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Regulation

Due diligence checklists

The twelve due diligence checkpoints, to be ticked before each transaction.

Updated : October 28, 2026· 3 min read

Twelve points, three situations

The Judgment of Midas, Nicolaes Clock (1589)
The Judgment of Midas, Nicolaes Clock (1589)

The checklists turn the due diligence method into concrete actions. They exist in three versions — purchase, sale, deposit — and two levels — basic and enhanced — and each fits on one page.

They are used by auction houses, galleries and dealers, and by some museums for their acquisitions. They also serve as a reminder for collectors.

This page presents the twelve checkpoints, their logic and how to use them.

  • Checklists
  • Twelve points
  • Compliance

Due diligence checklists in figures

12Points to check
3Versions: purchase, sale, deposit
2Levels: basic and enhanced
1 pagePer list

Source: OIMAP Legal Affairs Department.

Breakdown

Identity3 points
Provenance3 points
Lawfulness3 points
Payment2 points
Decision1 point

Breakdown of the twelve points.

The twelve points

Identity: 1. Verify the identity of the seller and the buyer. 2. Identify the beneficial owner. 3. Check the representative's powers. Provenance: 4. Obtain the ownership history. 5. Examine the provenance documents. 6. Check publications and exhibitions.

Lawfulness: 7. Consult the BIOP database. 8. Check export and import licences. 9. Check national protections (listing, inventory). Payment: 10. Identify the origin of funds. 11. Check consistency with the client's profile. Decision: 12. Record the decision and the justification.

Sweet Melancholy, Joseph-Marie Vien (1756)
Sweet Melancholy, Joseph-Marie Vien (1756)
An Old Clothes Shop, Seven Dials, John Thomson (1877)
An Old Clothes Shop, Seven Dials, John Thomson (1877)
Carnet (1863–1865)
Carnet (1863–1865)

Basic or enhanced

The basic list is enough for routine transactions under €10,000 with no warning sign. It is limited to the twelve points with the usual supporting documents. The enhanced list adds further checks for each point: archives, expert opinion, price justification, interview with the seller.

A transaction can move to the enhanced level along the way if a warning sign appears. The file then keeps the trace of this switch.

User feedback

A survey carried out in 2024 among 410 operators shows that 86% find the checklists "useful or very useful". The most satisfied operators are small galleries, for whom they are a first structuring of compliance.

The main requests for improvement concern integration with existing management tools and translation into more languages. The Secretariat is working on this with the market's software publishers.

Example of a purchase checklist

Extract from the purchase checklist
PointCheckTrace
1Identity verified on official documentCopy
4Ownership history obtainedSigned document
7BIOP consultation carried outDated capture
8Export licence checkedCopy of the document
10Origin of funds identifiedStatement
12Decision recordedSigned sheet

Landmarks

  1. First lists

    Annexes to the directive.

  2. Printable version

    Practical sheets.

  3. Digital version

    Online checkboxes.

  4. Integration into the Desk

    Guided completion.

A box ticked without evidence is worth nothing

Paper list or digital list

Taj Mahal, Back View of the Rest-House, with Figure, Dr. John Murray (c. 1858–1862)

Paper

Printed sheet
  • Simple
  • Usable anywhere
  • Physical archiving

For small structures.

Letter Box, Ogata Kōrin (1700s)

Digital

Online form
  • Timestamping
  • Attachments
  • Automatic archiving

For more active structures.

The Auction House: The Town Crier, Honoré Daumier (1864, printed 1920)
The Auction House: The Town Crier, Honoré Daumier (1864, printed 1920)
Carved Lacquer Scroll Box (1736–95)
Carved Lacquer Scroll Box (1736–95)
Telescoping basket (1800's)
Telescoping basket (1800's)

Using a checklist

  1. Choose

    Select purchase, sale or deposit.

  2. Qualify

    Determine the level.

  3. Complete

    Tick and attach the documents.

  4. Confirm

    Have another person check.

  5. Archive

    Keep for ten years.

Before signing

Vocabulary of the lists

Checklist
Reminder of points to check.
Switch
Move from one level to another.
Second checker
Person who reviews the file.
Trace
Retained proof of a check.

Frequently asked questions

Are the lists mandatory?

No, but they are recommended and accepted as proof of diligence.

Can they be adapted?

Yes, as long as the twelve points are kept.

Where can I download them?

In the useful documents on this page.

What is the link with the form templates?

Useful documents

Contacts

Small Mosque in the Kaiserbagh, Felice A. Beato (1858)
Small Mosque in the Kaiserbagh, Felice A. Beato (1858)
Legal Affairs DepartmentParis — Headquarters+33 1 00 00 02 00juridique@oimap.exampleMonday to Friday, 9 am – 5 pm

See the form templates

At the Market, Camille Pissarro (late 1800s)

Ready-to-use documents.

Form templates
Image credits (16)
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