How do we handle records still sitting in a system that is being decommissioned or shut down?

A system being decommissioned does not erase the obligations attached to the records it holds. Until those records reach the end of their approved retention period and are formally dispositioned, they remain subject to the same legal, regulatory, and operational requirements. The core principle is simple: shutting down a system is not a disposition event. The records must be accounted for before the system goes dark.

Inventory before you unplug

Start by identifying everything the system contains. Catalog the record types, their formats, associated metadata, and the retention rules that apply to each. Pay special attention to content that is easy to overlook — attachments, audit trails, system logs, and structured data that gives records their context. If you cannot map a body of content to a known retention requirement, treat it as a record until you can prove otherwise.

Decide the fate of each record set

For each category, determine which of three paths applies:

• Eligible for disposition — records past their approved retention period with no active hold may be destroyed following your organization’s documented disposition process.
• Still under retention — records not yet eligible must be migrated to a successor system or trusted repository that preserves their content, metadata, and usability.
• Subject to legal hold or active need — records under litigation hold, audit, or investigation must be preserved regardless of age. Confirm hold status before destroying anything.

Migrate to preserve, not just to copy

When records move to a new environment, the goal is to keep them findable, readable, and trustworthy over time. Carry forward metadata and audit history, validate that nothing was lost or corrupted, and confirm the records render correctly in the destination. Plan for long-term format viability so files remain accessible after the source application is gone. International guidance such as ISO 16175 addresses these expectations for records in digital environments.

Document everything

Capture the inventory, migration validation, and disposition actions in writing. A clear, auditable record of what was kept, moved, or destroyed — and the authority for each decision — protects the organization and demonstrates accountability.

Treat decommissioning as a governed project with records professionals at the table from the start, not a cleanup task handled after the fact.

For related guidance, see retention and disposition.