OMB Memo M-19-21 — Transition to Electronic Records Management

OMB Memorandum M-19-21 ("Transition to Electronic Records," June 28, 2019) directed all executive branch agencies to complete the transition from paper-based to electronic records management by December 31, 2022 — ending the practice of maintaining paper copies of records as the official federal record and moving to electronic records as the authoritative record for all agency business. Issued jointly by OMB and the National Archives and Records Administration (NARA), the memo set binding timelines for agencies to digitize existing paper records with permanent or long-term retention value and to adopt electronic records management systems for all new records created after 2022.

The context: despite decades of computing, most federal agencies were still creating, storing, and transferring large volumes of paper records in 2019. NARA was receiving and managing millions of boxes of paper records per year — a storage burden that was expensive, created access delays, and made electronic search and disclosure (including FOIA responses) dependent on paper-to-digital conversion that happened after the fact, if at all. M-19-21 aimed to flip the model: electronic by default, with paper existing only as a temporary input that must be digitized rather than retained as the record.

Legal Authority

• 44 U.S.C. § 3101 — Federal Records Act; requires the head of each agency to make and preserve records that document the agency's organization, functions, policies, decisions, procedures, and essential transactions; the core statutory records preservation obligation
• 44 U.S.C. § 3301 — Defines "records" for Federal Records Act purposes; as amended by the Presidential and Federal Records Act Amendments (2014), explicitly includes electronic records and emails as federal records subject to preservation requirements
• 44 U.S.C. § 2901 — National Archives and Records Administration authority to establish standards for records management; NARA co-issued M-19-21 under this authority
• OMB Memorandum M-19-21 (June 28, 2019) — Joint OMB-NARA directive requiring agencies to transition to electronic records by December 31, 2022; establishes digitization requirements for permanent and long-term paper records; requires agencies to report progress annually to OMB and NARA

Key Mechanics

M-19-21 set a December 31, 2022 deadline for all executive branch agencies to manage all permanent and long-term temporary records electronically. Requirements: (1) New records created after 2022 must be maintained as electronic records; paper records created temporarily (field notes, incoming mail) must be digitized and the paper copy may then be disposed of unless the law requires paper retention; (2) Existing paper records with permanent or long-term retention value must be scanned and digitized on a prioritized schedule; agencies must submit digitization plans to NARA; (3) Email must be captured and preserved as records in an electronic records management system — agencies may not use personal email accounts for government business without same-day copying to official records systems; (4) Electronic records systems must meet NARA-prescribed technical standards for authenticity, integrity, and long-term preservation; agencies must certify compliance. NARA provides technical guidance and approves agency records schedules. Compliance has been uneven — many agencies met the 2022 deadline for processes going forward but continue to hold large backlogs of pre-2022 paper records awaiting digitization. Violations of the Federal Records Act (failure to preserve records, unauthorized destruction) may be referred to DOJ and OIG.

Overview

What This Memo Requires

Electronic Records as the Default

After December 31, 2022, all federal agencies must:

• Create records in electronic format: All new agency records — emails, documents, spreadsheets, databases, meeting notes — must be created and managed as electronic records from the outset, not converted from paper after the fact
• Manage email electronically: Email is a federal record; agencies must have electronic email records management systems that capture, preserve, and make retrievable all email records subject to records retention schedules. "Print and file" email management (printing emails to paper and filing them in physical folders) is prohibited
• No longer accept paper transfers to NARA: After the transition deadline, NARA will only accept permanent records in electronic format; agencies sending paper records to NARA after 2022 must digitize them first
• Digitize existing paper records with long-term value: Existing paper records with permanent retention value or retention schedules beyond 10 years must be digitized and transferred electronically to NARA

Digitization Standards

M-19-21 directed NARA to issue digitization standards that agencies must follow when converting paper records to electronic format. Key requirements:

• Image quality: Scanned images must meet resolution standards (typically 300 DPI minimum for text documents) that preserve legibility and OCR accuracy
• Metadata: Electronic records must include metadata capturing provenance (who created it, when, in what context) consistent with NARA's metadata standards
• Format: Digitized records must be stored in formats that are accessible long-term — NARA accepts PDF/A (the archival PDF standard), TIFF, and other specified formats; proprietary formats that may become unreadable as software changes are not acceptable
• Authentication: For records with legal significance, digitization processes must create authenticated copies that can serve as the official record

Electronic Records Management Systems

Agencies must have electronic records management systems (ERMS) that:

• Capture records in context (not just the document, but who created it, when, and in what business process)
• Apply and enforce records retention schedules automatically (flagging records for review at the end of their retention period rather than requiring manual disposition)
• Enable electronic transfer to NARA for permanent records
• Support FOIA searches across the electronic records holdings

The Office 365 / Microsoft 365 ecosystem is the dominant platform for federal email and document records; NARA has issued guidance on configuring Microsoft 365 to meet federal records management requirements, including auto-retention settings and eDiscovery compatibility.

