13.3 Create Retention Labels for Data Lifecycle Management
Key Takeaways
- Create Data Lifecycle Management labels at Solutions > Data Lifecycle Management > Retention labels; the name cannot be changed after save, and double quotation marks are not supported in the name
- After the wizard, choose Just save the label for now; publishing and auto-apply are later chapters
- Most label settings cannot change after save except the retention period and descriptions; the option to mark items as a record is also locked after save
- Use Records Management file plan when you need event-based retention, disposition review, or to mark items as records or regulatory records
- A regulatory record cannot be removed by anyone, including a global administrator; the option is hidden until you run Set-RegulatoryComplianceUI and those labels cannot be auto-applied
Creating the label is a different skill from publishing it. Microsoft's Data Lifecycle Management article for this wizard is literally titled around exceptions: you create a few labels for items that need different retain/delete behavior than the container policy. You still need to understand records, because the exam blueprint sits next to records management and the same label object can mark an item as a record.
Portal path and permissions
Confirm Retention Management (or membership in Compliance Administrator). Then:
- Sign in to the Microsoft Purview portal.
- Open Solutions > Data Lifecycle Management > Retention labels.
- Select Create a label and complete the wizard.
- When you are offered publish, auto-apply, or save: select Just save the label for now, then Done.
- Repeat for each distinct retain/delete combination.
Be careful with the name. After the label is saved, the name cannot be changed. Double quotation marks are not supported in retention label names (Microsoft's example: a name like Permanent Label wrapped in quotes is invalid). Treat the name as a file-plan identifier users and eDiscovery will see. Descriptions can still be edited later.
To edit a label, select it and choose Edit label. You can change descriptions and eligible settings. Microsoft states that most settings cannot be changed after the label is created and saved, including the label name and the retention settings except the retention period. From file plan, the option to mark items as a record is also locked after save. You can usually still change the period length (regulatory records are stricter: you may extend the period but cannot shorten it after save).
You can delete a retention label only when it is not in any published or auto-apply label policy, is not configured for event-based retention, and does not mark items as regulatory records.
File plan (Solutions > Records Management > File plan) is the richer authoring surface: descriptors, import/export, and the record / regulatory record options. If you already created labels in Data Lifecycle Management, they automatically display in the file plan.
Define label settings: retain, delete, or both
On Define label settings you pick the same three outcomes as policies, with label-specific wording:
Retain-only. Choose Retain items indefinitely or for a specific period. For a finite keep without forced delete, set the period and then Deactivate retention settings after the period: the label stays on the item as a classify-only tag, unless it marks a record (lock/unlock restrictions remain). To keep without an end date, retain for An indefinite period.
Retain and then delete. Retain for a period, then Delete items automatically or Start a disposition review. Disposition review is a records-management control: reviewers approve disposal, extend, or relabel. Proof of disposition is available when you use disposition review or when the item is marked as a record (Microsoft documents proof for up to seven years in the capabilities comparison).
Delete-only. Choose Enforce actions after a specific period. Choose what happens after the period is automatically Delete items automatically. The time span is still called the retention period, and it still starts from created, modified, labeled, or an event—not from the moment you saved the label.
Start-of-period options on a label: when created, when last modified (SharePoint, OneDrive, Microsoft 365 Groups files), when labeled, or when an event occurs. Policies cannot use labeled or event starts. Event-based retention is why Microsoft tells you to create those labels from Records Management, not from a casual DLM exception.
Labels can also Change the label at the end of the period (apply a replacement label you already created) or start a Power Automate flow. You cannot relabel a regulatory record, but a replacement label may mark content as a regulatory record. You cannot delete a label that is selected as a replacement. Replacement labels can chain; Microsoft publishes no limit on how many replacement labels an item can pass through. If the replacement marks a record and the file is checked out, relabel retries after check-in. A replacement label is visible in Outlook only when it is in a published policy for that location or is delete-only.
Relabel example Microsoft uses: a three-year record label (users cannot delete in-app), then a five-year non-record replacement from created date. After three years users can delete from the app, but eDiscovery can still find the item until year five.
