Scheduling Records

Record Scheduling Basics

What is a records schedule?

By law, all federal records must be covered by a NARA-approved records schedule. Agencies must not destroy records until they are approved for destruction on an approved records schedule. (44 USC 3314).

An approved records schedule is a legal authority. It identifies and allows for disposal of a federal agency's records. A records schedule describes:

• The informational content and formats of records 
• The context or function of the records
• Whether and when an agency may destroy its records; or 
• Whether and when the agency must transfer the records to the National Archives for permanent preservation.

Records schedules apply to existing records. They usually apply to records created on an ongoing basis. Sometimes they only apply to a time-bound set of records.

There are two types of records schedules:

• Agency records schedules that apply to records of a specific agency or agencies. The schedule identifies which agencies it applies to.
• NARA-issued General Records Schedules (GRS) that provide disposition authority for records that are common across the federal government.

Why must agencies schedule records?

The Federal Records Act requires agencies to submit records schedules to NARA for review. NARA determines whether those records have enough value to warrant preservation or if they may be destroyed. (See 44 USC 3303 and 3303a.) In addition, the regulations also state that all federal records, including those created or maintained for the government by a contractor, must be covered by a NARA-approved agency disposition authority or a GRS. (See 36 CFR 1225.10.)

There are also benefits to scheduling your agency’s records. Scheduled records:

• Show what records an agency has and needs to manage.
• Help agencies respond to requests for records under the Freedom of Information Act (FOIA).
• Help agencies respond to discovery orders from the courts. 
• Identify high-value, permanent records so agencies can transfer them to the National Archives.
• Save taxpayer money by authorizing the destruction of records that aren’t needed.
• Help agencies streamline their business processes.
• Minimize the risk that records with privacy or other protected information are accidentally released. 
• Prevent premature or delayed destruction of records.
• Help agencies stay in compliance with federal records and information technology requirements.

Where are approved records schedules available?

Approved agency records schedules are available on NARA’s Records Control Schedules web page. See the Records Controls Schedules (RCS) Frequently Asked Questions for more information about the RCS. Agencies reschedule records over time, so older items or schedules may be superseded. We are marking superseded schedules as an ongoing process. Schedules are marked inactive when all items on the schedule are superseded or when NARA verifies that  all items on a schedule have been transferred to NARA or destroyed. 

What happens if there isn’t a records schedule, or the schedule isn’t followed?

Records cannot be legally destroyed without an approved records schedule. 

Agencies must treat unscheduled records as permanent until they are scheduled. 

It is unlawful to destroy or remove federal records from federal custody without a records schedule. Such destruction or removal is called an “unauthorized disposal.” You can learn more about this topic on NARA’s Unauthorized Disposition web page.

When should agencies submit a records schedule for NARA approval?

Agencies must submit new records schedules when:

• An agency has new records that are not covered by an existing schedule or the GRS.
• An interagency reorganization reassigns functions to an existing department or agency. In this case, the gaining organization must submit a new records schedule to NARA within one year of the reorganization. 
• A new department or agency assumes functions from an existing one. The new agency must schedule records documenting the acquired functions that are not covered by the GRS within two years.
• An agency needs to deviate from retention periods in the GRS.
• An agency needs to change retention periods for records previously appraised as temporary by NARA.
• An agency needs to change the approved disposition of records from permanent to temporary or vice versa.
• The informational content or the function documented by the records changes, so the agency must change the description of the records.
• An agency decides to change the scope of a non-Big Bucket records schedule item to include a greater or lesser aggregation of records.
• An agency decides to move one or more series between two aggregate items. 
• Records are now in a digital format and the analog records are described t on a schedule that specifically excludes electronic records.
• Program records are maintained solely on an agency web site.

See also 36 CFR 1225.22(b).

Records Schedule Requirements

Records Schedule Requirements

NARA may return a schedule to an agency for revision if it does not meet standards in 36 CFR 1225 and other formal NARA guidance.

