According to recent announcements on MyIntracomm, the European Commission will introduce an automatic deletion rule on 1 January 2027. Under this policy, more than 300 million working files older than 10 years stored on shared network drives (U, P, O, G) and in M365 collaborative spaces (Teams, SharePoint Online) face permanent automatic deletion on a rolling basis, unless staff manually intervene to identify and save them.
This initiative began in December 2025, when the Information Management Steering Board (IMSB) approved a general approach to optimise digital storage and support corporate AI readiness. In May 2026, the IMSB endorsed a detailed implementation plan prepared by the Centre for Organisational Transformation (COT) and the M365 Core Team. Under this plan, staff are expected to manually review and modify the files they need to keep – or register them in ARES – to “reset the clock” and save them from automatic deletion.
Generation 2004 fully supports building a modern, sustainable document management culture. Cleaning up obsolete data, reducing our environmental footprint, cutting server costs, and making files easier to find are vital goals for our institution.
However, we believe the current implementation plan is rushed. By relying on automatic mass deletion without adequate preparation, the plan places the entire burden and legal risk of losing institutional memory directly onto operational staff and middle management.
What Are the Main Concerns?
1. The stakeholder gap: Good intentions, missing operational input
In modern project management, like the ADKAR model cited in corporate notes), end-users are primary stakeholders. Without structured consultations across services during the preparation phase, decision-makers lacked a complete picture of operational realities, technical constraints, and statutory retention needs.
It is true that corporate retention frameworks already exist – such as the Common Retention List (CRL), archiving rules in ARES, and specific EU Learn courses for different staff profiles. These courses often remain rather theoretical and are not always easily applied to daily workflows. Before resorting to irreversible mass deletion, the administration should actively promote, refine, and operationalise these existing tools across all services.
At the same time, Communication around this initiative has been quite modest. A single MyIntracomm article and two Summer School presentations reaching only a few hundred participants cannot properly prepare an institution of over 32,000 staff. When preparing this article, we spoke with colleagues across various DGs: many were completely unaware of the policy or did not even realise its immediate impact.
2. The math behind the “10-minute review” suggestion
Corporate presentations suggest that colleagues can easily manage this transition with a simple “weekly 10-minute routine.” A look at the basic arithmetic shows that this claim is detached from reality.
The unit-level math: Take a unit of 15 staff members with 30,000 affected files. Even at an optimistic speed of 1 minute per document, 15 colleagues spending 10 minutes a week would process only 150 files weekly. Reviewing the entire backlog would take 200 weeks (nearly 4 years). At corporate level, even assuming 50% are trivial files, 30,000 staff would need at least 10 years of weekly sorting to assess the remaining 150 million files. This calculation does not even include the extra time needed for unit coordination meetings, team alignment discussions, and working group sessions officially recommended in the guidance.
Flawed suggested methods: The solutions officially proposed, such as reviewing thousands of files line by line from centrally provided Excel lists, dividing up file lists among team members to check, registering working drafts into ARES, or manually opening files to edit footers and ‘reset the clock’, are cumbersome manual workarounds. They do not resolve the core issue and make reviewing “orphaned files” from departed colleagues practically impossible.
Budget cuts vs hidden human costs: The financial driver is clear from Working Document VI (p248): the central corporate Storage budget dropped from €8.54M in 2025 to €4.94M in 2026 and is projected to fall to €3.62M in 2027 – a 58% cut in just two years. While reducing IT expenditure is understandable, shifting passive storage savings into hundreds of thousands of lost staff hours is counterproductive. In fact, the implementation plan submitted to the IMSB openly admits that „no analysis of the financial cost/benefit of implementation has yet been possible”. This means that a sweeping policy is being deployed without knowing if server savings will be completely wiped out by the immense human cost.
3. Unrealistic pressure on middle management and support staff
Middle managers only received specific dashboard data and instructions in mid-July 2026, right at the start of the summer holidays.
This leaves only 80 to 90 working days in autumn (the busiest period of the year and the intensive preparations for the next Multiannual Financial Framework (MFF) across many DGs), to complete a massive triage exercise.
Due to everyday workload constraints, this manual sorting often falls on secretarial staff, assistants, or newly arrived colleagues who cannot reasonably know whether a 12-year-old background file is critical for a future audit, court proceeding, or an incoming Access to Documents request from citizens, civil society, or journalists.
If colleagues must work long hours to meet this artificial deadline on top of their core operational responsibilities, Generation 2004 strongly reminds staff and managers that all extra hours must be formally registered as overtime or flexitime. Hidden, unrecorded overtime should not be used to mask the true operational burden of this project.
