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Smart Bulletin No. 025

GSA SmartPay-Record Retention Requirements


DateVersion History Action Log - Summary of Action/Changes
September 10, 2015Implementation of Smart Bulletin #25
October 25, 2023Revised for administrative format change(s)
Revised to incorporate updated guidance
March 22, 2024Revised for administrative updates

Effective Date

From Issuance until superseded.

Business Line(s) Affected

Purchase, Travel, Fleet, and Integrated


The purpose of this GSA SmartPay® Smart Bulletin is to inform customer agencies of the record keeping requirements under the GSA SmartPay® program.


The purpose of this Smart Bulletin is to generally describe records retention requirements and to allow reductions in the retention period for specific classes of records under prescribed circumstances. In addition, this Smart Bulletin will highlight the changes that affect the GSA SmartPay government-wide charge card program and provide direct links to the resources available from The National Archives and Records Administration (NARA). Any future updates that may affect record retention for the GSA SmartPay program will be added to this Smart Bulletin as they become available. In addition to the record retention requirements of FAR Part 4.703 Contractor Records Retention, the Contractor shall serve as the document repository agent for all GSA SmartPay transactions. The Contractor shall maintain electronic records of all transactions for a period of six (6) years after final contract payment.


FAR Part 4.703 Contractor Records Retention

NARA GRS 4.1 Records Management Records

GSA SmartPay Master Contract (C.7.2.4 Record Retention and Retrieval)[PDF, 248 pages]


A/OPCs and cardholders should familiarize themselves with the updates and new GRS 1.1 provided in Transmittal 23. Some of these changes affect the record retention of documents associated with the use of the GSA SmartPay program. For questions related to the GRS, please contact the NARA Office of the Chief Records Officer at

The Center for Charge Card Management (CCCM) will work to negotiate modifications to the GSA SmartPay Master Contracts to reflect the GRS 1.1 updates once the FAR Council has made any necessary changes to FAR 4.703, which governs record retention requirements for contracts.

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