Who decides which positions go on the Capstone official list, and who has to approve it?

Under the Capstone approach to email management, agencies manage email based on the role or position of the account holder rather than by reviewing each message individually. Accounts belonging to senior officials and other key roles are designated as “Capstone” accounts, and their email is generally treated as permanent. The list of those designated roles and accounts is the Capstone official list (sometimes called the verified or certified list of accounts).

So who builds it, and who signs off?

Who proposes the positions

In practice, the work of identifying which positions belong on the list starts inside the agency’s records program. The agency records officer — working with the records management staff — typically drafts the proposed list. They do this by mapping the agency’s organizational structure: identifying senior leadership, principal advisors, and other roles whose email is likely to have lasting value.

This is a collaborative step. Records staff usually coordinate with:

• Program and office leaders, who know which positions actually carry significant decision-making authority.
• IT and email administrators, who can tie roles to actual accounts and mailboxes.
• Legal counsel and FOIA/privacy staff, who flag accounts subject to litigation holds or special handling.

Who has to approve it

Two layers of approval matter.

Internally, the proposed designations need agency leadership endorsement. Because Capstone determines what email is preserved permanently, the decision rises above the records office — senior management (often through the Senior Agency Official for Records Management) reviews and signs off so the list reflects the agency’s real governance.

Externally, the disposition authority itself comes from the National Archives and Records Administration (NARA). An agency cannot unilaterally declare email permanent or temporary; the schedule that authorizes Capstone disposition must be approved by the Archivist of the United States. Agencies generally implement Capstone under a NARA-approved schedule (commonly via the relevant General Records Schedule) and then maintain their own verified list of accounts consistent with it.

The short version

The agency records officer (with program, IT, and legal input) proposes the positions; agency leadership approves the list internally; and NARA holds the ultimate authority over the underlying disposition schedule.

For related guidance on managing email and other electronic messages, see the email and messaging topic hub.