When a Derivative Classifier Marks a New Document: What Information Must They Include on the Classified By Line

The classified-by line on a derivatively classified document must identify the person who applied derivative classification, their position or title, and the source document and classification guidance used to make the determination. Under 32 CFR Part 2001 (the Information Security Oversight Office's implementing directive for Executive Order 13526), those identification requirements apply the moment a derivative classifier marks any newly created document that paraphrases, restates, or incorporates classified information from an original source. A line that says only "Classified by [Name]" without the source and guidance fails the standard.

The Three Required Identification Elements on a Classified-By Line

For derivative classification, the classified-by line is a three-part identification: the name of the person doing the derivation, their position or title, and the source document plus the specific classification guidance that authorized the marking decision. The government-wide template comes from the Office of the Director of National Intelligence's marking handbook and is reflected in most agency manuals. A correct line reads: "Classified by: Jane Doe, Program Analyst, Source: [original document, date, classification authority], Guidance: [agency classification guide, paragraph]."

The distinction matters because a derivative classifier is not an original classification authority. The original classification authority (OCA) made the underlying decision; the derivative classifier is applying that decision to a new document. The classified-by line therefore has to trace back to the OCA decision, or it has no legal foundation. If the line cannot be traced, the document is not properly marked.

Agencies customize format. The Department of Defense often uses a multi-line block in the header or footer; the Central Intelligence Agency uses a compact block. What does not change is the requirement to name a person, a position, and a sourcing basis. A line with a name only, or with a generic office label instead of a named individual, is incomplete.

Failure case worth noting: during a declassification review, the primary document can be reviewed without a name, because the OCA decision is embedded in the original. A derivative document cannot, because the reviewer has no way to verify the derivation without an identifiable source trail. That is why the line is enforced on derivatives rather than originals.

What the Classified By Line Must Never Substitute For

The classified-by line identifies who applied the classification, not why the information is classified at that level. The "reason" belongs elsewhere: in the classification authority block, the derivative classifier notes the agency classification guide, the source document, and any specific declassification instructions. The classified-by line is a signature trail, not an authority statement.

A common error is including the classification level in the classified-by line itself (e.g., "Classified by: Jane Doe — SECRET"). The level appears in the banner and portion markings; the classified-by line stays neutral. Repeating the level in the line creates inconsistency when the document is later downgraded or declassified. A reviewer should be able to update the banner without touching the classified-by line.

The classified-by line also should not include the declassification date for derivative documents. Derivative declassification follows the source, not the derivative — the source's declassification instructions control. Put the source's instructions in the source and guidance fields, not in the classified-by field. A derivative document's declassification is set to match the source's; if the source has no declassification date, the derivative inherits that absence.

For those who confuse the two, recall that original classifiers have their own classified-by line that names the OCA's authority (e.g., "Classified by: [Name], [Position], [Delegation of Authority No.]"). Derivative classifiers follow a different template entirely.

Comparing the Five Common Marking Blocks Across Formats

Three elements are mandatory across every format; two are conditional. The table below compares how they appear in the two most common formats — the ISOO/ODNI template and the DoD-style template — based on the ODNI Marking Classified National Security Information handbook (current edition) and DoD 5200.01-V2, Enclosure 4.

The verdict: in practice the two templates collapse into the same content, differing only in line breaks. DoD typically combines name and title on one line; the ISOO template separates them. What matters is that a reviewer or FOIA processor can trace from the derivative document to the source without hunting. If your agency manual uses a specific header block, follow it — but the four identifying data points (name, title, source, guidance) must all appear somewhere in the classification authority block, even if not on the classified-by line itself.

The Three-Step Marking Sequence and the Failure Points Between Them

The marking sequence runs name, then source, then guidance — in that order — because each step narrows down what the next requires. If you skip a step, you cannot complete the later ones accurately.

1: Confirm you are treating this as derivative, not original classification. A document that restates, paraphrases, or incorporates already-classified information is derivative; a document that reveals a new fact about national security is not. Misclassifying the mode is the most common failure — a derivative classifier authorized to restate an OCA's decision has no authority to make a new one. Verify against the source document before writing any line. 2: Enter your full legal name and current position/title exactly as they appear in the agency personnel record. Do not use initials, nicknames, or the office name alone. A derivative classifier whose title changed mid-project must use the title in effect on the marking date. 3: Enter the source document identifier, its date, and the specific agency classification guide and paragraph. "Derived from: source" without a paragraph reference is insufficient when the source is a multi-topic guide. 4: Check the completed block against the source's classification authority block. If the source's line is itself incomplete, escalate to the original classifier or the agency component security officer before applying markings.

