created by agency personnel while carrying out their official duties;
directions for using materials and recording techniques that will ensure the preservation of the records as long as they are needed by the Government;
guidance for the maintenance of these records, regardless of physical form;
guidance for distinguishing records from nonrecord materials, including personal papers; and
agency policy on the removal of nonrecord and personal materials.

Agency records managers may use the following techniques to develop guidance on recordkeeping requirements:

review statutes, regulations (including those of oversight and other agencies), Executive Orders, agency policy documents, directives, organizational and procedural manuals, and other authoritative issuances to become knowledgeable about mandated functions, programs, and activities;
review instructions for classifying, indexing, and filing records; records inventories; and records schedules for description of records in their organizational and functional context; and
review documentation for electronic information systems to determine the record content and format.

Records management audits of program offices should include a review of guidance on recordkeeping. The review would involve examination of file plans, filing systems, records inventories, the hard copy records in official files, and records in electronic information systems and system outputs to determine if needed documentation is being created and maintained and if there are any apparent gaps in the documentation.

In conducting this review, the three overall objectives of accurate and complete documentation listed at the end of the first paragraph of the section entitled "Adequate and Proper Documentation" can serve as guidelines or tests. The determination of whether records are complete and accurate requires thorough knowledge of the office's responsibilities, functions, specific programs, and activities. Therefore, program officials should review records managers' analyses.


In addressing recordkeeping requirements, there are several problem areas that require particular attention. Agency program officials and records managers should determine when the following materials are needed for adequate and proper (i.e., complete and accurate) documentation. Major problem areas include the following:

Documentation of policy and decision making accomplished orally or electronically.
In most agencies, policies, decisions, and commitments are frequently made in meetings, over the telephone, or by electronic mail or facsimile transmission. To ensure that such policies and decisions are adequately documented, agencies should establish procedures that require personnel at all levels to document conversations and meetings dealing with significant program business by preparing a dated and signed memorandum or form identifying the participants and summarizing the conversation or meeting. All personnel should ensure that records of policy and decision making made or received through electronic mail and facsimile are retained in appropriate recordkeeping systems.
Documentation of formal meetings.
Meetings of formal bodies such as boards, commissions, advisory groups, committees, and task forces, as well as high-level staff meetings at which agency business is transacted or discussed, should be properly documented. At a minimum, documentation in a meeting file should include the names and organizational titles of participants, an agenda, a list of materials distributed to participants, a summary of discussion of significant policy or procedural matters, decisions reached and actions decided upon, actions to be taken following adjournment, and assignments of responsibility. If the meeting is taped and a transcription subsequently made and filed, all speakers should be identified on the transcript.

Drafts and working files.

Although records of Federal agencies usually contain high-level policies and decisions, policy formulation and execution may be poorly documented. Support documents such as drafts and working files for reports, special studies, memorandums, and correspondence that support major program policy development may not be incorporated into office files. These support documents may be needed to fully understand the alternatives and options considered for high-level program initiatives, and the basis for deciding on a course of action. Some drafts contain unique information in substantive annotations or comments added during circulation for comment or approval. Agencies should maintain such drafts, with the file copy of the final document, if any, when the drafts relate to formulation and execution of high-level policies, decisions, actions, or responsibilities.

In addition to drafts, working files and background materials may be needed to adequately document agency activities. Agencies should evaluate the documentation practices of senior officials and staff, engineers, scientists, and other professionals and specialists, particularly those who manage unique agency programs and major contracts, and provide guidance for ensuring adequate documentation. Special attention should be given to notebooks, notes, calculations, and other background materials that may contain information needed to supplement formal records. Drafts and working papers or files that propose and evaluate options or alternatives and their implications in the development of high-level policies and decisions or that document findings or support recommendations should be preserved.

Background materials or drafts that are records according to agency recordkeeping guidelines should be maintained in agency recordkeeping systems. Senior officials or their staff members should not keep such Federal records as personal papers. (See "personal pa- pers/files" below.) Drafts and working papers or files that relate to routine program or administrative operations or that contain only corrections or editorial or stylistic changes may be disposed of as nonrecord materials.

Electronic information systems.