Records versus regulatory records
A standard retention label has retain/delete settings but does not declare a record. A record label places extra restrictions and extra audit. A regulatory record is stricter still. Microsoft's headline difference: after a regulatory record label is applied, nobody—not even a global administrator—can remove it.
| Action | Standard label | Record locked | Record unlocked | Regulatory record |
|---|---|---|---|---|
| Edit contents | Allowed | Blocked | Allowed | Blocked |
| Edit properties / rename | Allowed | Allowed by default (tenant setting can block) | Allowed | Blocked |
| Delete | Allowed (SharePoint/OneDrive deletion can be blocked tenant-wide) | Blocked | Blocked | Blocked |
| Change or remove label | Allowed | Container admin only, and the record must be locked | Blocked | Blocked |
| Auto-apply policy | Supported | Supported for records | Supported for records | Not supported |
| Priority cleanup override | Allowed | Blocked | Blocked | Blocked |
Lock/unlock (record versioning) applies to SharePoint and OneDrive, not Exchange. Exchange items marked as a record behave like the locked column. Default tenant setting Allow users to edit record properties applies to locked records in SharePoint/OneDrive when the file is larger than 0 bytes; turn it off under Settings > Solutions settings > Records Management > Retention Labels if property edits must be blocked. A standard label on a list item does not push retention to a document attachment; a record or regulatory record label does, and that attachment cannot be deleted.
Regulatory labels have extra admin restrictions: the period cannot be shortened after save (only extended); they are not supported by auto-labeling policies and must be applied with a published retention label policy; they cannot be applied to a SharePoint document that is checked out. Because the actions are irreversible, the regulatory option is hidden by default. Enable it with Security & Compliance PowerShell:
Set-RegulatoryComplianceUI -Enabled $true
The cmdlet takes effect immediately, with no confirmation prompt. Enabling it is an auditable action (Enabled regulatory record option for retention labels). Hide the option again with -Enabled $false. Create record and regulatory labels from Records Management so the mark-as-record pages appear. Who can apply them in apps: Exchange, any user with write access to the mailbox; SharePoint and OneDrive, Members / Contribute.
Do not choose regulatory records from Data Lifecycle Management as a casual exception. If the business only needs a longer keep than the site policy, a standard DLM label is the right object.
What you are not doing yet
Saving the label does not put it on any item. Availability in Outlook, SharePoint, and OneDrive comes from a retention label policy that publishes the label to locations. Automatic application comes from an auto-apply policy (sensitive info types, keywords/KeyQL, trainable classifiers, or cloud attachments). Those policies are where you attach the adaptive scopes from the previous section. Policy lookup, conflict resolution, and recovering content from Preservation Hold or Recoverable Items are later chapters.
Related behaviors you should recognize but not configure here: Insider Risk Management Adaptive Protection can auto-create a hidden 120-day retain label for unlabeled content deleted by elevated-risk users (Microsoft documents this as preview, and the label is not visible in the portal). Priority cleanup also applies labels under the covers and is not supported for items already marked as records. A Syntex model, an Outlook rule, or a Power Automate Apply a retention label action can apply labels after they exist.
Monitor usage from Data Lifecycle Management > Overview (content explorer and activity explorer). After labels are on items, eDiscovery/content search can find them with the Retention label condition. Auditing of apply/change/remove for standard labels on SharePoint and OneDrive is under file activities (Changed retention label for a file); Exchange record declaration logs Labeled message as a record.
Exam trap: Global Administrator or Compliance Administrator is not enough by itself if the account lacks Retention Management. Creating the label also does not require access to the files. Name, record declaration, and (for regulatory) a shorter period are the settings you cannot casually fix after save—get those right in the wizard.
You created a Data Lifecycle Management retention label and saved it. Which setting cannot be changed afterward?
What is the most important difference Microsoft publishes for a regulatory record compared with a standard record label?
You must retain contracts from the date they expire, send them through disposition review, and optionally mark them as records. Where should you create the retention labels?