Does a digitization project need executive or SAORM approval before it can start in a federal agency?

There is no single, universal rule that every digitization effort must first pass across an executive’s or the Senior Agency Official for Records Management’s (SAORM) desk. Whether explicit high-level sign-off is required depends on the project’s scope, the records involved, and your agency’s own internal policies. That said, federal digitization is governed work, and meaningful oversight is almost always expected somewhere in the chain.

When formal approval is more likely

Higher-level review tends to be triggered when a project:

• Aims to destroy original records after scanning. Disposing of source records once digitized is a disposition action that must align with an approved records schedule and applicable NARA guidance — not a decision a project team makes alone.
• Touches permanent, classified, or sensitive records, including those with privacy or Controlled Unclassified Information (CUI) implications.
• Is large in scale or budget, or changes how an entire records series is maintained going forward.

Smaller, routine conversions of temporary working copies usually carry lighter approval burdens, though they still must follow agency procedures.

Why the SAORM and executives matter

The SAORM is responsible for overseeing the agency’s records management program and ensuring compliance with federal requirements. Even when the SAORM does not personally approve a specific project, digitization should fit within the program direction they set. Executive sponsorship is also practically important: it secures funding, assigns accountability, and confirms the project serves a legitimate business and recordkeeping need.

A practical sequence

Before scanning begins, agencies typically:

1. Identify the records and confirm their schedule and retention status.
2. Determine whether originals may be destroyed and what approvals that requires.
3. Set quality, metadata, and format standards (FADGI guidelines are a common federal reference).
4. Address privacy, security, and access controls.
5. Obtain the governance sign-offs your agency’s policy specifies — which may include records management leadership, the SAORM, IT security, and program executives.

The safest assumption is that you need documented authorization appropriate to the records’ value and the project’s risk — and that you should consult your agency records officer early. For more, see the digitization and imaging hub.