On April 24, 2025, the National Archives and Records Administration announced it had received its first substantive shipment of Unidentified Anomalous Phenomena records — digital files transferred from the Office of the Director of National Intelligence, the Office of the Secretary of Defense, the Federal Aviation Administration, and the Nuclear Regulatory Commission. NARA's press release framed it as a milestone in "transparency," the first public output of a legal mechanism Congress built into the previous year's defense bill. The records went into a newly created Record Group 615, a permanent home at the Archives for what the law calls the Unidentified Anomalous Phenomena Records Collection.
That law — Sections 1841 through 1843 of the 2024 National Defense Authorization Act, Public Law 118-31, now codified at 44 U.S.C. 2107 note — is real, specific, and considerably narrower than what its sponsors originally proposed. It has deadlines. It has disposition rules. What it does not have, based on the public record available today, is a published compliance ledger telling Congress or the public which of the government's dozens of agencies have actually finished doing what the law requires.
What the law actually says — and what it dropped
The records-collection mandate did not start where it ended up. In July 2023, Senate Majority Leader Chuck Schumer and Senator Mike Rounds introduced the Unidentified Anomalous Phenomena Disclosure Act as an NDAA amendment, explicitly modeled on the JFK Assassination Records Collection Act of 1992, according to press releases from both Schumer's office and Senator Todd Young's office at the time. That original version was aggressive: a presumption of immediate public disclosure for all UAP records, an independent presidentially appointed Review Board empowered to approve or postpone releases, and — most strikingly — a government power of eminent domain over "recovered technologies of unknown origin" and biological evidence of "non-human intelligence" held by private companies or individuals.
"recovered technologies of unknown origin"
None of that survived conference. According to a January 2024 client alert from the law firm Cadwalader (published as Inside Government Contracts) and a more recent legal explainer from LegalClarity, the enacted version stripped the Review Board, the eminent domain provision, and even a presidential-certification mechanism that would have let the White House override the 25-year disclosure deadline. What remained was narrower and more procedural: NARA must establish the Records Collection, and by October 20, 2024, every federal agency must review, identify, and organize the UAP records in its custody, per NARA's own guidance page and its February 2024 memo to agency records officers, AC 13.2024. Records can be released in full, released with redactions, or postponed — but postponement requires citing Section 1843 of the Act or a declassification guide under Executive Order 13526, and Congress must be notified within 15 days of any postponement decision. Absent that, disclosure is mandatory no later than 25 years after a record was created — with no certification override left in the final text, according to LegalClarity's reading of the statute.
That gap between the July 2023 amendment and the December 2023 law is worth sitting with, because coverage of UAP "disclosure" often treats the two as interchangeable. They are not. The version that actually passed created an archive with a paper trail, not an open door.
The infrastructure NARA built, on the record
What NARA has done is document its own process in unusual detail for a records-management story. The February 2024 memo (AC 13.2024) alerted agency records officers to the new law. A May 2024 follow-up, AC 26.2024, laid out the actual metadata specification — a spreadsheet template requiring, among other fields, a "UAP Record Identifier" naming scheme, classification level, release status, and a "Refer To" field mandating that the Department of Energy be listed whenever a file contains Restricted or Formerly Restricted Data. A third memo, AC 04.2025, set September 30, 2025, as the deadline for agencies to transfer digital copies of records they had already identified as publicly releasable — and asked agencies to send material on a rolling basis rather than waiting. NARA states plainly that it will only accept digital copies; agencies keep the physical originals under their existing, NARA-approved records schedules.
That last point matters more than it sounds. NARA's own guidance says permanent records "will eventually be transferred to NARA, even if a copy has already been transmitted as part of the UAP collection" — meaning what the public sees in the Catalog today is a released copy, while the underlying original record follows a separate, much slower federal records lifecycle. A schedule NARA approved on August 20, 2025, for the Pentagon's All-domain Anomaly Resolution Office — Records Schedule DAA-0330-2023-0002 — illustrates exactly how slow. Of AARO's four record categories, three are permanent, including its case-by-case UAP reporting files and its congressional briefings. But the physical transfer of those originals to the Archives isn't due until 25 years after each case is closed or each report is submitted to Congress — and the schedule itself flags that the records remain subject to FOIA Exemptions covering national security, deliberative process, and law enforcement information. "Permanent" here is a preservation designation, not a promise of near-term public access.
What the public record does not settle
RG 615's own web page lists seven agencies that have begun transferring material: the FAA, the Nuclear Regulatory Commission, ODNI, the Office of the Secretary of Defense, the National Security Agency, the State Department, and the FBI. NARA describes this as an ongoing, rolling process and says the page will be updated as new transfers arrive. It is not, however, a scorecard — it does not say how many agencies were ever in scope, which ones have finished, or which are still working.
An independent researcher tracking the process through direct FOIA requests, publishing under the name HM05UAP on Substack, attempted to reconstruct that picture as of April 2025 by querying roughly two dozen agencies. The results, as that single, non-official source describes them, were uneven: agencies including the EPA, Fish and Wildlife Service, NIST, the National Science Foundation, and the U.S. Geological Survey reported no responsive UAP records at all. The Air Force and Space Force both initially rejected the FOIA requests as too vague. Requests to the Army, CIA, DIA, NSA, Navy, Marine Corps, and DOE headquarters were still pending. And NASA headquarters, according to the same tracker, reported finding no documents in response to a request about whether it had conducted a review for NARA transfer — a notable gap given NASA's high public profile on UAP through its 2023 Independent Study Team and its appointed Director of UAP Research. None of this is confirmed by NARA itself, and it should be read as one outside researcher's snapshot, not an official audit — but it is the closest thing to a compliance check that currently exists in public view, and it suggests the picture is considerably messier than the RG 615 page implies.
A separate FOIA response to the Department of Energy, reported by The Black Vault, reinforces the pattern: a broad request for three years of UAP-related email to the Secretary produced only two documents, both released in part, with more than half the content withheld under the deliberative-process exemption. The record shows engagement with the topic — congressional briefing material referencing Representative Tim Burchett — but the volume of what surfaced was minimal relative to the scope of the request.
A separate track, often mistaken for this one
A final complication: the high-volume 2026 document releases branded PURSUE — the Presidential Unsealing and Reporting System for UAP Encounters, launched May 8, 2026, at war.gov/UFO under a directive from President Trump — are not a product of the 2024 NDAA's Records Collection. Coverage from TWZ, Lawstreet, and other outlets describes PURSUE as an executive-branch transparency initiative coordinated by the Department of War, ODNI, NASA, the FBI, and the State Department. Nothing in the available record ties PURSUE's rolling tranches formally into the RG 615 statutory pipeline Congress built a year and a half earlier. They may eventually intersect — publicly releasable PURSUE material could, in principle, also satisfy an agency's NDAA obligations — but no document reviewed here establishes that link. Treating the two as one continuous "disclosure effort," as some coverage has, risks crediting a law with an initiative it did not create and cannot compel.
What would resolve this is straightforward: a NARA-published, agency-by-agency compliance table against the October 2024 and September 2025 deadlines, and a public statement from the Archives on whether PURSUE releases are being folded into Record Group 615. Neither exists yet.