On June 26, 2026, DoW Chief Information Officer Kirsten Davies signed DoW Instruction 5015.02, officially superseding the 2015 version of DoD Instruction 5015.02. For records management, information governance, AI, IT, legal, and compliance leaders across government, this reissue offers an early look at where NARA-aligned policy is heading.
Here are the five biggest changes agencies need to understand:
- AI-generated content is now a records management responsibility. The Under Secretary of War for Research and Engineering shares responsibility with the DoW CIO for developing policy on records created through data, analytics, and AI capabilities (Section 2.3). Records officers must treat AI processes as a trigger for schedule updates (Section 3.1.a.2.b).
- Electronic records management is now the default. Analog retention requires explicit NARA approval (Section 3.1.n.1). All other records need structured, searchable metadata covering disposition, ownership, and content.
- Automation is now a mandate. Section 3.1.b directs Components to dedicate resources to records management, redesign schedules to enable automation, and build records requirements into IT acquisition from the outset.
- Personal messaging now has a hard 20-day deadline. Employees must forward business records from non-official accounts to their official account within 20 days of creation or transmission (Section 3.1.a.6).
- This is likely a preview of government-wide policy. Agencies outside the Department of War should expect similar NARA-aligned requirements to extend across other departments.
Why Does DoW Instruction 5015.02 Treat AI-Generated Content as a Records Management Issue?
In practice, this recognizes that generative AI tools, analytics pipelines, and AI-assisted decision systems produce a category of federal record that most current schedules were never built to cover. Agencies deploying and scaling AI should expect FOIA requests, litigation holds, and NARA reviews to eventually test whether AI-generated content was captured, scheduled, and retained appropriately.
What Does the Shift to Electronic Records Actually Require?
Records must be captured, tagged, and governed with metadata that supports search, identification, and retrieval for information exchange. Agencies that have relied on end users to judge whether something qualifies as a record will need to close that gap under this standard.
What Does the Automation Mandate Look Like in Practice?
The instruction also calls for staffing records teams with systems engineering and data management skills alongside archival expertise. Together, these provisions describe a records program built to run with minimal reliance on individual users correctly identifying and filing records.
How Can ZL Tech Help Agencies Meet DoW Instruction 5015.02 Requirements?
ZL Tech's in-place information governance platform identifies, tags, and governs records, including electronic messages, AI-generated content, and other unstructured data, directly where they live without creating unnecessary copies. Several capabilities map closely to this reissue:
- Content-aware classification flags and schedules new AI-produced record types, supporting the review requirement in Section 3.1.a.2.b.
- Automated disposition applies records schedules programmatically across email, chat, and file systems, aligned with the automation mandate in Section 3.1.b.
- Metadata and full content capture supports search, identification, and retrieval across custody transfers, consistent with Section 3.1.c.
- E-comms governance supports the deadline-driven forwarding and retention that Section 3.1.a.6 now requires.
For agencies preparing for a SAORM review, an IG audit, or an upcoming NARA compliance check, DoW Instruction 5015.02 offers a preview of the standard federal records programs will be measured against.
