GovKM

GovKM Proposed Standards and Guidance

Keep Meaning and Controls Intact Across Systems

Plan and verify information exchanges so sources, versions, dates, references and required controls remain usable.

GovKM-proposed public draft. Published for public review. Not externally accredited or endorsed.

View the EICARS framework resource

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EICARS implementation guidance — proposed public draft. Checklist coverage: R07.1, R07.2, R07.3, R07.4. Prepared November 9, 2026. These suggested approaches support the published GovKM-proposed EICARS v0.1 draft; they do not add requirements or grant external accreditation.

Purpose and use

Plan and verify information exchanges so sources, versions, dates, references and required controls remain usable.

Use this guide within a declared organizational scope, with existing repositories and suitable organizational processes. AI is optional. Examples and suggested evidence are implementation aids; the published standard governs a conformance assessment. The Riverton case below is fictional, not an observed deployment or test result.

Responsible roles

Enterprise architecture, system and integration owners, with business, records and security acceptance.

Assign responsibilities through the organization’s actual instruments. A suggested role in this guide does not itself confer decision authority.

R07.1 Document cross-system exchanges

Suggested approach: Document the information that must survive each participating exchange: identity and version, meaning, dates, approvals, references, access restrictions and lifecycle context where relevant. Map existing fields and identify which system enforces each control. An export specification should describe business meaning as well as file structure.

Riverton example: Riverton’s project view references inspection and IT sources. The mapping explains which dates are assessment dates and which office owns approval, rather than treating similarly named fields as interchangeable.

Evidence and completion check: Retain the mapping and owner approval. Walk through one exchange and explain how an authorized recipient interprets every material field and control.

R07.2 Provide usable export or exchange

Suggested approach: Provide a documented, usable way to exchange or export necessary information and context. Prefer documented open formats where suitable, while meeting preservation and security needs. Check that the route is actually available under the organization’s configuration and permissions. A flat file may be adequate for a small register but inadequate for complex records.

Riverton example: Riverton can export the briefing’s reference list and retrieve the required source revisions through controlled routes. It does not assume a PDF export preserves all original formulas or history.

Evidence and completion check: Demonstrate the exchange with representative approved material. Retain format and access instructions, dependencies and a description of information that the route cannot carry.

R07.3 Verify exchanges and migrations

Suggested approach: Test representative exchanges or migrations against expected business outcomes agreed in advance. Include versions, attachments, dates, references, permissions and lifecycle requirements that matter to the destination use. Reconcile the transferred population and investigate omissions. A successful file transfer is only one part of acceptance.

Riverton example: Riverton moves an approved test inspection file and checks that the correct revision remains locatable, the reference works and an unauthorized user remains denied access.

Evidence and completion check: Keep the test population, expected outcomes, source-to-target observations, exceptions and acceptance decision. Include negative access checks without using real protected personnel data.

R07.4 Identify exchange losses

Suggested approach: Record unsupported fields, degraded content and control losses in an exchange exception record. Identify the dependent uses affected, assign remediation and obtain responsible acceptance where permitted. Do not claim a requirement is satisfied merely because the organization accepts a risk. Keep the existing source authoritative when appropriate.

Riverton example: An export omits Riverton approval evidence. Staff retain the source and limit the receiving view until the approval reference is available; they do not present the export alone as an approved report.

Evidence and completion check: Show one exchange limitation and its treatment. Verify a correction before dependent use, or document that the affected use remains restricted and the requirement remains not demonstrated.

Evidence and completion checks

Agree the population, expected results and acceptance conditions before assessing. Record the date, assessor, evidence reference, observed result and limitation. Use approved safe examples for access, malicious-content or lifecycle tests. Documented policy and observed operating behavior are both relevant; one does not automatically prove the other.

On smaller screens, scroll the table horizontally to view every column.

