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What does the law now require, and has it been met?

Most likely: compliance is partial; the records collection exists but the review and reporting duties have slipped, and…Ahead on the evidence, not yet confirmed. It needs two reviews to be accepted.

Where it stands

Three answers have been proposed. Compliance is partial; the records collection exists but the review and reporting duties have slipped, and… leads, with evidence 2 for: supported by its tests. Two are still possible.

Why it matters

The enacted records provisions and the 2026 guidance set deadlines and duties; whether agencies met them is checkable⁠[1]⁠[2].

Answers 3

None of these.
Not tested enough to call either way
Evidence: none yet
Still possible

History

  1. Greenewald: the FY2025 annual report was delivered months after its statutory deadline.Against: Agencies have complied with the records review, the NARA collection and the annual reporting duties.
  2. DefenseScoop: historical Record Report Volume 2 had not been published as of February 2026.Against: Agencies have complied with the records review, the NARA collection and the annual reporting duties.
  3. DLA Piper: oDNI's own guidance describes the NARA collection as separate from PURSUE.For: Compliance is partial; the records collection exists but the review and reporting duties have slipped, and…
  4. U.S. House Committee on Oversight and Government Reform: the House task force wrote in April 2026 that AARO's responses were less than adequate.For: Compliance is partial; the records collection exists but the review and reporting duties have slipped, and…
  5. Asked on this site
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