Schedules must include:

• Clear descriptions of the records at the series or system level
• Clear and applicable cut-off and disposition instructions
• Citations to superseded schedule items, if applicable
• Adequate justifications for series that deviate from the GRS
• For permanent records, the inclusive dates, the total volume, and the annual accumulation 
• Whether General Accounting Office (GAO) concurrence is not required, has been obtained, or has been requested

See also: Records Schedule Quality Control Checklist
 

How to Schedule Records

36 CFR 1225.12 explains the basic process for developing a records schedule. Agencies should follow these steps to complete a successful records schedule:

1. Conduct a functional or business process analysis. See Knowing Your Records - Know What Your Agency Does.
2. Conduct an inventory. You need to know the records you are scheduling to successfully schedule them. See Knowing Your Records for more information about inventorying your records.
3. Determine the appropriate scope of the records schedule items. The scope of a schedule describes where the schedule applies, such as a single office or agency-wide. It also includes the level of aggregation of series into items within the schedule. For more guidance and the available options, see How to Schedule Records - Scoping Records Schedule Items.
4. Analyze disposition and retention needs. Propose final disposition of records and how long your agency needs to keep records before disposal or transfer. See How to Schedule Records - Analyzing Disposition and Retention Needs.
5. Create the records schedule. Collect all the necessary information you will need and draft your schedule items. See How to Schedule Records - Creating the Records Schedule.
6. Obtain clearances and approvals. See Obtaining Internal Clearances and External Approvals for more information on this part of the process.

Complete these steps before submitting a draft schedule to NARA.

Why does NARA ask for so much information on the records schedule?

Records schedules need to provide clear and concise record descriptions and implementable disposition instructions so that:

1. NARA can appraise the records. We have to understand what the records are and how the agency uses them to approve their disposition. We also have to make sure that agencies keep records reasonably long enough.
2. Your agency can use the schedule. Agency staff now and in the future need to be able to understand the schedule. They need to be able to recognize their records to know which disposition authorities to use.

Be prepared to support your NARA appraiser throughout the appraisal process in the following ways:

• Your agency may need to provide information to the appraiser about the records and their use.
• You may need to add additional information to the schedule or make revisions.
• Your agency may need to let your appraiser look at examples of records.
• Your appraiser may need to speak with records custodians and program offices.

Scoping Records Schedule Items

There are two factors to consider when deciding on the scope of your records schedule:

• The area of application for a schedule refers to where in the organization the schedule can be applied.  For example, the schedule applies to a single office or unit, a division or subdivision, the entire agency, or many agencies within the same department. Options include:
  • Agency-wide
  • Department-wide 
  • Agency Subdivision (individual office or division) - if using this option, you must identify the office or subdivision on the schedule
• The level of aggregation is the number of series covered by an individual item. Options include:
  • Individual Series (Granular) Item
  • Fixed/Closed Aggregate Item: an item that includes multiple series, but only those series specifically listed on the schedule or crosswalk
  • Flexible/Open Aggregate Item: also known as a Big Bucket or functional item; it covers multiple series, but can be applied to any future records that the agency has that fall under the item description

Not all of these options can be used together. See the Records Schedule Scoping Cheat Sheet for additional information.

Area of Application

NARA-approved disposition authorities apply only to the organization identified on the schedule. See 36 CFR 1225.22 for guidance on rescheduling records due to an agency reorganization. 
Unless the schedule specifies otherwise, disposition authorities apply retroactively to all existing records described in the schedule.

Office-based (Agency Subdivision)

• The schedule applies only to those records within the designated business unit. 
• The business unit can be described at any level of the organizational hierarchy (unit, division, program, etc.). 
• It is the most limited of the areas of application.
• Office-based schedules are often easier for agency staff to use. They only identify the records of a particular office and how to manage them.
• This type of schedule may require updates after an agency reorganizes to ensure that the schedule is still accurate. 

