How often does NARA require agencies to review and test their vital records plan?

Vital records are the documents an organization needs to function in an emergency and to protect the legal and financial rights of the organization and the people it serves. Because these records are so important, a vital records plan cannot be a one-time effort. It has to be kept current and proven to work.

The General Expectation: At Least Annually

For federal agencies, the National Archives and Records Administration (NARA) treats vital records as part of an agency’s broader records and continuity-of-operations responsibilities. The widely followed expectation is that an agency review its vital records inventory and test its vital records plan at least once a year.

An annual cycle exists because the things a plan depends on change constantly:

• Which records qualify as “vital” shifts as missions, systems, and programs evolve.
• Storage locations, file formats, and backup media become outdated.
• Staff with key responsibilities leave or change roles.

A plan that is never revisited quietly drifts out of date and may fail at the exact moment it is needed.

Review Versus Test

It helps to separate two related activities:

• Review means confirming the vital records inventory is complete and accurate — that the right records are identified, properly classified, and stored where the plan says they are.
• Testing means actually verifying you can retrieve and use those records: restoring a backup, accessing an off-site copy, or walking through recovery steps in an exercise.

A review on paper is not enough. Testing is what reveals whether copies are truly readable, current, and accessible.

Beyond the Annual Cycle

Annual is a floor, not a ceiling. A vital records plan should also be reviewed and, where appropriate, re-tested after any significant change, such as:

• A move to a new system, repository, or facility.
• A reorganization or major change in mission.
• An actual emergency or a near-miss that exposed gaps.

Treating the plan as a living document — reviewed yearly and updated whenever circumstances shift — is the practical standard agencies are held to.

For current federal requirements and related guidance, consult NARA directly, and see more in the archives and preservation topic hub.