The Agency Is Charging Too Much — How to Challenge the Fees

Fee estimates that seem excessive are challengeable. Here is how to get an itemized breakdown, request a waiver, and narrow your request to reduce costs.

📅 Updated 2025✅ All 50 States

What Agencies Can Legally Charge

Public records laws generally allow agencies to charge for the actual, direct costs of fulfilling a request. What is and is not chargeable varies by state, but the general framework is:

Cost TypeChargeable?Notes
Duplication (paper copies)Usually yesMost states cap at $0.10–$0.25/page
Duplication (electronic/PDF)Usually no or minimalMany states prohibit fees for emailing existing files
Staff search timeSometimesVaries widely — some states cap at first 1–2 hours free
Attorney review timeRarelyMost states do not allow attorney billing rates for FOIA review
Computer programmingSometimesOnly if special programming is genuinely required
Overhead / administrative feesUsually noAgencies cannot add overhead or profit on top of direct costs

Step 1: Request an Itemized Fee Breakdown

Before paying or disputing, ask for a written itemization of how the fee was calculated. Include in your request:

  • Number of pages or files to be provided
  • Hourly rate charged for search and review time
  • Number of hours estimated for each category
  • Whether any portion of the fees can be waived
  • Statutory authority for each fee component charged

Agencies that cannot produce an itemized breakdown have a harder time defending their fee estimates at the appeal stage.

Step 2: Challenge Specific Line Items

Common fee abuses and how to challenge them:

Attorney Review at Legal Rates

In many states, agencies cannot bill attorney hourly rates for records review. Review must be billed at the rate of the lowest-paid staff member who could perform the review. If an agency is billing $250/hour for an attorney to review records, challenge this specifically.

Charging for Electronic Files That Already Exist

If the records exist as electronic files and the agency is charging for printing and scanning them, challenge this. Most modern open records laws require agencies to provide records in their existing electronic format at no or minimal cost.

Excessive Search Time Estimates

If an agency estimates 40 hours to search an email system for a specific term over a 3-month period, that is likely inflated. Modern email systems search instantly. Ask the agency to explain its search methodology and why the estimated time is justified.

Step 3: Request a Fee Waiver

Almost every state's open records law includes a fee waiver provision for requests that primarily benefit the public interest rather than a private commercial interest. Use our Fee Waiver Language Builder to generate the exact language for your state.

Strong fee waiver arguments include:

  • The information will be shared publicly (posted online, published, distributed)
  • You are a journalist, nonprofit, researcher, or educator
  • The request concerns government accountability or the exercise of official power
  • You have no commercial interest in the information
  • The disclosure will contribute to public understanding of government operations

Step 4: Narrow Your Request

If a fee waiver is denied and the estimate is still too high, narrowing the request is the most practical solution:

  • Reduce the date range
  • Limit to specific named custodians rather than "all staff"
  • Request electronic format only (avoids printing/scanning charges)
  • Limit to final documents rather than all drafts
  • Ask the agency which portion of your request is most easily fulfilled and start there

Frequently Asked Questions

In some states yes, in others no. Many states require agencies to provide a fee estimate first and get agreement before proceeding, but cannot require payment before even looking. Check your state's specific law. If an agency demands full payment upfront before doing any work, that may be challengeable.
No — using fees to deter requesters is a recognized abuse of open records laws. Several courts have found that agencies cannot use fee estimates as a pretext to avoid disclosure. Document your challenge in writing and raise this argument explicitly in your appeal: that the fee estimate is not reasonably related to actual costs and appears designed to discourage access.
In most states, the agency is bound by its fee estimate or must notify you before exceeding it. You generally have the right to stop the process before additional costs are incurred if the final fee will exceed the estimate. Some states specifically require agencies to get your approval before exceeding a stated estimate by more than a set amount.
Disclaimer: General informational guidance only. Laws vary by state. Not legal advice. Consult a qualified attorney for specific situations.