Take Advantage of the

M-19-21 Directive
M-19-21 Federal Storage

Take Advantage of the

M-19-21 Directive

Transitioning to an Electronic Records Platform: Taking Advantage of the M-19-21 Directive

On June 28, 2019, the Office of Management and Budget (OMB) in conjunction with the National Archives and Records Administration (NARA) issued M-19-21, Transition to Electronic Records. M-19-21 specifically describes the steps that agencies must take to meet the goal of transitioning business processes and recordkeeping to a fully electronic environment, and end NARA’s acceptance of paper records by December 31, 2022.

Milestones to Compliance

  • December 31, 2022:
  • ✓ All permanent and temporary records will be managed electronically
    ✓ All agencies must close agency-operated records storage facilities and transfer inactive, temporary records to Federal Records Centers or commercial records storage facilities

  • January 1, 2023:
  • ✓All transfers of permanent records must be in electronic format


The deadline is quickly approaching and to successfully achieve M-19-21 compliance, it is essential that agencies develop a solid plan for their records maintenance, digitization strategy, and storage program. As a leader in the industry with 70 years of experience, we can help your agency develop a plan and provide solutions to achieve M-19-21 compliance. Here are some recommended actions to consider:

Contract Vehicles

Iron Mountain has an extensive ecosystem of associate companies, both large and small, providing access to various contract vehicles including SEWP, CIO-SP3, and the VA T4NG.

Contact us to learn how you can acquire Iron Mountain Records, Data Management and Document Imaging Services through GSA Schedule 36 Number GS-03F-049GA.
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Start With A Thorough Self-Assessment

Conduct a comprehensive inventory of your records volumes by format. Understand their retention requirements, digitization status, records workflows, access requirements, and geographic needs to help prioritize and take action.
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Know Your Options

Explore storage options including with NARA, a commercial vendor, and/or in-house, as well as developing a digitization strategy to migrate workflows and implement consistent protocols for applying retention schedules – all while considering staff and budget constraints.
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Set A Plan For M-19-21 And Beyond

It is imperative that agencies have an end goal in mind and establish an overall plan and timeline not only for M-19-21, but for continued digital transformation as technologies evolve.

For most, this is proving to be a daunting task, but agencies have an opportunity to take advantage of this transition to advance digital transformation efforts and drive efficiencies that deliver significant cost savings.

Know Your Options

Option Pros Cons Recommended Situation
A. Transfer Records to a NARA Federal Records Center (FRC) More cost effective than a full digitization project

Meet OMB efficiency goals of re-focusing staff and resources to mission critical activities
FRCs near capacity

Local FRCs may not be an option, requiring expensive shipping to far locations and additional time for records services

More costly than a commercial provider
Low-activity permanent records or temporary records scheduled to be dispositioned soon
B. Transfer Temporary Records to Commercial Storage Facility More cost effective than a full digitization project

Meet OMB efficiency goals of re-focusing staff and resources to mission critical activities

Less costly, improved SLAs and/or custom Records Management (RM) programs

May have options for small scale digitization projects later
Requires proper research and vetting of commercial providers

No digitization means agencies will not benefit from automation / data analytics
Low, Mid, or High-activity temporary records not due for disposition soon
C. Store In-House / Offices Meets goals of closing records centers

Keeps records within agency walls and control.
Costly use of office space and agency staff to manage records in new location

Does not meet OMB efficiency goals of re-focusing staff and resources to mission critical activities
Agencies that need to maintain control / access to records
D. Destroy Old or Unneeded Records Saves on future storage costs

Ensures collection is in compliance with current retention schedule
Potentially high up-front cost Agencies still storing older or unnecessary records, or those that have quality digital copies.
E. Digitize Now Meet overarching goals to transition to a more digital government now

Enables automation / data analytics

Leverage GSA & NARA’s partnership to procure comprehensive storage and digitization solutions
Can be very costly

Requires thoughtful digitization strategy to ensure agency achieves optimum ROI

Requires coordination with multiple cross-department stakeholders to ensure success (IT and Records Management)
High-activity temporary records that feed into processing workflows

Government Solutions Portfolio

We help agencies digitally transform to meet the 2022 deadline, while implementing next-generation technologies that generate insights and unlock the value of information. Our solutions include:

Additional Resources

Premium Content Multimedia Achieving M-19-21 Compliance: Self Assessment Video

Achieving M-19-21 Compliance: Self Assessment Video

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Premium Content Datasheets and Brochures Transitioning to a Digital Government

Transitioning to a Digital Government

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Premium Content Whitepapers Achieving M-19-21 Compliance

Achieving M-19-21 Compliance

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Contact Iron Mountain

Our Customer Support section can help provide you with the quickest answers to your questions, or feel free to contact us at your convenience

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Contact Iron Mountain

Our Customer Support section can help provide you with the quickest answers to your questions, or feel free to contact us at your convenience