The June 30, 2024 deadline for M-23-07, the OMB/NARA memo that pushed federal agencies to ditch paper records for good, has passed. But if you assumed that meant the story was over, 2026 has made it clear it isn’t. This year has brought a fresh oversight report, a new reporting cycle, a quiet technical shift in what “compliant” even means, and a wave of AI-driven products racing to help agencies catch up [1][2].
The Compliance Numbers Are Improving, Slowly
NARA’s own 2024 records management report, released late last year, found that 71% of agencies said they’d met the deadline to manage permanent records electronically — up from 68% the year before [3]. That’s progress, but it also means roughly 44 agencies missed the mark, and about half of those hadn’t even filed for a formal exception [3]. NARA isn’t just tracking this passively either. In September 2025, the agency’s Inspector General published an audit examining NARA’s own preparedness to receive electronic records and its handling of exception requests under M-23-07, and it came back with two recommendations to tighten how the agency manages compliance and its ERA 2.0 intake system [4]. In other words, the pressure isn’t just on agencies submitting records — NARA is being told to get its own house in order too.
A New Reporting Cycle Just Kicked Off
This spring, NARA opened its 2025 Federal Agency Records Management reporting period, running from March 9 through May 15, 2026 [5][6]. Every Senior Agency Official for Records Management (SAORM) had to file an annual report on their agency’s progress toward M-23-07’s goals, meaning the government now has a much clearer, more current snapshot of who’s actually caught up and who’s still behind, expected to surface later this year.
The Technical Standard Underneath M-23-07 Has Shifted
Here’s a development that’s easy to miss but matters a lot to vendors: NARA formally moved away from the old DoD 5015.2 standard, which had been the benchmark for records-system functionality for years, in favor of the Universal Electronic Records Management (ERM) Requirements built through the Federal Electronic Records Modernization Initiative (FERMI) [7]. That change is reshaping what software companies need to build toward if they want their platforms certified as compliant.
The Industry Response: AI Is Doing the Heavy Lifting
M-23-07 has had its biggest real-world impact on the vendor side. Analysts now expect AI-enabled content management to hold roughly a 35% share of the government content-management market in 2026, largely because agencies need faster ways to classify decades of scanned, backlogged paper [8]. Cloud-based systems are projected to account for 58% of deployments this year as agencies move away from on-premises servers entirely [8]. Big platform players have taken notice: Hyland struck a partnership with Microsoft in June 2026 to bring its Content Innovation Cloud to Azure, specifically targeting government customers [9], while the 2025 federal AI inventory already listed over 100 separate use cases for Microsoft Copilot tools inside agencies [9]. Case management, tied closely to records retention and audit trails, is projected to grow faster than any other segment of the government content-management market through 2031 [9].
None of this means the transition is finished. Analysts still describe records-management skill gaps and legacy-system dependence as real drags on progress [8]. But M-23-07 has clearly done what it set out to do: it turned a once-optional modernization effort into a hard deadline agencies can’t ignore, and in doing so, it kicked an entire industry of records and AI vendors into higher gear.
Sources
- National Archives — AC 04.2026: 2025 Federal Agency Records Management Reporting Period and Questionnaires
- National Archives — AC 06.2026: 2025 SAORM Annual Report
- National Archives — Federal Agency Records Management 2024 Annual Report (PDF)
- NARA Office of Inspector General — Audit Report No. 25-AUD-04 (PDF), September 8, 2025
- National Archives — https://www.archives.gov/records-mgmt/memos/ac-04-2026
- National Archives — https://www.archives.gov/records-mgmt/memos/ac-06-2026
- RM University — “The SAORM Role in Federal Agencies”, June 2026
- Fact.MR — Government Enterprise Content Management (ECM) Market Size & Forecast 2036
- Mordor Intelligence — Government Enterprise Content Management (ECM) Market Size, Share & 2031 Growth Trends Report, July 2026
Leave a Reply