Email Records

Email is both the most voluminous and most legally sensitive category of electronic records. M-19-21 reinforced that email records management is not optional:

• Official email must be captured: Agencies must capture emails that document official agency business; the mechanism may be automatic journaling into a records repository, integration with document management systems, or capture at the user level
• Personal email prohibition: Officials may not conduct government business on personal email accounts to avoid records retention requirements — a practice that had become visible in several high-profile incidents (including Hillary Clinton's State Department email controversy, which preceded M-19-21)
• Text messages and instant messages: M-19-21 acknowledged that text messages, Slack-type messaging, and other ephemeral communications increasingly contain federal records; agencies must have capture strategies for these channels

Key Requirements

• December 31, 2022 deadline: Complete transition to electronic records; no new paper-only record systems
• Email management: Electronic capture of all federal email records; "print and file" methods prohibited
• NARA transfer: All permanent records transferred to NARA in electronic format after 2022
• Digitization of existing records: Paper records with permanent or 10+ year retention value must be digitized on agency-published schedules
• Electronic records management systems: Agencies must have ERMS meeting NARA standards for capture, retention, and disposition
• Metadata standards: Electronic records must include NARA-required metadata
• Self-assessment reporting: Agencies report annually to NARA on records management maturity using NARA's Records Management Self-Assessment (RMSA)

How It Affects You

If you work at a federal agency (records officers, IT staff, program offices): M-19-21 compliance requires two parallel efforts: system capability (deploying ERMS, configuring email retention, building digitization pipelines) and behavioral change (training staff that emails and texts are records, ending paper workarounds). The December 2022 deadline passed; agencies that haven't completed the transition face NARA compliance reviews and potential IG findings. The most common compliance gap is email and messaging: automatic retention configurations in Microsoft 365 or Google Workspace are the fastest path to compliance. For program offices generating significant paper (regulatory submissions, grant applications, contracts), establishing a scan-and-discard workflow requires both scanning infrastructure and legal sign-off that the digitized version satisfies evidentiary requirements.

If you are a FOIA requester: M-19-21's transition to electronic records management should improve FOIA response quality over time — agencies with functioning ERMS can search electronically rather than manually combing paper files. The transition also means that records from pre-2022 paper systems may require digitization before they can be produced in response to FOIA requests; agencies can charge reasonable search and duplication fees for this. If you receive paper scans in response to a FOIA request, the underlying records may still be in paper form — pre-2022 records may not have been digitized yet.

If you are a researcher or historian: NARA's transition to electronic-only records acceptance fundamentally changes how federal archives will look for future historians. Records created since 2023 should be electronically preserved with full metadata; the challenge is the gap between the digitization mandate and the agency resources to implement it. Many agencies have millions of pages of pre-2023 paper records that should be digitized under M-19-21 but haven't been — budget constraints mean digitization is moving more slowly than the mandate implies. NARA's annual records management reports track agency compliance.

If you are a journalist or oversight professional: Text messages and messaging platform communications are federal records under M-19-21 and the Federal Records Act — deletion of such messages without proper records retention compliance is a records management violation. Several investigations into agency officials' use of Signal, WhatsApp, and similar apps for official business (including the 2025 Houthi strike-planning Signal group) have raised whether M-19-21's requirements are being followed for newer communication channels.

Implementation Status

The December 31, 2022 deadline passed with uneven agency compliance. NARA's Records Management Self-Assessment data shows that most agencies have made significant progress on email records management (particularly those on Microsoft 365 with auto-retention configured) but that many remain behind on:

• Digitization of existing paper records: The volume of paper is enormous; agencies have developed digitization plans but implementation is resource-constrained
• Emerging communication channels: Text messages, Teams chats, and other modern communications remain poorly captured at many agencies
• Small agency compliance: Smaller agencies without dedicated records officers have the most compliance gaps

NARA has provided technical assistance, published guidance for Microsoft 365 configuration, and issued compliance findings for agencies with significant gaps.

Relationship to Broader Policy

• Federal Records Act: M-19-21 implements the FRA's broad records preservation mandate with specific electronic records requirements
• FOIA: Electronic records management directly affects FOIA response capability and speed; FOIA litigation often turns on whether agencies have searchable electronic records
• M-13-13 Open Data: Electronic records as the default aligns with open data's machine-readable-by-default principle; electronic records are more amenable to proactive disclosure and structured data extraction
• E-Government Act: The E-Gov Act's vision of electronic government services requires electronic records to support those services; M-19-21 completes the records side of the e-government transition

Recent Developments

• June 2019 — M-19-21 issued; December 31, 2022 transition deadline set
• December 2022 — Deadline passed; NARA issued transition compliance guidance; agencies with significant gaps subject to NARA compliance review
• 2023-2024 — NARA began declining to accept paper transfers from agencies that have not demonstrated inability to digitize; agencies required to develop remediation plans
• 2025 — High-profile reporting on Trump administration officials using Signal for official communications raised compliance questions under M-19-21 and the Federal Records Act; National Security Council records management practices scrutinized