Agency-Wide

• "Agency" refers to either an independent agency, such as the Environmental Protection Agency, or to a component of a larger department, such as the Centers for Disease Control under the Department of Health and Human Services.
• The schedule applies to the same records wherever they exist in the agency. This includes electronic systems used across the agency. 
• The records covered by an agency-wide schedule must have the same content and uses, as well as the same retention and disposition periods. If this is not the case, then an agency-wide schedule is not appropriate.

Department-Wide

• Only Department-level Agency Records Offices can create these types of schedules.
• This schedule type applies to records in most or all components (agencies) of a larger Department. This includes electronic systems.
• The schedule must identify the component agencies it applies to. If any component should be excluded, do not include it in the records schedule field “Agencies to which this schedule applies.”
• Department-wide schedules always consist of aggregate items (see Level of Aggregation below). Even if the schedule covers a single record series, it is an aggregate item because records exist in more than one agency.
• Department-wide schedules need a crosswalk that identifies superseded authorities from each component agency. 
• Identifying the record series covered by this type of schedule requires considerable research and coordination across components of the Department. 
• All component agencies need to agree with the Department about the disposition and retention of records on the schedule.

Level of Aggregation

The level of aggregation refers to the number of record series covered by an individual disposition item. Items either cover a single series of records or many, related record series. A schedule can have items with different levels of aggregation.

The options for level of aggregation are:

• Individual Series/System (Granular) Item
• Flexible/Open Aggregate Item (also known as a Big Bucket or functional item)
• Fixed/Closed Aggregate Item

See below for more specific descriptions of each item type and how to use them.

Individual Series/System (Granular) 

• This is a disposition authority for one record series or electronic system. 
• This type of item can either cover records on a recurring basis or cover records from a specific period of time.
• Use this type of item for:
• A single series of records in a specific office. 
• The primary content of a single, discreet electronic system within an agency.
• This type of item has the least ambiguity about what records it covers. 
• Individual series (granular) items may need more time to manage, track, and enter into recordkeeping systems.

Aggregate Items

• An aggregate item consists of many related series of records and/or electronic systems. See also 36 CFR Subpart B Part 1225.14(b)(1). In simple terms, an aggregate item groups together multiple records series related to the same work process, activity or function. 
• Record series may also be grouped by the positions or roles of persons at certain management levels. See Role-based Scheduling for further information on this option. 
• All series in an aggregated item must:
  • Have the same disposition. However, series should not be aggregated by a common disposition alone. 
  • Relate to the same work process, activity, or function.
• Aggregate records schedule items may be either fixed/closed or flexible/open. The flexible/open option is also known as a big bucket item or functional item. 
• Agencies must provide additional information to NARA when proposing aggregate records schedule items. NARA appraisers need to understand the scope of the item’s coverage to appraise the schedule.
• Aggregate items are useful in agencies that reorganize frequently. Items based on work process and functions are less likely to need revision every time the agency reorganizes, provided functions and processes don't change. 
• See the Guide to Aggregate Item Schedules for additional information.  

Role-Based Scheduling

What is role-based scheduling?

Role-based scheduling is where the position or role of an individual is a factor in determining the disposition of records.

The role-based approach assumes that a small number of officials at or near the top of an organization create or receive the majority of permanent (or historically valuable) records. A Capstone schedule is an example of a role-based schedule approach. While the Capstone approach is relatively new, role-based schedules for senior agency officials are common.

Best Practices for Role-Based Scheduling

Analyzing Disposition and Retention Needs

What does disposition mean?

"Disposition" identifies the final fate of federal records that are no longer needed for current business. Permanent disposition means records will be transferred to the National Archives. A disposition of temporary means that the records will be destroyed. 

What is a disposition instruction?

