Do federal agencies still have to manage paper records after M-23-07?

Yes. M-23-07 reshaped how federal agencies handle paper, but it did not end the obligation to manage analog records. The memorandum moved the government to electronic recordkeeping as the default — it did not declare that paper records no longer exist or no longer matter.

What M-23-07 actually changed

The OMB/NARA directive “Update to Transition to Electronic Records” pushed agencies to manage records electronically and to transfer permanent records to the National Archives in electronic form. After the transition deadline, NARA generally stopped accepting transfers of permanent records in analog (paper) formats, except by approved exception.

The key word is transfer. The change targets the format in which records are created, managed, and sent to NARA going forward. It is a modernization mandate, not a release from custody of the paper an agency already holds.

Why paper records still require management

Agencies hold vast volumes of legacy paper that did not vanish on the deadline. Those records remain subject to the same fundamental duties:

• Existing analog records must still be retained and protected for as long as their approved retention schedule requires.
• Paper records cannot be destroyed at will. Disposal must be authorized by an applicable records schedule or disposition authority, exactly as before.
• Records under legal hold, FOIA request, or other obligation must be preserved regardless of format.
• New analog records that are still created must be captured and managed, even as agencies work to digitize or phase them out.

In practice, agencies respond by digitizing legacy paper to NARA’s quality and metadata standards, then disposing of the originals only when that digitization is authorized — and by managing remaining paper under its schedule until it can be closed out.

The bottom line

M-23-07 sets the destination — electronic management and electronic transfer to NARA — but the journey involves a real inventory of paper that still needs scheduling, safekeeping, and lawful disposition. An agency cannot treat the memo as permission to ignore or summarily destroy paper records.

So the honest answer is yes: agencies still manage paper records after M-23-07. The mandate accelerates the shift to digital and changes what NARA will accept, but it does not erase the recordkeeping responsibilities attached to the analog records agencies already have. See the federal records management hub for the broader framework.