A longtime goal to transition to a paperless government is once again a moving target, with the White House now giving agencies until the end of June 2024 to fully transition to electronic recordkeeping.

A 2019 directive had set a deadline of Dec. 31, 2022, for when the National Archives and Records Administration would stop accepting paper records from agencies.

But as anticipated by federal records leaders for the last two months, a Dec. 23 memo from the Office of Management and Budget delays that deadline until June 30, 2024. The memo is signed by OMB Director Shalanda Young and acting Archivist of the United States Debra Steidel Wall.

“Starting on July 1, 2024, agencies will be required to digitize permanent records created in analog formats before transfer to NARA,” the memo states. “Digitization and transfer must be made in accordance with NARA regulations and transfer guidance, including metadata requirements.”

The memo cites challenges agencies faced in digitizing their records during COVID-19 restrictions as a major impetus for the delay.

It also establishes a “limited exception” to the June 30, 2024 deadline “in circumstances where replacing specific analog records with electronic systems would be burdensome to the public, the cost would exceed the benefit, statutory or regulatory barriers impede implementation, or there is exceptional intrinsic value in the original format.”

Meanwhile, all temporary records — which aren’t transferred to NARA and can be destroyed after a certain amount of time — should be managed electronically “to the fullest extent possible” by the end of June 2024.

“Transitioning federal agencies to an electronic — or ‘paperless’ — environment is a priority to enable and increase the ability of the public to engage with Government in new and more efficient and effective ways,” the memo states. “It is critical that federal agencies move beyond paper-based processes and embrace the opportunities afforded to improve government by transitioning fully to an electronic environment.”

The delay to the electronic record keeping deadline isn’t surprising, according to Jason R. Baron, professor at the University of Maryland and former director of litigation at NARA.

“It has been doubtful for some time whether the entire federal government could transition to electronic recordkeeping by the last day of 2022,” Baron told Federal News Network. “Although the memorandum cites COVID-19 as a possible reason for agencies needing more time, I suspect that the real underlying reasons for delays involve the limited resources agencies face, and the complexity of the issues involved. These systemic issues will not be going away any time soon, and it remains to be seen whether agencies will be able to meet even the extended deadlines.”

The government-wide push to phase out paper recordkeeping began in 2012, when the Obama administration set a goal of managing electronic records “to the fullest extent possible” by 2020. The vast majority of agency record-keepers signaled their confidence in meeting that goal as late as 2018.

But challenges with metadata requirements and lagging IT modernization projects ultimately helped to scuttle the 2020 target. In the summer of 2019, the Trump administration followed up by setting a hard deadline for when NARA would stop accepting paper records at the end of 2022.

Prior to the pandemic, 98% of agencies reported they were confident they would meet the Dec. 31, 2022, deadline.

But only 66% responded positively in their 2021 reports to NARA published earlier this year. More than one-third of agencies told NARA they planned to request an exemption, while a quarter of agencies hadn’t yet determined whether they would need one.

“Agencies indicated that there are delays in digitization projects and disposition of records, as access to hard copy records in offices and other storage spaces continued to be limited,” NARA wrote in its summary report of agency responses.

As Baron noted, COVID-19 hasn’t been the only challenge. While most federal records are created and stored electronically, agencies are still struggling to capture appropriate metadata and meet other long-term preservation requirements for electronic records.

“These challenges include identification of metadata, technology issues, cultural change management, and legal or regulatory requirements that continue to require paper,” NARA’s report states.

The latest OMB memo also highlights plans to address challenges agencies face in managing a fast proliferating trove of digital records beyond just email. By next June, NARA will  issue updated guidance for expanding the “Capstone” approach used for managing email records to other forms of digital messaging.

“I applaud NARA for committing to issuing guidance expanding the widely adopted Capstone approach for preserving email of senior government officials to all types of ephemeral and encrypted messages,” Baron said.

By the end of 2023, NARA will also issue guidance on managing records that reside in collaborative working environments across multiple agencies. Additionally, NARA is planning to finalize new Electronic Records Management standards and services under the Federal Electronic Records Modernization Initiative (FERMI) by Dec. 31, 2023.

“Agencies should use FERMI resources to comply with records management policies and mandates from NARA and OMB, including the requirements above,” the memo states.

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