ItemSuggested evidence and demonstration
R07.1Retain the mapping and owner approval. Walk through one exchange and explain how an authorized recipient interprets every material field and control.
R07.2Demonstrate the exchange with representative approved material. Retain format and access instructions, dependencies and a description of information that the route cannot carry.
R07.3Keep the test population, expected outcomes, source-to-target observations, exceptions and acceptance decision. Include negative access checks without using real protected personnel data.
R07.4Show one exchange limitation and its treatment. Verify a correction before dependent use, or document that the affected use remains restricted and the requirement remains not demonstrated.

Record a gap where the required outcome is not demonstrated. Assign an owner and review date, then verify any correction. Completion of this page alone does not demonstrate conformance with all ten domains, certify legal compliance, approve an AI deployment or authorize autonomous actions.

Common mistakes

Accepting file counts as proof of fidelity; silently dropping approval fields; assuming destination permissions match the source.

Continue the checklist

Use this page with the EICARS standard, the identity guide and the full Riverton scenario. No particular product, model or repository migration is required.

Implementation overview

Suggested operating approach: assign the responsible roles, confirm applicability, implement suitable controls in the existing environment, examine operating evidence and track unresolved gaps. Tailor the methods to scale and risk. Maintain current services during preparation and preserve records, access and legal obligations throughout.

Standards traceability and references

Government Authority and References

U.S. federal reference review: November 9, 2026. These are GovKM mappings of relevance, not government endorsement or a legal compliance determination. Statutes and regulations are mandatory only within their scope; federal policy applies to covered agencies and uses; technical guidance and voluntary resources require the stated selection, adoption or contractual basis. Private and nonfederal organizations must identify their own governing requirements.

The eCFR is authoritative but unofficial. Retrieved Title 36 pages displayed currency through November 5, 2026. Source retrieval does not establish exhaustive legal currency or clause-level implementation compliance. Check current agency supplements, deviations, court orders, schedules, contracts and later amendments. Add the organization’s actual instruments and the qualified official’s applicability determination.

R07.1 — Document cross-system exchanges

  • 36 CFR 1236.12 — Electronic records controls

    Issuing body: National Archives and Records Administration. Pinpoint: 1236.12(a), (d). Relevance: Controls and interchange.

    Classification: Regulation — mandatory when applicable. Applicability: Federal agency records within the source’s statutory and regulatory scope. Not a general obligation on private organizations.

  • 36 CFR 1236.14 — Electronic records controls

    Issuing body: National Archives and Records Administration. Pinpoint: 1236.14(b). Relevance: Migration context.

    Classification: Regulation — mandatory when applicable. Applicability: Federal agency records within the source’s statutory and regulatory scope. Not a general obligation on private organizations.

  • NIST SP 800-53 Revision 5 with Release 5.2.0

    Issuing body: National Institute of Standards and Technology. Pinpoint: CA-3, AC-4. Relevance: Exchange controls.

    Classification: Government technical guidance — conditional on selection or adoption. Applicability: Selected controls, baselines, tailoring and applicable policy or contracts determine obligations. Not every catalog control is universally mandatory.

GovKM recommendation boundary: The cited sources support the underlying governance outcome. This checklist’s packaging, evidence register and assessment format are GovKM recommendations unless separately adopted.

R07.2 — Provide usable export or exchange

  • 36 CFR 1236.12 — Electronic records controls

    Issuing body: National Archives and Records Administration. Pinpoint: 1236.12(d). Relevance: Interchange formats.

    Classification: Regulation — mandatory when applicable. Applicability: Federal agency records within the source’s statutory and regulatory scope. Not a general obligation on private organizations.

  • NARA Bulletin 2014-04 as revised — Transfer formats

    Issuing body: National Archives and Records Administration. Pinpoint: current transfer-format tables. Relevance: Permanent transfer formats.

    Classification: Agency bulletin — requirements within stated transfer scope. Applicability: Permanent electronic records transferred to NARA.

