Are Microsoft Copilot and ChatGPT outputs considered records, and how do you capture them?

Outputs from generative AI tools such as Microsoft Copilot and ChatGPT can absolutely be records. Whether a given output is a record does not depend on the technology that produced it. It depends on what the content is, how it is used, and whether it documents an organizational decision, activity, or transaction.

When AI output is a record

Apply the same test you would apply to any other content: a record is information created or received in the course of business that has evidential or informational value worth retaining. Under that principle, an AI output is likely a record when it is:

• Relied upon to make a decision or finalize an action
• Distributed, published, or filed as official content
• Incorporated into a report, policy, contract, or other recordkeeping system
• Responsive to a foreseeable legal, audit, or public-records request

By contrast, throwaway drafts, exploratory queries, or content that is never used or shared often qualify as transitory and may be dispositioned quickly under your retention schedule.

What to capture

A useful practice is to treat the AI exchange as a unit of evidence, not just the final answer. Where it has business value, consider capturing:

• The output itself in a stable, openly readable format
• The prompt or input that produced it, for context and authenticity
• Basic metadata: who, when, which tool, and how the output was used

This mirrors the recordkeeping principles in ISO 15489-1, which call for records to be authentic, reliable, complete, and usable over time.

How to capture them

• Save the substantive output into your designated recordkeeping repository, not just the chat history of the tool.
• Use durable formats (for example, PDF/A or plain text) so the content remains accessible after the AI tool changes or is retired.
• Apply your existing retention schedule by classifying the output to a records series based on its business function, the same way you would an email or memo.
• Establish policy so staff know which AI interactions must be preserved, and avoid relying on the AI platform alone to retain content.

For more on converting and preserving digital content reliably, see the Digitization & Imaging topic hub.

The bottom line: focus on content and use, not the tool. If an AI output documents business, manage it as a record.