FBI Seeks to Renew Its Summary Arrest Forms: 3,381 Agencies, a 'Voluntary' Label and a Nov. 10 Deadline

Three years ago, the FBI told the public that its monthly arrest-count forms were mandatory for the agencies that file them [2]. The renewal notice it published on September 11 calls them voluntary [1]. The forms are the same two, 1-708 and 1-708a, and the 60-day window to comment on keeping them closes November 10 [1].

What the FBI is asking OMB to approve

The forms record the age, sex, race and ethnicity of people arrested, one for arrestees under 18 and one for those 18 and older [1]. The FBI’s Criminal Justice Information Services Division collects them for the Uniform Crime Reporting Program under the Uniform Federal Crime Reporting Act of 1988 and 28 CFR 0.85(f), as the national clearinghouse for crime statistics [1]. The request is a plain extension: no new questions, no new forms [1].

The numbers in the notice are where the story is.

The FBI now estimates about 3,381 federal, state, local, tribal and territorial agencies file each form monthly, for 40,572 responses per form and 81,144 in all [1]. It puts the time at 15 minutes for the 1-708 and 12 minutes for the 1-708a, for 18,257 burden hours a year [1]. The burden table lists the annual frequency as 1, though the arithmetic beside it multiplies by 12 months [1].

Compare the last two renewals. In July 2020 the FBI estimated 8,054 responding agencies and about 39,886 burden hours [4]. In September 2023 it estimated 4,800 agencies and about 25,920 hours, and described the obligation to respond as “mandatory per 28 Code of Federal Regulations 0.85(f)” [2]. The 2026 notice cites the same regulation in its abstract and says, under the obligation heading, “The obligation to respond is voluntary” [1]. It gives no reason for the change.

Who still fills these out, and why the count keeps falling

The shrinking respondent count tracks the slow retirement of the old Summary Reporting System, or SRS. On January 1, 2021, the FBI tried to move every agency to the National Incident-Based Reporting System, NIBRS, and only about 66% were ready to report 2020 data that way [7]. In 2022 the FBI went back to accepting both formats [7].

The FBI’s 2025 crime report, released in August, shows where that left things. Of the 17,075 agencies whose data were published, 15,099 reported through NIBRS and 1,976 through SRS [5]. The SRS agencies covered 6.7% of the population, down from 8.4% the year before [5].

Those 1,976 agencies and the notice’s 3,381 respondents are different measures, and the notice does not say which system its respondents use [1, 5]. A records unit that still files summary reports should not assume the forms are about to disappear. Nothing in the notice sets an end date.

The difference between the systems matters for what arrest numbers mean. Under SRS, an agency reported only the most serious offense in an incident, the hierarchy rule, and the FBI collects only arrest counts for the 20 Part II offenses [6]. NIBRS allows up to 10 offenses per incident and records arrestee demographics as part of the incident [5]. The FBI’s own report cautions that its aggregated NIBRS categories “may not be directly comparable” to the violent crime figures in Crime in the United States [5].

What it means for a records unit

For an agency still on summary reporting, the renewal keeps the monthly routine as it is. Two forms, 15 and 12 minutes each by the FBI’s estimate [1]. The forms feed national arrest tables; the 2025 report’s year-over-year arrest trends drew on 13,286 agencies that sent 12 full months of arrest data for both 2024 and 2025, and showed juvenile violent crime arrestees falling from 39,117 to 37,156 [5].

The voluntary label is less of a change on the ground than it reads. Participation in the FBI’s crime data collection is voluntary for law enforcement agencies, Stateline reported in May [8], and CRS described submitting either SRS or NIBRS data as “currently voluntary” in 2025 [6]. The 2026 notice now matches that description. What it does not do is say whether anything else about the FBI’s view of 28 CFR 0.85(f) has moved.

The move to NIBRS has a price. CRS cited a South Carolina agency with 101 sworn officers that was quoted up to $200,000 in initial costs plus annual maintenance [7]. From FY2018 through FY2021, some Byrne JAG recipients had to put 3% of their awards toward NIBRS compliance; CRS says no set-aside has been explicitly required since FY2022 [7]. The National Crime Statistics Exchange has offered 11 grant opportunities totaling $121.3 million since 2010 [7].

Where the pressure on summary reporting comes from

CRS laid out the options it saw for Congress. Lawmakers “could also consider legislating a new deadline past which the FBI will no longer accept SRS format data,” or make parts of law enforcement grant programs conditional on the transition [6]. They “could also opt to do nothing” [6].

The case against a hard deadline rests on cost. CRS wrote that the transition “may be especially difficult for smaller, or lower funded, agencies to achieve,” and that “some stakeholders fear that jurisdictions that struggle with the transition to NIBRS may be denied funds” [6]. Some agencies have also worried that counting every offense in an incident will make crime look higher. CRS said studies found no significant change in reported crime rates, though low-crime places can still see notable percentage increases [6].

The data side has its own problem. Summary agencies covered 22.9 million people in 2025 [5]. Their arrest counts arrive on a form that records less than an incident report does.

What I’m watching

November 10. The 60-day comment period closes [1]. In the 2023 cycle, the FBI followed with a 30-day notice two months later, sending comments to OMB through reginfo.gov under control number 1110-0005 [2, 3]. Records managers who think 15 and 12 minutes understate the work have until then to say so [1].

The SRS sunset question. No end date has been announced, and CRS wrote that “it is not clear how long SRS data will continue to be accepted” [7]. OMB approval of a collection like this one runs no more than three years before it has to be renewed again [3].