Is it true that an agency can refuse a FOIA request just because finding the records would be a lot of work?

The short answer is no, not by itself. Under the federal Freedom of Information Act (FOIA), an agency generally cannot deny a request simply because locating and reviewing the records would take effort. Effort is expected. FOIA is built on the presumption that government records are open to the public, and an agency must conduct a search reasonably calculated to find the records you describe. “This is a lot of work” is not, on its own, a lawful basis to refuse.

What an agency may actually do

While burden alone is not a denial, the law does give agencies tools to manage the cost and scale of large requests:

• Charge fees. Agencies may charge for search time and, depending on your requester category, for review and duplication. Fee waivers may be available when disclosure serves the public interest.
• Ask you to narrow or clarify. If a request is broad or vague, an agency can ask you to reasonably describe the records so the search is manageable. Working with them often speeds things up.
• Take more time on complex requests. Agencies can invoke limited extensions and may use multitrack processing, handling simpler requests faster than voluminous ones.

These mechanisms address workload. They are not the same as refusing to look.

Where burden can become a real limit

There is a narrow exception. If a request does not “reasonably describe” the records, or if responding would require the agency to create new records, conduct research, or analyze data rather than search existing files, the agency may decline that portion. The line is between searching for records that exist (required) and manufacturing answers (not required). An unusually burdensome search can also factor into fee estimates and timing, but it does not erase the duty to search.

What this means for you

• Burden alone is not a valid denial; ask the agency to cite a specific statutory exemption or basis.
• If cost is the obstacle, request a fee estimate, a fee waiver, or a narrower scope.
• You can appeal an inadequate search or an improper denial, and many agencies offer help through a FOIA Public Liaison.

Good agency recordkeeping is what makes searches efficient in the first place. For more, see the FOIA and public records hub.