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NARA M-23-07 and the End of Paper: What Pennsylvania County Records Offices Need to Know
OMB/NARA memorandum M-23-07 ended paper transfers of permanent federal records: since June 30, 2024, the National Archives accepts records in electronic format with required metadata only. The mandate applies to federal agencies, not counties — but county and municipal offices that administer federal funds carry records obligations in their award terms, and the all-digital standard is becoming the baseline government-wide. Pennsylvania offices that digitize to PDF/A under PHMC standards meet both directions of travel at once.
On June 30, 2024, the National Archives and Records Administration stopped accepting paper. Under OMB/NARA memorandum M-23-07, federal agencies now transfer permanent records to NARA in electronic format with required metadata only — the close of a transition that began with memorandum M-19-21 in 2019. No Pennsylvania county is a federal agency, and M-23-07 does not bind a county records office directly. But records managers in county and municipal government should read the memo anyway, for two reasons: the obligations that already reach local government through federal funding, and the unmistakable direction of travel for public records everywhere.
What does M-23-07 actually require?
M-23-07, issued jointly by the Office of Management and Budget and NARA in December 2022, updated the federal government's transition to electronic records. Its central requirement: after June 30, 2024, agencies manage all permanent records electronically, and NARA accepts transfers of permanent records only in digital form with the metadata prescribed under 36 CFR Part 1236, with limited exceptions. Agencies that still hold analog records must digitize them to NARA's standards before transfer. The memo turned digitization from a modernization initiative into the only path records can take into the National Archives.
Why does a federal memo matter to a Pennsylvania county?
Directly, it does not — county and municipal records in Pennsylvania are governed by state law and the retention schedules set through the Pennsylvania Historical & Museum Commission. The connection runs through money and through precedent. County offices administer federal dollars constantly: community development block grants, emergency management reimbursements, transportation funds, public health programs. Those awards carry records requirements in their terms — the Uniform Guidance at 2 CFR 200.334 requires financial records and supporting documentation to be retained for at least three years from the final expenditure report, and they must be producible when a federal program office or auditor asks. An office whose award files are digitized, indexed, and searchable answers that request in minutes. An office with paper in a basement does not.
The precedent matters as much as the program terms. M-23-07 established that the operating standard for public records in the United States is digital, with metadata, in archival formats. State and local requirements have historically followed where federal records policy led — offices that digitize now are aligning with where every level of government is headed, not chasing a deadline after it arrives.
How do PHMC standards fit with the federal direction?
Pennsylvania's own records authority already points the same way. PHMC's records management standards for local government specify retention schedules and archival digitization practices, with PDF/A as the archival format — the same format family NARA's transfer guidance is built around. That overlap is the practical good news for a county records office: one properly executed digitization program satisfies both directions of travel. Records scanned to PDF/A with capture metadata and full-text indexing meet PHMC's archival expectations, support federal award documentation duties, and position the office for whatever electronic-records requirements arrive next — while also making day-to-day obligations like Right-to-Know responses dramatically faster.
What should a county records office do now?
Three moves, in order. First, inventory: identify which record series hold federal award documentation, which are permanent under PHMC schedules, and which are still paper-only. Second, prioritize the overlap — series that are both permanent and federally connected are the ones where digitization pays twice. Third, digitize to the archival standard the first time: PDF/A, capture metadata, full-text indexing, and quality control documented well enough to stand behind in an audit. Converting to a convenience format and re-converting later is the expensive path.
M-23-07 did not create a deadline for counties. It announced where public records are going — and the offices that digitize to archival standards now will not have to be told twice.
Why Reynolds
Reynolds Business Systems has digitized records for more than 30 Pennsylvania counties and municipal offices from our Emmaus headquarters in the Lehigh Valley — family-owned since 1970, with a 100% client retention rate, a 14-year average staff tenure, and a 100% accuracy guarantee. We scan to PHMC standards including PDF/A, index for full-text retrieval, and deliver into Laserfiche as a Laserfiche-certified partner, so award files, permanent series, and active records are searchable, redaction-ready, and audit-defensible. Pennsylvania local entities can purchase through COSTARS without a separate competitive bid. To scope a digitization program for your office, call (610) 398-9080 or request an assessment at /contact.
Sources Cited
5 REFS- Executive Office of the President, Office of Management and Budget
- National Archives and Records Administration
- Pennsylvania Historical & Museum Commission (PHMC)
