Arizona Public Records Law

Response Timeline

No fixed statutory deadline. Agencies must respond 'promptly' (A.R.S. § 39-121.01(D)(I)). What constitutes 'prompt' varies by complexity. Failed legislative proposal (HB2808) would have required 5 business days. In practice, many agencies aim for 5-10 business days. Failure to respond promptly is deemed a denial.

No residency requirement. 'Any person' may inspect public records (A.R.S. § 39-121).

How to Submit a Request

Accepted Methods

• Written — No specific format required
• Oral — Oral requests permitted
• In person — May inspect during regular office hours

No specific form required. Records must be open for inspection 'at all times during office hours' (A.R.S. § 39-121.01). Cannot require requester to state purpose.

Email or portal?

Requests may be made in any form, including orally, so a portal can never be the only accepted channel.

The Arizona Public Records Law nowhere requires a request to be submitted in writing. Section 39-121 speaks only of inspection by any person during office hours, and section 39-121.01(D)(1), which governs a request for copies, requires only that the requester affirm at the time of the request whether it is for a commercial purpose; it imposes no writing requirement on the request itself. No provision of Title 39 authorizes a public body to designate a required submission channel or portal. Because a requester cannot be compelled even to put a request in writing, a public body cannot lawfully make an online portal the only way to submit one.

• A.R.S. § 39-121 (inspection by any person)
• A.R.S. § 39-121.01(D)(1) (request mechanics; no writing requirement stated)

No controlling case identified specifically on the submission-channel question. The verdict rests on the plain text of §§ 39-121 and 39-121.01(D)(1), neither of which imposes a writing requirement, corroborated by the Reporters Committee's Open Government Guide: Arizona, the Arizona Ombudsman's own public records guidance, and MuckRock's Arizona guide, each confirming oral, mail, and e-mail requests are accepted in practice.

Arizona agencies vary widely: some larger cities, counties, and universities run a records-request portal (for example NextRequest), while many towns, special districts, and school districts publish only an e-mail address or a clerk's contact information. Our records data for Arizona lists e-mail, mail, and in-person as accepted methods, consistent with a portal being optional rather than exclusive.

Last reviewed 2026-07-30.

Required Elements

• Description of records sought

Optional Elements

• Contact information
• Preferred format

Fees

Fees must be reasonable. Higher fees may apply for commercial-purpose requests. Inspection is free. Electronic records including embedded metadata must be disclosed. Agencies cannot charge unreasonable fees to discourage access.

Fee Waivers

• No statutory fee waiver mandate; agencies may waive at discretion

No statutory fee waiver provisions. Agencies may waive fees voluntarily.

Exemptions

• Confidentiality
  Records protected by other statutes that specifically require confidentiality (court-derived)
• Privacy
  Individual privacy interests that outweigh public interest in disclosure (court-derived balancing test)
• Best interest
  Disclosure would be 'detrimental to the best interests of the state' (court-derived)
• Medical
  Medical records (A.R.S. § 12-2292)
• Ccw permits
  Concealed weapon permit records (A.R.S. § 13-3112(J))
• Trade secrets
  Trade secrets and proprietary data (various statutes)
• Law enforce
  Law enforcement investigation records that would interfere with investigations
• Personnel
  Certain personnel records involving privacy interests
• Security
  Security plans and vulnerability assessments
• Deliberative
  Pre-decisional deliberative communications (limited, case law)

Arizona is distinctive: the Supreme Court recognizes three common law exceptions (confidentiality, privacy, detriment to state) rather than a statutory exemption list. Courts apply a balancing test weighing privacy against public interest in disclosure. Additional statutory exclusions scattered across various titles.

Appeal Process

No formal administrative appeal required. Ombudsman provides informal dispute resolution. Primary enforcement through Superior Court. Special action provides expedited remedy. Agency wrongfully denying access liable for resulting damages.

Request Templates

Records Retention

A.R.S. 41-151 through 41-151.24

View retention law →

Retention schedule catalog →

Only the Arizona State Library has authority to set, modify, extend or decrease retention periods. Agencies must designate a records officer. The online catalog is searchable by agency name and by keyword/phrase. General Schedules and Custom Schedules are available for all public bodies.

Sources & References

• Full text of law →
• Primary source →
• RCFP Open Government Guide — Arizona →
• NFOIC State FOI Resources →

Bodies Covered

Which kinds of public body this law applies to, with the statutory basis for each claim.

