The growing reliance on digital infrastructures has made Electronic Records Management Systems (ERMS) essential for ensuring organisational governance, accountability, and effective service delivery. This study presents a structured comparative literature review of ERMS adoption and implementation across developed and developing governmental contexts. The objective is to identify key determinants influencing implementation, examine recurring challenges, and highlight contextual differences in adoption patterns. A structured literature review was conducted using peer-reviewed journal articles, conference proceedings, and institutional reports published between 2010 and 2024. The findings identify four primary determinants influencing successful ERMS implementation: governance and policy alignment, technological infrastructure readiness, human resource capacity, and system interoperability. The results reveal notable contextual differences. In developing environments, implementation is largely constrained by infrastructural limitations, financial constraints, and shortages of technical expertise. In contrast, studies conducted in more digitally mature environments emphasise challenges related to system interoperability, usability, and metadata standardisation. The study demonstrates that ERMS implementation should be understood as a socio-technical process that requires alignment among governance frameworks, technological infrastructure, and organisational culture. By synthesising fragmented case-based research into a comparative analytical framework, this study advances the study of ERMS implementation. It provides practical insights for policymakers and practitioners involved in digital governance initiatives. Future research should prioritise longitudinal and cross-national empirical studies to further strengthen theoretical development in digital records management.