Observe · Regulate · Protect — since 2007. 19th OIMAP General Assembly: Singapore, 10–12 June 2026. Programme
Regulation

Financial transparency

Declaring sales, keeping a register of transactions, accepting inspections: the transparency obligations of art market operators.

Updated : October 28, 2026· 3 min read

Pages in this section

A market that accounts for itself

Seal of Doge Michele Steno (reverse) (1400–1409)
Seal of Doge Michele Steno (reverse) (1400–1409)

The art market has long been seen as opaque: confidential prices, anonymous sellers, discreet payments. Directive 2019-04 laid down a principle of proportionate transparency: operators declare their sales, keep a register and accept inspections.

Transparency does not mean publicity. The identities of buyers and sellers remain protected; it is the authorities and the Observatory that receive the information.

This section presents the reporting obligations, the transaction registers and the inspections.

  • Transparency
  • Declaration
  • Registry

Financial transparency in figures

30 daysDeadline for declaring a sale
10 yearsRetention of the register
1,120Approved operators reporting
96%Rate of declarations made on time

Source: OIMAP Legal Affairs Department.

The three pages of the section

Breakdown

Auction houses58%
Galleries and dealers24%
Platforms12%
Administrations6%

Origin of sales declarations.

Carnet (1863–1865)
Carnet (1863–1865)
Coin of Demetrios, I (reverse) (200–190 BCE)
Coin of Demetrios, I (reverse) (200–190 BCE)
Views:  The Market on the Molo, Antonio Canaletto (1735–1746)
Views: The Market on the Molo, Antonio Canaletto (1735–1746)

Three obligations

The first obligation is to declare each significant sale within thirty days: date, lot, price, terms. The second is to keep a register of transactions, which keeps all the operator's transactions in an orderly manner. The third is to accept inspections by the national authority and the Observatory.

These obligations are graduated: an occasional operator is subject to a simplified declaration, an approved operator to the full regime.

Why transparency benefits the market

The data declared feeds the Observatory, which produces the world index, rankings and price analyses. Without it, buyers, insurers and States would be working in the dark. Transparency also reduces the risk of money laundering, by making transactions more readable.

Finally, it protects operators themselves: a well-kept register is valuable evidence in the event of a dispute or inspection.

A balance to preserve

Transparency is a balance: too little, and the market remains opaque; too much, and players turn to less supervised channels. OIMAP has therefore chosen proportionate obligations, with simplified regimes and strong data protection.

This balance is reviewed at each revision of the directives. The 2025 public consultation will notably address extending the declaration to over-the-counter transactions between private individuals.

The three obligations

A three-stage regime
ObligationDeadlineRecipient
Declaration of a sale30 daysOIMAP Observatory and national authority
Keeping the registerAs they happenKept by the operator
Reply to an inspection15 daysCompetent authority

Landmarks

  1. Directive 2019-04

    Principle of transparency.

  2. Online declaration

    Desk portal.

  3. Digital register

    Standard model.

  4. 96% of declarations on time

    Observatory review.

Confidentiality

American Red Cross War Council Medal (obverse), Daniel Chester French (1920)
American Red Cross War Council Medal (obverse), Daniel Chester French (1920)
Sweet Melancholy, Joseph-Marie Vien (1756)
Sweet Melancholy, Joseph-Marie Vien (1756)
Solidus of Justinian I (obverse) (c. 545–565)
Solidus of Justinian I (obverse) (c. 545–565)

Approved or occasional operator

The Auction House:  The Town Crier, Honoré Daumier (1864, printed 1920)

Approved

Auction house, gallery, platform
  • Full declaration
  • Digital register
  • Periodic inspections

Full regime.

Portrait of Pope Paul II Barbo (obverse) and (reverse), Cristoforo di Geremia (c. 1468)

Occasional

Private individual or small dealer
  • Simplified declaration
  • Lightened register
  • Spot checks

Simplified regime.

Getting into compliance

  1. Identify

    Know which sales are concerned.

  2. Declare

    Use the portal.

  3. Register

    Keep the register.

  4. Keep

    Archive for ten years.

  5. Monitor

    Prepare for inspections.

Reflexes

An inspector

Letter Box, Ogata Kōrin (1700s)
« Transparency is not police control. It is the condition for a market to deserve its reputation. »
Inès Moreau, inspector in the supervision service

Vocabulary of transparency

Declaration
Information transmitted on a sale.
Registry
Log of transactions.
Statistical confidentiality
Protection of individual data.
Check
Verification of an operator's compliance.

Frequently asked questions

Must a private sale be declared?

Yes, if it is made by an operator.

Who receives the declarations?

The Observatory and the national authority.

Where do I declare?

On the Desk portal.

What sanctions for lateness?

See the Inspections page.

Useful documents

Contacts

Eighteen Views of Rome: The Piazza Farnese (recto), Lievin Cruyl (1664)
Eighteen Views of Rome: The Piazza Farnese (recto), Lievin Cruyl (1664)
Legal Affairs DepartmentParis — Headquarters+33 1 00 00 02 00juridique@oimap.exampleMonday to Friday, 9 am – 5 pm

Read the reporting obligations

Solidus of Justinian I (reverse) (545–565)

Who declares what and when.

Reporting obligations
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