What should we do if our agency blew past the NARA electronic records deadline and our system still is not compliant?

Missing a federal electronic records deadline is a serious gap, but it is recoverable. The worst response is silence. Agencies that document the gap honestly, communicate it, and execute a credible remediation plan are in far better standing than those that conceal it. Treat the situation as a managed corrective action, not a one-time failure.

First, Stop the Bleeding and Assess

Before planning a fix, understand the scope.

• Confirm exactly which requirements you are missing. Distinguish between records that are merely stored electronically and records managed in a compliant, retrievable, retention-aware way.
• Identify which record categories and systems are affected, and whether any at-risk records are nearing the end of their retention period or are subject to a litigation hold.
• Make sure nothing is being inadvertently destroyed or rendered inaccessible while you work. Preservation comes first; perfection comes later.

Communicate Up and Out

Noncompliance is a leadership issue, not just a records-team issue.

• Brief senior management and your agency’s records officer in writing, with a frank picture of the gap and the risk.
• Coordinate early with the National Archives. NARA generally favors agencies that self-report and engage proactively over those it has to chase. Ask what reporting or interim measures apply to your situation.
• Loop in legal, privacy, IT, and security so the response is coordinated rather than siloed.

Build a Realistic Remediation Plan

Regulators and oversight bodies respond to credible, dated plans far better than to vague intentions.

• Prioritize the highest-risk records first: permanent records, records under hold, and records with imminent disposition dates.
• Set milestones with owners and target dates, and track progress against them.
• Fix root causes, not just symptoms. If policy, training, or system configuration allowed the gap, address those so it does not recur.
• Update your records schedules, policies, and procedures to reflect how records are actually managed going forward.

Keep the Paper Trail

Document every decision, communication, and corrective step. A well-documented good-faith effort is itself evidence of diligence and significantly reduces your exposure.

For broader context on standards and obligations, see the compliance and standards hub. When in doubt about specific federal requirements, rely on official NARA guidance and the governing records laws rather than assumptions.