Coverage notes

• No requester-standing limit: any person may ask APRL opens records to inspection by 'any person' at all times during office hours (§ 39-121), with no residency qualifier anywhere in the chapter. The same shape as Ohio's and Georgia's, unlike Virginia's citizens-of-the-Commonwealth limit. A.R.S. § 39-121 (public records in the custody of any officer open to inspection by any person at all times during office hours)
• No fixed deadline: 'promptly furnish', deemed denied on failure to respond promptly Arizona sets no fixed number of days. The custodian shall 'promptly furnish' copies (§ 39-121.01(D)(1)), and access is deemed DENIED if the custodian 'fails to promptly respond' (§ 39-121.01(E)) -- but neither subsection states a number of days. Any fixed number of days used to decide when to check in is our follow-up convention, not a statutory mark, and the initial letter never states one as a deadline. A.R.S. § 39-121.01(D)(1) (request to examine or be furnished copies, including by mail; custodian shall promptly furnish copies; requester shall affirm the request is not for a commercial purpose, or provide a statement of intended use if it is)
• The commercial-purpose affirmation: every requester must affirm, not just commercial ones At the time of any request, the requesting person must affirm that the request is not for a commercial purpose, or provide a statement of intended use if it is (§ 39-121.01(D)(1)); only a commercial-purpose request then triggers § 39-121.03(A)'s separate statement and commercial-value fee regime. 'Commercial purpose' means a use with reasonably anticipated monetary gain -- sale, resale, or a mailing/address list (§ 39-121.03(D)); the subsection's only express exclusion is narrower than a general research carve-out (it covers only research FOR EVIDENCE in a judicial or quasi-judicial proceeding), so our letter does not lean on that exclusion. Instead it affirmatively states our public-benefit civic research carries no resale, no mailing/address list, and no reasonably anticipated monetary gain, so it never meets the definition's three affirmative prongs in the first place. Misrepresenting a commercial purpose carries treble-damage civil penalties (§ 39-121.03(C)); our declaration is accurate. A.R.S. § 39-121.01(D)(1) (request to examine or be furnished copies, including by mail; custodian shall promptly furnish copies; requester shall affirm the request is not for a commercial purpose, or provide a statement of intended use if it is)
• An index of withheld records, on request, not an automatic redaction duty Unlike Virginia's, Ohio's, and Georgia's textual 'release the remainder' redaction duties, APRL has none. Instead, 'if requested,' the custodian must furnish an index of records or categories of records withheld and the reasons (§ 39-121.01(D)(2)), and failing to promptly furnish that index when requested is itself a deemed denial (§ 39-121.01(E)). Our letter explicitly asks for the index so the statute's own conditional trigger is satisfied. A.R.S. § 39-121.01(D)(2) (upon request, the custodian shall furnish an index of records or categories of records withheld and the reasons, excluding privileged material)
• No exemption list: a case-law balancing test with the burden on the custodian Arizona's Title 39 has no statutory exemption list. Instead, the Arizona Supreme Court recognizes three common-law exceptions -- confidentiality, privacy, and the best interests of the state -- balanced against the strong presumption favoring disclosure, with the custodian bearing the burden of showing the probability of specific, material harm before withholding (Carlson v. Pima County; Mitchell v. Superior Court); there is no blanket exemption even for an active criminal investigation (Cox Arizona Publications v. Collins). Before that balancing test is ever reached, a document must clear a threshold 'substantial nexus' test for whether it is a 'public record' at all (Griffis v. Pinal County). A.R.S. § 39-121.01(A) (definitions of 'officer' and 'public body'; 'public body' includes any public organization or agency supported in whole or in part by, or expending, state or local government monies) · Carlson v. Pima County, 141 Ariz. 487, 687 P.2d 1242 (1984) · Mitchell v. Superior Court (In and For Pima County), 142 Ariz. 332, 690 P.2d 51 (1984) · Cox Arizona Publications, Inc. v. Collins, 175 Ariz. 11, 852 P.2d 1194 (1993) · Griffis v. Pinal County, 215 Ariz. 1, 156 P.3d 418 (2007)
• Fees: inspection is free, copies limited to actual cost, commercial fees do not apply to us Inspection itself carries no fee. Mailed copies may carry a copying and postage charge (§ 39-121.01(D)); an Arizona Attorney General opinion (I13-012-R13-018) confirms a public body may charge copying costs but not an inspection fee, and a requester using their own device to copy incurs no charge. The separate commercial-value fee regime (§ 39-121.03(A)) applies only to a commercial-purpose request, which ours is not. Because our letters ask for electronic delivery by reply email, duplication and postage cost should be minimal or zero. A.R.S. § 39-121.01(D) (copying and postage charges for mailed copies; inspection itself carries no fee)
• Court records run through Rule 123, not Title 39 A common misconception treats Title 39 as governing court records; it does not. Arizona Supreme Court Rule 123 governs access to judicial records instead, presuming them open under its own procedure. A court's own administrative records held by an elected clerk of the superior court, a county officer under § 39-121.01(A), remain reachable through APRL via that clerk. Ariz. Sup. Ct. Rule 123 (Access to the Judicial Records of the State of Arizona; judicial records presumed open, governed separately from A.R.S. Title 39)
• Arizona has 22 federally recognized tribal nations that APRL does not reach Unlike Ohio's and Georgia's profiles, Arizona has substantial tribal territory and 22 federally recognized tribal nations (Navajo Nation, Tohono O'odham Nation, Gila River Indian Community, Salt River Pima-Maricopa Indian Community, Hopi Tribe, and others). A sovereign tribal government is not 'this state' or a political subdivision of it, so APRL does not reach its own records; it is also not a federal executive agency, so federal FOIA does not reach it either. Route any such request to the tribal government's own records law, if one exists, never to APRL. A.R.S. § 39-121 et seq. (Arizona Public Records Law scope; Arizona law only)
• Enforcement: a special action in superior court, attorney fees, and a damages cause of action A person denied access may appeal through a special action in superior court; the court may award attorney fees and other legal costs to a substantially prevailing requester (§ 39-121.02(A)-(B)). A person wrongfully denied access has a separate cause of action against the officer or public body for resulting damages (§ 39-121.02(C)). The Arizona Ombudsman-Citizens' Aide also offers non-binding, informal dispute resolution before any court filing. A.R.S. § 39-121.02 (special action in superior court; attorney fees and costs to a substantially prevailing requester; cause of action for damages from a wrongful denial)