Failure handling: a missing source identifier is the most frequent defect in derivative marking, according to ISOO's Report to the President annual review findings. When the source cannot be identified, the document cannot be derivatively classified and must be referred to an OCA in the owning agency. Do not improvise; do not leave the source field blank.

How the Classified By Line Interacts With the IGI and the Source Document

The "source" field in the derivative block refers to two things at once: the document from which the information was taken, and the classification guide that governs its level and duration. Those usually point to the same information but are not identical, and confusing them is a common error.

The information classification guide (ICG), sometimes called the "classification guide," is the document the OCA uses to set classification levels for categories of information. It is what makes derivative classification repeatable: a derivative classifier cites the guide's paragraph rather than the OCA's signature. The source document is the specific paper in front of you. A derivative document incorporating five categories from two sources must cite both source documents and both applicable guide paragraphs.

When the source document is itself derivative, the trail extends: your classified-by line must trace back through the source to the original OCA decision. This is the "chain" problem in derivative classification. In practice, reviewers accept a source-document-only citation when the source is properly marked, but during declassification a multi-hop chain can break if intermediate sources were not consistently marked.

Marking New Document Types: Emails, Slides, and Embedded Charts

Each new-document type carries distinct marking obligations for the classified-by line. Emails are the most frequent failure case, because the header/footer fields that carry the classified-by line are easily stripped when a message is forwarded or saved to PDF. The classification authority block should appear in the message body, not only in email system fields.

For slide decks, put the classified-by block on the title slide and on each slide that contains classified content, plus the deck-level block on the master slide. Embedded charts and tables extracted from the deck into another format must carry their own block, not inherit invisibly. A chart pasted into an unclassified spreadsheet with a note "SECRET — see deck" does not satisfy the requirement.

For documents generated from templates, the block should be part of the template and populated at the time of derivation. If the template block is auto-filled with the preparer's login name but not the title or source, the result is incomplete. Templates must require all four data points.

Derivative Classification Errors with Real Consequences

Errors in derivative marking are not cosmetic. They appear in ISOO's annual reports as recurring findings, and they create review and FOIA delays, retraction risk, and in some cases referral to the agency's classification review body. The most damaging error is over-classification — restating a lower-level source at a higher level — because it can persist for decades in derivative documents derived from the mis-marked derivative.

Under-classification is rarer but higher risk. It occurs when a derivative classifier paraphrases away the source's classification markers — the paraphrase is "new text" and gets marked lower because the classifier no longer sees the source banner. The fix is mechanical: compare each paragraph against the source paragraph it restates, and copy the source's level to the derivative paragraph.

A third error: using the classified-by line as a "signature of accountability" when the classifier is not sure who should be accountable. The line must name a real, current person. "Classified by: Classification Office" fails because no individual is accountable. Name the analyst who made the determination, even if a supervisor approved it.

Why the Source and Guidance Fields Cannot Be Omitted From the Line

Omitting the source and guidance fields is the single most common derivative-marking defect found in ISOO reviews. The pattern is understandable: a classifier who "knows" what is classified may treat the source line as boilerplate. But the source and guidance fields are what make derivative classification auditable. Without them, the reviewer cannot verify the decision, and the classifier cannot demonstrate that they acted within their authority.

The fields also matter because derivative classifiers have no independent classification authority. Their entire authority is borrowed from the OCA decision documented in the source. The source and guidance fields are the written record of that borrowing. An agency cannot defend a derivative classification in litigation, FOIA, or a declassification review if the borrowing is undocumented.

A useful practice: treat the source field as the most important of the four, not the least. If you cannot fill it in completely, stop and resolve that before marking anything else. A document with a name and title but no source is worse than a document with no markings at all, because it falsely asserts authority.