  • 44 U.S.C. 3506 — Information resources management responsibilities

    Issuing body: U.S. Congress; Office of the Law Revision Counsel. Pinpoint: (b)(6). Relevance: Scoped open-format duties.

    Classification: Statute — mandatory when applicable. Applicability: Agencies covered by the Paperwork Reduction Act definitions and relevant subsections.

  • OMB M-25-22 — Federal AI acquisition

    Issuing body: Office of Management and Budget. Pinpoint: section 4. Relevance: AI portability.

    Classification: Federal policy — mandatory provisions within stated scope. Applicability: Covered Federal AI acquisition; obligations flow to vendors through applicable procurement instruments.

GovKM recommendation boundary: Open-format duties and permanent-transfer specifications have different scopes. Neither authorizes public release of protected information.

R07.3 — Verify exchanges and migrations

  • 36 CFR 1236.14 — Electronic records controls

    Issuing body: National Archives and Records Administration. Pinpoint: 1236.14(b). Relevance: Migration preservation.

    Classification: Regulation — mandatory when applicable. Applicability: Federal agency records within the source’s statutory and regulatory scope. Not a general obligation on private organizations.

  • NIST SP 800-53 Revision 5 with Release 5.2.0

    Issuing body: National Institute of Standards and Technology. Pinpoint: CA-3, SA-11. Relevance: Exchange and testing.

    Classification: Government technical guidance — conditional on selection or adoption. Applicability: Selected controls, baselines, tailoring and applicable policy or contracts determine obligations. Not every catalog control is universally mandatory.

  • NIST SP 800-53A Revision 5 with Release 5.2.0

    Issuing body: National Institute of Standards and Technology. Pinpoint: assessment planning and procedures. Relevance: Assessment methods.

    Classification: Government technical guidance — conditional on selection or adoption. Applicability: Security/privacy control assessment; broader application is an adaptation.

GovKM recommendation boundary: The representative test and selected artifacts must fit the declared exchange; these references do not approve every migration automatically.

R07.4 — Identify exchange losses

  • 36 CFR 1236.14 — Electronic records controls

    Issuing body: National Archives and Records Administration. Pinpoint: 1236.14(b). Relevance: Metadata preservation.

    Classification: Regulation — mandatory when applicable. Applicability: Federal agency records within the source’s statutory and regulatory scope. Not a general obligation on private organizations.

  • OMB Circular A-123 revised March 10 2026

    Issuing body: Office of Management and Budget. Pinpoint: section IV(C), (E). Relevance: Deficiency correction.

    Classification: Federal policy — mandatory provisions within stated scope. Applicability: Executive agencies as defined in its Applicability section.

  • FAR 4.802 — Contract files

    Issuing body: Federal Acquisition Regulatory Council. Pinpoint: 4.802(b), (d). Relevance: Decentralized files.

    Classification: Regulation — mandatory when applicable. Applicability: Covered Federal contract files; agency supplements and deviations apply.

GovKM recommendation boundary: The acceptance rule for losses is an EICARS recommendation. Retaining multiple repositories does not remove any applicable controls.

Federal AI-use, high-impact AI, AI-acquisition and covered LLM procurement requirements have distinct scopes and exceptions. Information preparation does not substitute for any applicable AI-use risk acceptance, information-system authorization, procurement or legal decision.

This section gives relevant official references for each covered checklist item and is not an exhaustive list of every possible obligation. The actual agency, program, records, data, system and contract determine additional duties. The EICARS organization of these tasks, suggested registers and completion checks remain GovKM recommendations unless independently required or adopted.

Version history

November 9, 2026 — Publication authorized by GovKM. Guidance based on checklist and government authority reference package checked November 5, 2026. References must be periodically revalidated.

November 9, 2026 — Expanded implementation guidance, version 0.1. Replaced the shorter implementation text with the reviewed Riverton examples, task-specific approaches, evidence checks and official authority mappings, with Robert Noyes’s approval. Existing URLs and checklist anchors are preserved. No EICARS requirement or GovKM doctrine is amended.