Do I really have to destroy records as soon as a NARA-approved schedule says they're eligible, or can the agency keep them longer?

Short answer: eligibility is permission to destroy, not a command to destroy on a specific day. A NARA-approved schedule tells you the minimum time records must be kept and authorizes their disposition once that period ends. Reaching the eligibility point does not, by itself, force immediate destruction.

What “eligible for disposition” really means

A records schedule establishes how long a series of records is retained and what happens at the end of that retention period (transfer to the National Archives for permanent records, or destruction for temporary ones). When the retention period elapses, the records become eligible for that action.

In practice this means:

• You may not destroy temporary records before they are eligible. The schedule sets a floor, and premature destruction of federal records is improper.
• Once eligible, the agency is authorized to carry out the approved disposition.
• Agencies are expected to dispose of eligible temporary records in a timely, routine way as part of sound recordkeeping, rather than accumulating them indefinitely without reason.

So the schedule is best read as “keep at least this long, then dispose under this authority” — not “destroy the moment the clock runs out.”

When you must keep records longer

Several circumstances override routine disposition and require continued retention even after eligibility:

• Litigation, audit, or investigation holds. If records are relevant to pending or reasonably anticipated litigation, an investigation, or an audit, disposition must be suspended until the hold is lifted.
• Open records demands. Active FOIA, Privacy Act, congressional, or discovery requests can require you to preserve responsive records.
• Ongoing business need. If the records are still needed for agency operations, retaining them is acceptable, though indefinite drift past the approved period should be deliberate, not accidental.

In these situations, keeping records past eligibility is not a violation — destroying them would be.

The bottom line

The schedule protects against destroying records too soon and authorizes disposition once retention is met. Eligibility permits action; it does not compel same-day destruction, and legal holds or active requests can require you to hold longer. Agencies should still dispose of eligible records routinely so retention does not become open-ended without justification.

For more context, see the federal records hub.