Who May Sign a Classified By Line, and Who Must Approve It

Any trained, authorized derivative classifier may sign the classified-by line for a derivative document they marked. No separate OCA signature is required. The classifier's authority comes from their training and their agency's designation as an authorized derivative classifier — not from being an OCA. Documenting that training is part of the agency's internal control program; ISOO's implementing directive requires agencies to maintain a derivative classifier training program.

Supervisory review varies. Some agencies require a second-level review of the completed marking block before the document leaves the originating office; others do not. The classified-by line names the individual who made the determination, regardless of whether a supervisor also approved. Do not list the supervisor as the classifier if the analyst made the calls.

Self-correction: if a derivative classifier discovers an error, they correct the block and reissue the document. If the error is discovered after transmission, they notify the recipients and the agency's classification management officer. Do not simply cross out and initial if the document is already distributed; a superseding version is required.

What Changes During a Security Review, Upgrade, or Downgrade

Security reviews, classification challenges, and declassification actions all touch the classified-by line. When a derivative document is reviewed and confirmed, the line stays as originally written unless the review uncovers an error. When a document is challenged by a holder (under EO 13526, any authorized holder can challenge), the challenge is filed with the OCA, not the derivative classifier — the derivative classifier explains the derivation but cannot resolve the challenge.

Upgrades are rare and require OCA involvement. A derivative classifier cannot upgrade a derivative document beyond the source. A declassification review, by contrast, follows the source's instructions; if the source has been released, the derivative is reviewed against the source's release and can be declassified accordingly, at which point the classified-by line is annotated with the review record.

Records management matters here: the archive copy of a derivative document should preserve the original classified-by block, with any later annotations appended rather than overwritten. Otherwise, the audit trail — the point of the whole system — is lost.

FAQ

Does the classified-by line need a date?

Yes, the date of derivative classification belongs in the classification authority block, usually parallel to the classified-by line rather than inside it. Some agencies combine them. The date records when the derivation was made and is used when reviewing whether the source was still in effect on that date. Omitting the date makes reconstruction harder but does not by itself invalidate the classification.

Can a contractor sign the classified-by line?

Yes, if the contractor is an authorized derivative classifier under the agency's program and the contract requires it. The line still names the individual person and their title/role; "Contracted support" alone is not a title. Many agencies use a specific contractor title such as "Contract Analyst." Confirm with the agency's classification management officer before applying; some agencies prohibit contractors from marking certain categories.

What happens if I realize the source block is wrong after I've marked the new document?

Stop distribution, correct the derivative line to reflect the actual source, and re-mark the document. If it has already gone out, notify recipients and your classification management officer immediately, and issue a superseding version. Do not leave the error in place — downstream documents derived from your mis-marked document will inherit it.

Is the classified-by line the same in every agency?

No format is identical, but the four data points — name, position/title, source document, classification guidance — are common to every agency template that implements 32 CFR 2001. What differs is the layout, the labels, and sometimes the order. Follow your agency's specific template. Where your agency template omits one of the four, add it as an annotation rather than leave it out.

Does a derivative classifier need to check with the OCA before applying the marking?

Routine derivative classification does not require OCA sign-off, since the OCA already made the underlying decision. Consult the OCA or their delegate when the source is ambiguous, when the source's markings conflict, or when the derivative incorporates information not obviously covered by the cited guidance. Consulting an OCA does not shift the classified-by line to the OCA unless the OCA is also the derivative classifier on that document.

Can I use a position title instead of a name?

No. A named individual is required. Position title alone is insufficient because the accountability needs to attach to a person in the event of a later review, challenge, or declassification action. Where workplace safety or other rules require redacting the individual's name in a specific released copy, an agency can annotate, but the underlying record keeps the name.

What if the source document is itself unmarked?

An unmarked source cannot support derivative classification. Suppose you find a paragraph that should be classified based on your knowledge but the source document carries no markings. You cannot derivatively classify on that basis; refer the matter to an OCA in the owning agency. Marking on assumption, even correct assumption, is precisely the failure the classified-by line is designed to prevent.

Are markings required on draft documents?

Yes, if the draft contains classified material derived from a classified source, the draft must be marked, including the classified-by line. Drafts are sometimes treated informally, and that is where many of the recurring ISOO findings originate. The marking requirement applies to all stages of a document's existence, including working drafts and review copies, and continues until the document is destroyed or declassified.