A disposition instruction consists of:

• The disposition, of identification of the records as either temporary or permanent; 
• A cutoff instruction, either specific or implied; and
• Either the retention period or transfer period. The retention period is how long the agency must keep temporary records after the cutoff before destruction. The transfer period is how long the agency can keep the records after the cutoff before transferring them to NARA.  

Disposition instructions should be realistic. For example, avoid scheduling records for destruction when an office or program terminates. This practice can lead to retaining records much longer than needed. Instead, agencies should use fixed time periods for records retention.

Likewise, agencies should limit use of the instruction “destroy when no longer needed” for temporary records. This instruction leaves decisions about retention up to individual users. It results in the records management program losing control of such records. It also often leads to over-retention or premature destruction. The disposition instruction “destroy when no longer needed” is also difficult to automate. For these same reasons, agencies should not borrow the flexible retention phrase from the GRS, “longer retention is authorized for business use.”

Proposing Disposition

Although it is ultimately NARA’s decision, agencies propose to NARA whether they think that records have permanent or temporary value. 

The Appraisal Policy of the National Archives describes the types of records that NARA identifies as permanent.

NARA requires certain information about permanent records. In most cases there are fields in ERA to collect this information:

• The initial date of the records that the item covers
• The current volume of the records
• If the records are recurring, the annual accumulation
• The expected date of initial transfer of the records under the item
• Any access restrictions consistent with the Freedom of Information Act, including restrictions on security-classified information

In evaluating records for final disposition, it is important to recognize that:

• Different parts of the agency may use the same information. Compare similar records created at different organizational levels. NARA generally designates as permanent only the most complete series of records. 
• Not all agency programs will have the same number of permanent series. Agency programs vary in significance based on their function and activities.

NARA will evaluate proposed disposition instructions during the schedule appraisal process and approve or suggest changes. NARA has the final authority on the disposition of federal records.

Your agency’s NARA appraiser is available for advice throughout the scheduling process.

Cutoff Instructions

A cutoff instruction indicates the point at which records are no longer in active use and when the retention or transfer period starts. Cutoff instructions can be specific or implied. Specific cutoff instructions use the Cutoff Instruction field on the schedule. This field is optional. Alternatively, you can use implied cutoff instructions, where the cutoff instruction is part of the retention or transfer instruction. 
Record retentions that are based on the age of the record, such as “Destroy when 3 years old,” do not use cutoff instructions. They are unnecessary. The cutoff is implied as the date of creation or receipt.

ERA provides options for agencies to choose from to encourage clear disposition instructions. There are options for cutoff instructions, transfer instructions, and retention instructions. NARA recommends using these standardized options as much as possible. Limit the use of the “Other” option.

Specific cutoff instructions can be based on fiscal or calendar year or an event, or both. Examples of specific cutoff instructions that use the “Cutoff instruction field” on the schedule:

• Cut off at the end of the Fiscal Year. (It is implied that it is the Fiscal Year in which the records were created or received) 
• Cut off at the end of the fiscal year received. 
• Cut off when training is completed.

Note that end of year cutoffs were more common for paper records where records disposition would occur once a year. You can apply these types of cutoffs in automated systems, but more often a machine-implementable disposition instruction will use only an event because of the complexity of coding cutoff based both on an event and the year that event occurred.

Implied cutoff instructions are included as part of the retention or transfer instruction. Rather than specifying a cutoff event, the cutoff event is part of the instruction. Examples of implied cutoff instructions:

• Destroy when superseded or obsolete. (The implied cutoff is when the records are superseded or obsolete.)
• Transfer 15 years after case is closed. (The implied cutoff is when the case is closed.)

Specific cutoff instructions tend to be more clear than implied cutoff instructions. Use specific cutoff instructions if your users struggle to understand when to cut off records. 

A good cutoff instruction is the foundation of an implementable disposition instruction.

