What M-23-07 Is
M-23-07, formally titled “Update to Transition to Electronic Records,” is a joint memorandum issued by the Office of Management and Budget (OMB) and the National Archives and Records Administration (NARA) on December 23, 2022. It set a new government-wide deadline of June 30, 2024, by which federal agencies had to manage their permanent and temporary records electronically, and after which NARA would stop accepting paper-based record transfers altogether.
The Roots: M-12-18 and the Managing Government Records Directive
The push to digitize federal recordkeeping did not start with M-23-07. It traces back to a 2012 presidential directive that produced OMB/NARA Memorandum M-12-18, the government’s first major modern push toward electronic records. That effort aimed to modernize record-keeping practices but was eventually rescinded and folded into later, more ambitious guidance, as federal reporting later noted when tracing the lineage of today’s digitization rules.
M-19-21: The Direct Predecessor
The immediate predecessor to M-23-07 was M-19-21, “Transition to Electronic Records,” issued jointly by OMB and NARA in June 2019. M-19-21 set the original target dates for agencies to stop managing records on paper: December 31, 2022, for permanent records, and an earlier date for closing out paper-based storage practices. NARA also published supporting guidance, Bulletin 2020-01, to address agency questions and outline an exception process for agencies that could not meet the deadlines.
What Led to M-23-07: COVID-19 and Implementation Delays
M-19-21’s original end-of-2022 deadline collided with the COVID-19 pandemic. Agencies that were already working through the logistical, staffing, and technical challenges of retiring paper-based systems found the pandemic disrupted procurement schedules, IT modernization projects, and the availability of staff needed to digitize backlogs of physical records. By late 2022, it had become clear across government that the original deadline was not realistic.
In response, OMB and NARA jointly issued M-23-07 on December 23, 2022, an update rather than a replacement. As NARA’s own Records Express blog explained at the time, the memo extends the M-19-21 deadlines to June 30, 2024, giving agencies more time to complete their transition to electronic records because of implementation delays caused by the pandemic. The memo opens by reasserting the underlying rationale for the whole effort: strong records management, it states, is necessary for transparency and accountability and underpins American democracy.
What the Memo Requires
M-23-07 reinforced, rather than replaced, the goals of M-19-21. Under the new deadline, agencies had to manage all permanent and temporary records electronically, with appropriate metadata, or store any remaining physical records in commercial storage facilities. After June 30, 2024, NARA would no longer accept transfers of permanent or temporary records in analog formats, accepting only electronic-format records with appropriate metadata. Agencies unable to meet the deadline could request a formal exception through the process NARA had already established under Bulletin 2020-01.
Follow-Up Guidance and Enforcement
As the June 2024 deadline approached, NARA issued a series of clarifying memos to help agencies interpret the rule, including guidance on Federal Records Centers and on submitting transfer requests before the cutoff. NARA later granted narrow, time-limited exceptions — for example, a 2024 joint bulletin with the Office of Personnel Management (OPM) allowed agencies extra time to digitize Official Personnel Folders and Employee Medical Folders.
The Aftermath
NARA’s government-wide reporting shows the deadline drove real change but not universal compliance. According to NARA’s 2024 Federal Agency Records Management report, 71% of agencies said they met the deadline to manage, preserve, and transfer permanent records electronically, up from 68% the prior year, while 44 agencies did not meet the deadline; about half of those had filed for an exception. M-19-21 and M-23-07 together remain the two guiding documents agencies cite when reporting their records-management progress to NARA each year.
Sources
- National Archives, Records Express Blog — “OMB M-23-07 Released”, December 27, 2022
- National Archives — AC 12.2023: OMB/NARA Memorandum Updating M-19-21 Due Dates
- National Archives — AC 17.2024: Transfer Requests, Direct Offers, and the M-23-07 Deadline
- National Archives — AC 14.2024: Federal Records Centers and the M-23-07 Deadline
- National Archives — NARA Bulletin 2024-01: Limited Exception for OPFs and EMFs
- National Archives — Federal Agency Records Management 2024 Annual Report (PDF)
- The White House — M-19-21, Transition to Electronic Records (PDF), June 2019
- PTFS — “Understanding M-23-07 Compliance Requirements”
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