4. Technical, legal, and security blind spots
The recent corporate FAQ highlights several major operational challenges that have not been safely resolved:
Collaboration with External Service Providers: As a colleague pointed out, external service providers, who operate and maintain key Commission systems, do not have access to internal platforms like ARES, making collaborative shared space essential. In addition, technical units manage hundreds of thousands of project files in complex directory structures where mass migration into ARES is technically unfeasible and would break active maintenance workflows.
Dashboard Errors and IT Helpdesk Load: In Summer School sessions, staff noticed basic metadata errors, such as files marked as modified before they were created. Telling colleagues to log IT tickets for these widespread glitches, risk overloading the IT Helpdesk with massive extra work and unnecessary costs.
Digitally Signed Documents (QES): Opening and re-saving or modifying a PDF to “reset the 10-year clock” invalidates its Qualified Electronic Signature, destroying its legal value in court.
Broken Links: Live administrative manuals, training guides, and team intranets frequently link to background documents on shared drives. Deleting these files will break working workflows.
Complex Data, Scripts: Scientific and economic units rely on scripts (Python, R, Stata) and linked datasets. Changing these files causes code errors.
Special Legal Retention Rules: Many DGs have statutory obligations to retain records for longer periods (e.g., nuclear safety in JRC, health registers in DG SANTE, state aid in DG COMP). While the guidance advises teams to “contact experts or request dedicated DIGIT storage before 1 January”, identifying these needs without a structured audit is almost impossible for local teams. Furthermore, alternative DIGIT storage involves extra procedures and costs.
Data Security, Transparency, Zipping, and Shadow IT: Under extreme time pressure, staff may resort to temporary workarounds, such as compressing entire folders into .zip files to protect them, or saving vital documents onto local C: drives, H: drives, personal OneDrive folders, and external USB storage. Generation 2004 does not recommend these workarounds. They undermine cybersecurity, create version-control chaos, and break GDPR compliance. Everyone shares the common goal of a transparent, structured, and reliable storage environment, but this must be achieved together in the right sequence, with proper corporate solutions, rather than through individual emergency fixes.
The Way Forward: What Needs to Happen in November 2026
True document lifecycle management (DLM) does not start by pushing the burden downwards onto operational staff with automatic deletion. It requires safe technical infrastructure, clear rules, and adequate time.
Primarily, the IMSB should grant an immediate moratorium at its review meeting in late 2026. Postponing the 1 January 2027 deletion rule is an essential step to prevent accidental loss of vital public records, eliminate legal exposure, and relieve staff from artificial workload stress during the autumn peak.
Following this pause, senior management should adopt a structured, step-by-step roadmap to achieve a genuine cultural and infrastructural transition:
- Conduct a comprehensive Commission-wide consultation: Engage in structured dialogue across all services to identify specific operational needs, specialised data workflows, and statutory retention requirements.
- Perform evidence-based risk and cost-benefit analysis: Assess real operational workflows and calculate the true administrative cost of manual file management compared to automated storage solutions.
- Deploy automated cleanup and Automatic Cold Storage: While eliminating obsolete data is essential, this must be managed centrally through automated system tools (such as deduplication and technical file purging) rather than manual staff triage. The remaining inactive files should automatically migrate to secure, low-cost, read-only archival tiers, aligned with the Commission’s own EU eArchiving standards and Member State best practices – slashing storage costs by up to 90% without requiring manual staff hours or risking permanent data loss.
- Provide comprehensive operational guidance and practical tools: Develop detailed, role-specific guidelines and effective IT solutions that go well beyond high-level intranet pages and complex spreadsheets.
- Make practical DLM training mandatory for all staff and newcomers: Roll out hands-on training across all DGs and embed modern document management principles into compulsory induction packages for every new recruit.
- Implement continuous monitoring and targeted support: Track progress across services and provide dedicated assistance to units with large legacy data backlogs.
- Introduce gradual deletion rules only when systems and habits are mature: Enable automatic deletion policies only after safe storage options, clear exception paths, and everyday filing routines are firmly established across all services.
By following this logical roadmap, the Commission can protect its institutional memory while transforming document management from an arbitrary administrative burden into a shared, empowering culture of efficiency.
Help Us Provide Evidence: Complete the Anonymous Staff Survey
To ensure that institutional decisions are supported by objective, real-world evidence from the ground, Generation 2004 has launched a brief, completely anonymous staff survey.
We invite colleagues across all services to take 3–4 minutes to share their actual file volumes, time constraints, and practical readiness.