Cutoff instructions should:

• Be clear and straightforward. Anyone should be able to tell when the retention or transfer period starts for a record, including a computer application. 
• Event-based instructions should be specific. Use a specific event in the records workflow.
• Use “Destroy when no longer needed” sparingly. This type of instruction requires that someone determine that the record is no longer needed.
• When selecting a cutoff for aggregated items, be careful that the cutoff makes sense for all records covered by the item. It is possible to define specific cutoffs for individual series in a crosswalk, but this defeats the purpose of an aggregated item.

Understanding how cutoff instructions work is important for implementing disposition. It is especially important for implementing automatic disposition. Cutoffs should be either age-based or event-based. 

• Age-based cutoffs use the age of the record to determine when retention or transfer occurs. In this case, the implied cutoff is when the record is created or received. Automated systems can implement these instructions based on the date the record was created or received.
• Event-based cutoffs use an event to determine when retention or transfer occurs. The event might be a final action taken on the record or the record becoming superseded or obsolete. The event is usually when the record is no longer in active use. Automated systems can implement event-based instructions using metadata, such as when a case is closed, a specific date in a workflow, or last modified date.

See also the Guide to Machine-Implementable Disposition Instructions for additional guidance.

Options for Record Retention and Transfer Periods

ERA provides standardized options for both retention and transfer periods. Retention period is used for temporary records. Transfer instruction is used for permanent records. The retention or transfer period refers to how long records are retained once they are no longer needed for active use before they are transferred to NARA or destroyed. This period of time starts with an event. The event could be the creation or receipt of a record. This is common for records that have immediate and short term use. The event can also be at the end of the record’s active use, such as when a case is closed or the record is superseded or obsolete. See Cutoff Instructions for more information on these events.

Retention periods and transfer instructions are typically expressed in years. Some disposition instructions say to transfer permanent records in blocks. See Transfer Period Timeframes for more information on blocking instructions.

Try to use the standardized options in ERA for retention periods and transfer events. Avoid the use of “Other.”
 

Transfer Period Timeframes

For permanent records, the standard transfer period is between 15 and 30 years after cutoff, whatever cutoff might be. Transfer of permanent records should only occur when:

• The agency's business has ceased
• The passage of time has lessened the sensitivity of the records.

Sometimes it may be appropriate to transfer permanent records in blocks. An example of a disposition instruction that uses blocking is: “Transfer 15 years after cutoff in 5 year blocks.”

A block is a chronological grouping of records in the same series. The blocking instruction indicates the frequency of transfer and the date range expected in a transfer. Using the example above, an agency would transfer records every 5 years. Each transfer would contain 5 years of records. An agency would transfer the records 15 years after cutting off the last records in the block. Blocking is most often used when the annual volume of records is small and it is more cost effective to transfer records from multiple years together at once.

Agencies may need to keep certain unclassified records longer than 30 years to meet their business needs. These include personnel files, law enforcement files, and files governed by specific statutes. NARA usually does not approve transfer of security classified records earlier than 25 years. We do this to align with mandatory declassification review requirements.

Agencies must provide additional information to request early or late transfer of permanent records to NARA:

• Complete the Checklist for Proposing the Early Legal Transfer of Permanent Records when proposing to transfer unclassified records that are less than 15 years old or security classified records that are less than 25 years old. 
• Complete the Checklist for Proposing the Late Legal Transfer of Permanent Records when proposing to transfer records to NARA more than 30 years after cutoff or when the records are more than 30 years old, if transfer is based on the age of the record. 

Agencies must provide the completed checklist with the proposed new schedule. These checklists help us determine if earlier or later legal transfer dates are appropriate. Submitting a checklist does not guarantee that we will approve the proposed schedule. 

For more information see:
NARA Bulletin 2020-02: Guidance on Scheduling the Early and Late Transfer of Permanent Records

Flexible Retention Periods (Retention Bands)

Flexible retention periods, or retention bands, are an option available when scheduling temporary records. 

A flexible retention period allows an agency to choose a retention period within stated parameters for temporary records. The retention parameters are known as the retention band. Flexible retention periods may be applied to both aggregate schedule items and traditional granular schedule items.

