“Becoming” digital: federal digitization standards here and on the horizon

This is the third and final installment of a blog based on a webinar jointly hosted by Preservica and Deloitte entitled “Transition to Electronic Government: Practical Advice from the Field.”

While a great deal of attention rightly has been paid to managing and accessioning into permanent archives “born digital” documents, there still remains a tremendous amount of legacy paper records that are candidates for digitization under the deadlines set in Memorandum M-19-21 issued by OMB and NARA (see discussion in first blog, here). In accord with that Memo, after December 31, 2022, “all temporary records in Federal agencies will be managed electronically to the fullest extent possible,” and after that date “NARA will no longer accept transfers of permanent or temporary records in analog formats. . . .” This all means that agencies must necessarily be paying increased attention on digitizing their legacy paper holdings.

As discussed on the webinar, NARA took the first step on April 10, 2019, when it issued regulations covering digitization standards for temporary records, in newly revised sections of Title 36 of the Code of Federal Regulations, Part 1236, Subpart D. As issued in the Federal Register, these new standards authorize agencies to destroy original source records if digitized copies of those records have been made pursuant to standards set out in the regulations, and have been properly validated. Agencies do not need further approval from NARA to go ahead with disposition of original source records if they have complied with the standards and validation measures. See 36 C.F.R. §§ 1236.30-36. NARA also has provided detailed responses to Frequently Asked Questions (FAQ) about NARA’s Digitization Regulation.

NARA also plans to issue future regulations for public comment covering proposed digitization standards for federal records appraised as permanent. There’s no official date for release of the guidance but it is expected in the second half of 2020.

In the meantime, there is a fair amount of helpful guidance already issued by NARA on the subject of digitization. As referenced in NARA’s Records Express Blog (required reading for anyone wishing to keep up with the latest initiatives and guidance in the area of federal recordkeeping), a white paper created by the Federal Records Management Council (FRMC). provides a detailed “Digitization Cost Benefit Analysis,” which looks at the benefits, risks, and challenges of moving from paper to electronic forms of recordkeeping. Additional sample digitization pricing documents are contained on a NARA web page devoted to the work of the FRMC, see https://www.archives.gov/records-mgmt/policy/frmc.

Digitization strategies will continue to form an important part of the overall efforts agencies must make to meet the upcoming 2022 federal deadline, in order to ensure continued long-term preservation of our Nation’s records.

For more on forming a digitization strategy, see the latest webinar with Preservica and History Associates called "Transition to Electronic Government: Planning, Protection and Preservation Strategies for Digitizing Agency Records."

If you missed the first two parts of this blog series, the first post can be found here and the second here.

Jrbaron 2019
Posted by
Jason R. Baron

Jason R. Baron served as NARA’s first Director of Litigation between 2000 and 2013 and is now a lawyer in private practice in Washington, DC.