Documentary materials in electronic form include records, nonrecord materials, and personal files. Electronic information systems present special problems because of the diversity of the materials in the system, the fragility of the media, the potential for technical obsolescence, and the decentralized control over the materials in office automation applications. Agencies must ensure that electronically- generated records are identified and that the systems used to store the records comply with recordkeeping requirements. Electronic recordkeeping systems must be designed to ensure the security and integrity of records, preservation of records for the time they are needed, and migration of data to other agency systems or subsequent systems. If record messages that are made or received through electronic mail do not show the complete names of senders, addressees, and the date of transmission, users should also take reasonable steps to preserve the mail envelope information sheet, distribution list, or other screen that contains any of that information that is not on the message itself. In addition, receipts should be maintained if needed for recordkeeping purposes. (See Appendix B.) Contractor records.

The term "contractor records" is frequently applied to paper, audiovisual, and electronic records and data created or received from or maintained by contractors for Federal agencies. Contractors performing agency functions create records essential for effective management and for accurate and complete documentation of these functions. Unless contract provisions explicitly define the documentation to be provided to the agency, contractors are likely to treat needed documentation as private property. Agencies should ensure that contract provisions require the submission of program and administrative documentation needed by the agency, including back- ground data and technical documentation. Contracts should also specify which records need to be kept by the contractor for audit or other administrative purposes, and the length of time they are to be maintained.

Personal papers or files.

Personal papers or files are documentary materials accumulated by an official or staff member that are not used in the transaction of agency business but that may be maintained in a Government office. Personal papers/files may refer to or comment on the subject matter of agency business, provided they are not actually used to conduct business. If maintained in a Government office, personal papers should be clearly designated as such and filed or otherwise maintained separately from the records of an office.

Although not actually personal papers, other documentary materials are sometimes part of personal collections. These include extra copies of records created and retained only for convenience of reference, such as copies of records an individual has drafted, reviewed, or otherwise acted upon and other nonrecord materials that may be removed but only with the agency's approval. Agencies are required to develop and explaining that departing officials may not remove any Federal records from agency custody while removing their personal papers and designated nonrecord materials.

When documentary materials that have been identified and separately maintained as personal papers, along with extra copies of records and other designated nonrecord materials, are removed by departing officials, agencies should consider maintaining a record of the removal and a certification that no Federal records have been removed.


  1. Has the agency provided guidance for all employees on the definition of Federal records and nonrecord materials, including those created by office automation tools (word processing, electronic mail, spreadsheet, and data base applications), and the ways in which they must be managed?
  2. Does each office or program have written guidance on what records, including electronic records, are to be created and maintained and the format of each record copy?
  3. Has the agency issued guidance and instructions for documenting policies and decisions, especially those decisions reached orally and for those communicated electronically?
  4. Has the agency issued guidance on the record status of working papers or files and drafts?
  5. Has the agency issued guidance on personal papers?
  6. Has the agency implemented controls over the removal of documentary materials?
  7. Do contracts identify which contractor-created records are Federal records?
  8. Do contracts specify the delivery of all records that may, in addition to the final product, have future value to the agency? Are contractor required to deliver background data and technical documentation along with electronic records?


This guidance should be used to develop agency directives or other formal issuances that are disseminated to all employees with access to office automation programs. Agencies should provide sufficient guidance and assistance to employees to make them aware of their individual responsibilities and comfortable in carrying them out. In addition, agencies should review the decisions made by employees in carrying out these responsibilities.

All employees with access to office automation (computers) should receive guidance, with concrete examples tailored to the various functions and programs of the agency on the following:

how to distinguish Federal records from nonrecord materials and personal documentary materials; how to determine when drafts and working papers are Federal records; how to know when receipts or acknowledgments for e-mail messages are needed for recordkeeping purposes; how and when to generate a recordkeeping copy of e-mail messages, receipts or acknowledgments, spreadsheets, word processing documents, and data base reports; how to mark or classify documents for filing or incorporation into an electronic system with recordkeeping capabilities, when appropriate; and
how to contact the records officer and records liaison for assistance. (See 44 USC 3301, 36 CFR 1222, Disposition of Federal Records and Personal Papers of Executive Branch Officials. )

In managing official files in either paper or electronic format, agencies should take appropriate steps to ensure the integrity and security of their records. For electronic information systems agencies should establish fixed procedures for generating backup copies of their systems or the data (records) contained in the system and for recycling the backup tapes or disks.