Examples of flexible retention periods

There are four principal types of flexible retention periods for temporary records:

• Time band with minimum and maximum retention. Example: "Destroy when no less than 3 years old and no more than 6 years old." Time bands should be meaningful and reasonable. A time band spanning more than a few years may result in significant inconsistencies across the agency, incurring legal risk.
• Minimum retention, with longer retention permitted. Example: "Destroy when 5 years old. Longer retention is authorized if still needed for business purposes." Do not use this type of retention for records that contain personal privacy information. An open ended retention could result in keeping information longer than allowed by the Privacy Act.
• Maximum retention, with earlier destruction permitted. Example: "Destroy when 5 years old. Earlier disposal is authorized if no longer needed for business purposes." Do not use this type of retention for records needed for protection of legal rights or for ensuring government accountability. This type of retention can result in premature disposal of the records. Consult your General Counsel before proposing this type of retention band to ensure it is appropriate for the records. This is the least common type of retention band.
• Retention until no longer needed. Example: "Destroy when no longer needed for business reasons." Do not use this retention for records needed to protect legal rights, for ensuring government accountability, or for records that contain personal privacy information. Use this type of instruction sparingly and only when there is little to no risk in destroying records immediately. Agencies should consider whether the records are in fact transitory, in which case they could use the GRS instead.

Implementation of Flexible Retention Periods

Agency records management programs are responsible for consistent application of flexible retentions throughout their agency. Agencies should establish internal policies for how they will use flexible retentions. Inconsistent records disposition can open an agency to legal risk. An agency may use a schedule item with a flexible retention period in the following ways:

• The agency may set different retention periods for records held in different offices. This applies whether the item is for a single series or is an aggregate item.
• For aggregate items, the agency may establish different retention periods for individual series within the aggregate item. 
• Individual series within an aggregate item can have different retentions based on the office that holds the records. 
• In all the above options, the retention period selected must fall within the stated parameters of the schedule item.

Additional Considerations for Flexible Retentions

Apply flexible retention periods consistently across your agency for certain records. Consistent retention is necessary for records such as:

• Records with legal rights implications
• Records likely to be requested under the Freedom of Information Act
• Records likely to be subject to discovery in litigation
• Records that contain personal privacy information.

Your agency may still use flexible retentions for these records. Just make sure that retention is applied consistently.

• Record retention should be consistent at the office level, at minimum. Do not allow individual staff members to establish retention periods for their own records. This includes records covered by General Records Schedules, which often allow for longer retention periods. Agencies should establish common set retention periods for their records at least at the office level. Only use the disposition “Destroy when no longer needed for business reasons” when there is minimal risk associated with retaining records for shorter or longer periods than necessary.
• Records management applications need fixed record retentions. Establishing set retention periods for records is necessary for automated records management. Records management applications need a single retention period associated with the records to calculate disposition. An agency that allows for different retentions in different offices may find it necessary to repeat disposition authorities in their system to accommodate the different retention periods. See the Guide to Machine-Implementable Disposition Instructions for more information.

Machine-Implementable Disposition Instructions

Machine-implementable disposition instructions allow a computer application to implement record disposition. Systems can automate disposition either by automatically disposing of records or by notifying a records manager that records are eligible for destruction or transfer to NARA. For more information on how to write machine-implementable disposition instructions, see the Guide to Machine-Implementable Disposition Instructions.

Creating the Records Schedule

Agencies submit schedules to NARA via the Electronic Records Archives (ERA). 

The ERA Training Materials provide instructions on creating a schedule in ERA. 

Agencies can use the ERA 2.0 Schedule Data Entry Tool to collect and prepare information for entry into ERA. The tool explains what information should go into each field in the records schedule.

Job Aids: 
Best Practices for Writing Descriptions
Dos and Don’ts of Records Scheduling
Records Schedule Quality Control Checklist
 

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