I'd like to expand upon some of the messages in my document.
Records are not just required under the Access to Information Act. There is an infrastructure of document management, storage and retrieval that feeds requests under the Privacy Act: discovery and litigation proceedings, public inquiries, written parliamentary questions, questions and requests from House committees and Senate committees, and examinations from over a dozen officers and agents of Parliament. There are lots of people involved in the management, storage and retrieval of documents and records within the Government of Canada. It is quite an undertaking.
I would say that if you want to impose deadlines and penalties, you're pushing on a rope unless there is a lot more investment, care and attention to the issue of records and document management by future governments.