Is Your AI Prompt Part of the Contract File?

Open the file for the last action you closed and find everything an AI tool touched. The market research summary you drafted with your agency's assistant. The industry day notes a model cleaned up. The answers to vendor questions you asked it to tighten before release. Now ask the question the National Archives has put in front of every contracting officer: which of those belong in the contract file?

On August 21, 2026, NARA sent agencies its guidance on applying the Federal Records Act to AI materials, memo AC 11.2026. The core of it is short. Using an AI platform does not, in and of itself, create a federal record. What you do with the output afterward can.

I've spent decades in federal procurement, and the contract file has always been where an acquisition proves what happened. AI doesn't change that job. It changes how many drafts exist before the final one, and who, or what, wrote them.

Does using an AI tool create a federal record?

Not by itself. NARA lists the circumstances that turn recorded information into a federal record. The question is whether the agency used it in official business, relied on it in decision making, circulated it to others, integrated it into an agency system, controlled it, or must keep it to meet a business or legal obligation.

Then the memo gets specific.

Likely records

Prompts captured in an agency system and circulated or used for official purposes beyond personal convenience
AI meeting summaries that are circulated or serve as the official record
Outputs saved in an agency system and used for official business

Likely non-records

Query results nobody acted on
Audit trails kept only to refresh your own memory
Meeting notes you never shared
Commercial AI software itself, such as ChatGPT or Gemini, unless an agency significantly modifies it

"The fact that AI was used is secondary." National Archives and Records Administration, AC 11.2026

That is the sentence I'd underline. If AI helped draft your market research report, the schedule that governs that report still governs. For procurement records, NARA's appendix points to General Records Schedule 1.1, item 010.

Where does the line fall in a real acquisition?

Most AI use in a contracting office will land in two categories NARA names. A transitory record is needed for less than 180 days and isn't needed to meet financial or legal obligations (GRS 5.2, item 010). An intermediary record is used to create a later record and can be destroyed once that record exists (GRS 5.2, item 020).

Walk one action through it. You ask a model to summarize three public capability statements for market research. You read the summary, check it against the source documents, and write your own report. The summary looks like an intermediary record, and your report is the record that matters. Change one fact: you paste the summary into the report unedited and send it to the program office. Now the agency relied on it and circulated it.

The prompt follows the same logic. A one-off question you never used is a non-record. A prompt your office saves and shares as the standard way to draft a determination is a record, and NARA lists it as one.

I'd add one practice of my own, and it's a recommendation, not a NARA requirement. If a file reviewer or your successor would need to know AI shaped a document to understand it, write that down next to the document.

Which prompts make the sorting routine?

Three prompts. The first two belong in your agency's approved tool. The third runs on a public document.

Prompt 1: How do I sort the AI materials from one action?

Run it at closeout or at each milestone. It takes descriptions, not content.

Below is a list of AI materials from one acquisition action.
Each line gives the type of material (prompt, output, summary,
or audit trail), what I did with it (used in a decision,
circulated, saved to an agency system, or nothing), and who
saw it. There is no document text, no vendor names, and no
source selection information.

Apply these factors from NARA's August 2026 guidance: used in
official business, relied on in decision making, circulated,
integrated into an agency system, needed for business or legal
obligations.

Label each line LIKELY RECORD, LIKELY NON-RECORD, or ASK
RECORDS OFFICER. Name the factor that drove each label. If a
line looks like a transitory or intermediary record, say so.

Customize it by adding your office's file plan headings at the end, so each label also says where the item goes.

Prompt 2: How do I write the AI file note?

Draft a file note of no more than 120 words for (name of the
document). State the AI tool used and whether it is
agency-approved, the date, what the tool was asked to do, what
I checked against source documents, and what I changed. Do not
include vendor information or source selection information.
Write in plain language for a reviewer who was not involved.

Keep the note in the file next to the document it describes.

Prompt 3: How do I build a one-page desk guide from NARA's memo?

Below is NARA's guidance on applying the Federal Records Act
to AI materials. Turn it into a one-page desk guide for a
contracting office. Use four sections: what counts as a
record, what usually does not, what to save and where, and
when to ask the records officer. Use short sentences. Quote
NARA where the exact words matter. List the General Records
Schedule items NARA cites for procurement, transitory, and
intermediary records.

Give the draft to your records officer before anyone uses it. NARA is explicit that each agency has principal responsibility for deciding what is a record.

What should a contracting office do this quarter?

For contracting officers and contract specialists, four steps:

Pick one action closing this month and run Prompt 1 on its AI materials.
Agree with your records officer on where AI file notes go.
Move your office's shared prompts into one agency-controlled location. If they're circulated and used for official work, they're likely records already.
Add one line to your closeout checklist: AI materials sorted.

Does this apply to contractors who support acquisition offices?

Read the definitions closely. NARA's definition of "made" covers contractors working on the agency's behalf. The drafts you produce with AI for a contracting office sit inside this guidance, so ask your COR how they want AI use documented before a reviewer asks you.

What stays with the human?

Every prompt here is a starting point, not a replacement for your own judgment. AI drafts, flags, and speeds the record. You still read what it gives you, check it against the source documents, and own the decision that carries your name. Used as autopilot, it just helps you be wrong faster.

Where can I learn what is safe to put into an AI tool?

Knowing what can go into which tool, and what you have to keep afterward, is now part of the daily work of anyone who touches a contract file. Module 1 of Commercial GenAI for Public Sector Procurement, Using GenAI Safely in Government Procurement, is open for enrollment at $395 per module, with approximately 3.5 contact hours, five knowledge checks, and a 20-question test. Eligible for approximately 3.5 CLPs as self-directed study, subject to agency approval — The Wolverine Group is not an accredited CLP/CEU provider. Agencies can pay by purchase card or purchase order. Module 2, Regulatory Compliance Across Government Levels, is now open, and records management is one of the topics it covers.

Choose a module →