An inspection is prepared… by working well every day

Transparency inspections aim to check that operators declare their sales, keep their register and retain their supporting documents. They are carried out by national authorities, with the support of the Observatory.
An operator who has carried out its due diligence, kept its register and declared its sales has nothing to fear. The inspection is then a formality that takes a few hours.
This page describes the course of an inspection, the operator's rights and the possible sanctions.
Transparency inspections in figures
Source: OIMAP Legal Affairs Department.
How an inspection proceeds
An inspection begins with a written notice stating the purpose, the period and the documents requested. The operator has fifteen days to supply them. Officers examine the register, a sample of due diligence files and the declarations sent, and may ask questions.
A report is then drawn up. The operator has thirty days to respond. If there is no breach, the file is closed. Otherwise, a proportionate sanction is imposed.



The operator's rights
The operator inspected has the right to be informed of the grounds for the inspection, to be assisted by an adviser, to submit written observations and to challenge the report. Officers are bound by professional secrecy: the data obtained may be used only for the compliance inspection.
It also has the right to a proportionate inspection: a small gallery is not inspected like a large house, and requests for documents must remain reasonable.
Inspections, a tool for improvement
Beyond sanction, an inspection is an opportunity to improve practices. Each year, the Observatory publishes an anonymised summary of findings: the most frequent breaches, good practices noted, desirable developments. Operators use it as a self-assessment grid.
Since 2023, a self-diagnosis tool has allowed an operator to inspect itself against the same criteria as the authority. Operators that use it regularly are inspected less often.
Graduated sanctions
| Breach | Sanction | Example |
|---|---|---|
| Late declaration | Warning then penalty | Declaration at D+40 |
| Incomplete register | Formal notice | Missing fields |
| Repeated omission | Suspension of approval | Undeclared sales over a year |
| False declaration | Withdrawal of approval and prosecution | Price deliberately understated |
Landmarks
- Inspection notice
Written notification.
- Transmission of documents
Time limit to reply.
- Report
Findings and conclusions.
- Decision
Closure or sanction.
Cooperate
Document-based or on-site inspection

Document-based
Remote examination- Quick
- Not very intrusive
- Sufficient for most cases
Most common mode.

On site
Visit to premises- More thorough
- Examination of stock
- Reserved for sensitive cases
Exceptional mode.



Preparing for an inspection
- Gather
Gather register, declarations and files.
- Check
Check consistency.
- Designate
Name a contact person.
- Reply
Supply the documents.
- Follow
Correct the remarks.
To have at hand
An inspector

« The best inspection is the one where the operator shows us what it has perfected since last year. »
Vocabulary of inspection
- Formal notice
- Formal request to correct a breach.
- Inspection report
- Document setting out the findings.
- Document-based inspection
- Remote inspection by documents.
- Professional secrecy
- Officers' obligation of confidentiality.
Frequently asked questions
Can I refuse an inspection?
No, it is an obligation of approval.
Where can I challenge a sanction?
Before the national court and then the Arbitral Tribunal.
Are small operators inspected?
Yes, in a proportionate manner.
Who decides on sanctions?
The national authority, with the opinion of the Secretariat.
Useful documents
Contacts

Discover anti-money laundering
Image credits (16)
- Portrait of Gianfrancesco Gonzaga di Ròdigo, 1443–1496, Lord of Sabbionetta (reverse), Antico (1479) — Cleveland Museum of Art, CC0 1.0
- Document Box (Ryōshibako) with Chrysanthemum and Plum (lid) (late 1800s-early 1900s) — Cleveland Museum of Art, CC0 1.0
- Medal Commemorating Commodore Oliver Hazard Perry (1785-1819) and the Battle of Lake Erie, Moritz Fürst (1813) — Cleveland Museum of Art, CC0 1.0
- Christ Driving the Money Changers from the Temple, Rembrandt van Rijn (1635) — Cleveland Museum of Art, CC0 1.0
- Solidus of Justinian I (c. 545–65) — Cleveland Museum of Art, CC0 1.0
- Teapot with Landscape and Imperial Poem, Chen Hanwen (1762–95) — Cleveland Museum of Art, CC0 1.0
- Noble: Henry VI in Ship with Shield of Arms (obverse); Ornamental Cross with Lis Terminals (reverse) (1422–61) — Cleveland Museum of Art, CC0 1.0
- Yokkaichi: View of the Mie River, from the series The Fifty-Three Stations of the Tōkaidō, Utagawa Hiroshige (c. 1833–34) — Cleveland Museum of Art, CC0 1.0
- Medal of Claude Joseph Rouget de L'Isle (1760-1836), Alfred Borrel (1911) — Cleveland Museum of Art, CC0 1.0
- Fish or Seal Club (X’ús’) (late 1800s–early 1900s) — Cleveland Museum of Art, CC0 1.0
- Medal: Loïe Fuller (obverse), Pierre Roche (1900) — Cleveland Museum of Art, CC0 1.0
- Roman Ruins, Villa Pamfili, Hubert Robert (1774) — Cleveland Museum of Art, CC0 1.0
- Coin of Eukratides I (170–145 BCE) — Cleveland Museum of Art, CC0 1.0
- Seal Color Box (1662–1722) — Cleveland Museum of Art, CC0 1.0
- Portrait of John VIII Palaeologus, Emperor of Constantinople, 1424-1428 (obverse), Pisanello (c. 1438–1439) — Cleveland Museum of Art, CC0 1.0
- Creamer, Louis Rorimer (c. 1910) — Cleveland Museum of Art, CC0 1.0
Cleveland Museum of Art · CC0 1.0
Financial transparencyDeclaring sales, keeping a register of transactions, accepting inspections: the transparency obligations of art market operators.›
Reporting obligationsWho must declare, which sales, within what time and through which channel: the reporting regime of the art market.›
Money laundering sanctions in the art marketThe penalties and measures incurred by operators and persons involved in money laundering: criminal, administrative and professional sanctions.›