What happens if a federal agency misses the NARA deadline to manage all records electronically?

Under federal policy issued jointly by the Office of Management and Budget (OMB) and the National Archives and Records Administration (NARA), agencies have been directed to manage all permanent and temporary records in electronic formats, and to stop sending paper records to NARA for storage. When an agency misses such a deadline, the consequence is generally not a fine or criminal penalty. Instead, the effects are practical, administrative, and reputational.

What actually happens

NARA does not impose punitive fines on agencies the way a regulator might penalize a private company. The federal records framework relies on oversight, transparency, and continued obligation rather than monetary penalties. In practice, missing the deadline means:

• The obligation does not go away. A missed deadline does not relieve an agency of the requirement. The records still must be managed electronically; the agency is simply behind.
• NARA may decline to accept non-electronic transfers. Agencies can lose the ability to transfer paper or non-conforming records to NARA, leaving those records on the agency’s own books and budget.
• Increased oversight and reporting. NARA tracks agency progress through self-assessments and reporting. Falling short can mean more scrutiny, follow-up, and required corrective-action plans.

Why it still matters

Even without fines, the downstream risks are significant:

• Legal and accountability exposure. Records that are poorly managed can complicate FOIA responses, litigation holds, audits, and oversight inquiries.
• Risk to permanent records. Mismanaged or unconverted records can be at greater risk of loss, which conflicts with an agency’s duty to preserve records of enduring value.
• Cost and inefficiency. Maintaining legacy paper or hybrid systems is typically more expensive and slower than the electronic environment the policy is meant to create.

What an agency should do

An agency that has missed or expects to miss the deadline should not treat it as a failure to hide. The constructive path is to document its current status, engage with NARA, prioritize permanent records, and build a realistic remediation plan. NARA generally favors continued progress and good-faith cooperation over perfection on a calendar date.

For broader context on federal recordkeeping duties and oversight, see federal records.