Electronic Mail

When an agency determines that its needs would best be served with maintenance of these records in a paper recordkeeping system, the e-mail user should take the following steps:

Identify record status at the time of transmission or receipt.
Print those messages that are Federal records, and any attachments.
If all addressees do not appear on the message, print the header, mail envelope information sheet, status sheet, distribution list, or other screen that shows the full name(s) of addressee(s) and attach this information to message.
Print documentation containing information about the receipt of the message when required for recordkeeping purposes, and attach it to the message. (If the sender requested a receipt for recordkeeping purposes in accordance with agency criteria, he or she will retain the printed message and transmission document until receipt is received.)
Mark the document as the official file copy, write the file classification on it, and place it in the file box or other designated place for such items to be filed.

When an agency determines that its needs would best be served with maintenance of these records in an electronic recordkeeping system, the e-mail user should use the following procedures:

Identify the record status as specified by agency instructions. Associate the receipt with the message and transmission document if the sender requested a receipt for recordkeeping purposes in accordance with agency criteria. Transmit an electronic copy of the message and related document(s) showing full name(s) of addressee(s) if not on the message, and the receipt (when applicable) to the appropriate directory in the electronic recordkeeping system.

Word Processing

When an agency determines that its needs would best be served with maintenance of these records in a paper recordkeeping system, the creator of a word processing document should complete these tasks:

Identify the record status of drafts and other background materials, and print those that are records.
Generate or ensure that the support staff generates appropriate file copies of final documents.
Ensure that the final documents and official file copies show the date, approval of the signer, and file classification.
Ensure that any necessary drafts and related materials are attached to the official file copy.
Ensure that the file copies of the final document (if the end-user produces one) are placed in a file box or other designated place for such items to be filed.

When an agency determines that its needs would best be served with maintenance of these records in an electronic recordkeeping system, the creator of a word processing document should follow these procedures:

Identify the record status of drafts and other background materials, and save all versions that are records.
Electronically associate drafts and other background materials that are records with the final document, if there is one.
Ensure that the directory in the electronic recordkeeping system where the document will be maintained is noted on all records.
Transmit an electronic copy of all records to the appropriate directory in the electronic recordkeeping system once the document is finalized or when no further action on the document will be taken.


When an agency determines that its needs would best be served with maintenance of paper files, the creator of a spreadsheet should first identify the record status of the spreadsheet. Then, for spreadsheets that are Federal records, he or she should determine whether the formulas for the individual cells need to be documented. When documentation is required, the spreadsheet creator should perform one of the following tasks:

If the spreadsheet program can include this information on a printed copy, print the spreadsheet with the formulas.
If the spreadsheet program cannot print the formulas, print the spreadsheet and annotate the printout.
(When documentation of the formulas is not required, the creator should simply print the spreadsheet.)
If it is associated with another record, e.g., if it is an enclosure to a memorandum or letter, an appendix or exhibit to a report, or background material needed for complete documentation, attach a copy to the related record.
If it is not associated with another record, mark the document as the official file copy, write the file classification on it, and place it in a file box or other designated place for such items to be filed.

When an agency maintains electronic recordkeeping systems, the creator of a spreadsheet should first identify record status and then take one of the following steps:

If it is associated with another record, ensure that an electronic copy is part of the related record.
If it is not associated with another record, transmit an electronic copy to the appropriate directory in an electronic recordkeeping system.

Data Base Reports

When an agency determines that its needs would best be served with maintenance of paper files, the creator of a data base report should first determine whether the report is a Federal record or a nonrecord working or background document, and print those that are Federal records.

If it is associated with another record, e.g., if it is an enclosure to a memorandum or letter, an appendix, or exhibit to a report, or background material needed for complete documentation, attach a copy to the related record.

If it is not associated with another record, mark the document as the official file copy, write the file classification on it, and place it in a file box or other designated place for such items to be filed


When an agency maintains electronic recordkeeping systems, the creator of a data base report should first identify record status, then take one of the following steps: If it is associated with another record, e.g., if it is an enclosure to a memorandum or letter, an appendix or exhibit to a report, or background material needed for complete documentation, ensure that an electronic copy is part of the related record. If it is not associated with another record, transmit an electronic copy to the appropriate directory in an electronic recordkeeping system.


In addition to the policy guidance and advice available from your agency's records officer, information resource management officials, legal counsel, and inspector general, the National Archives Office of Records Administration can provide assistance in answering questions about records and recordkeeping requirements. Consult the Records Management Main Page or send an e-mail to
Agencies may also contact one of the Federal records service facilities