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

Transparency inspections

How the authority checks declarations and registers: course of an inspection, operator's rights, sanctions and remedies.

Updated : October 28, 2026· 3 min read

An inspection is prepared… by working well every day

Document Box (Ryōshibako) with Chrysanthemum and Plum (lid) (late 1800s-early 1900s)
Document Box (Ryōshibako) with Chrysanthemum and Plum (lid) (late 1800s-early 1900s)

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.

  • Check
  • Sanctions
  • Rights

Transparency inspections in figures

1,120Approved operators
212Inspections carried out in 2024
9Suspension sanctions
94%Inspections with no remarks

Source: OIMAP Legal Affairs Department.

Breakdown

No remarks94%
Minor remarks4%
Serious breaches2%

Result of the 2024 inspections.

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.

Medal Commemorating Commodore Oliver Hazard Perry (1785-1819) and the Battle of Lake Erie, Moritz Fürst (1813)
Medal Commemorating Commodore Oliver Hazard Perry (1785-1819) and the Battle of Lake Erie, Moritz Fürst (1813)
Christ Driving the Money Changers from the Temple, Rembrandt van Rijn (1635)
Christ Driving the Money Changers from the Temple, Rembrandt van Rijn (1635)
Solidus of Justinian I  (c. 545–65)
Solidus of Justinian I (c. 545–65)

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

Scale of sanctions
BreachSanctionExample
Late declarationWarning then penaltyDeclaration at D+40
Incomplete registerFormal noticeMissing fields
Repeated omissionSuspension of approvalUndeclared sales over a year
False declarationWithdrawal of approval and prosecutionPrice deliberately understated

Landmarks

  1. Inspection notice

    Written notification.

  2. Transmission of documents

    Time limit to reply.

  3. Report

    Findings and conclusions.

  4. Decision

    Closure or sanction.

Cooperate

Document-based or on-site inspection

Teapot with Landscape and Imperial Poem, Chen Hanwen (1762–95)

Document-based

Remote examination
  • Quick
  • Not very intrusive
  • Sufficient for most cases

Most common mode.

Noble: Henry VI in Ship with Shield of Arms (obverse); Ornamental Cross with Lis Terminals (reverse) (1422–61)

On site

Visit to premises
  • More thorough
  • Examination of stock
  • Reserved for sensitive cases

Exceptional mode.

Yokkaichi: View of the Mie River, from the series The Fifty-Three Stations of the Tōkaidō, Utagawa Hiroshige (c. 1833–34)
Yokkaichi: View of the Mie River, from the series The Fifty-Three Stations of the Tōkaidō, Utagawa Hiroshige (c. 1833–34)
Medal of Claude Joseph Rouget de L'Isle (1760-1836), Alfred Borrel (1911)
Medal of Claude Joseph Rouget de L'Isle (1760-1836), Alfred Borrel (1911)
Fish or Seal Club (X’ús’) (late 1800s–early 1900s)
Fish or Seal Club (X’ús’) (late 1800s–early 1900s)

Preparing for an inspection

  1. Gather

    Gather register, declarations and files.

  2. Check

    Check consistency.

  3. Designate

    Name a contact person.

  4. Reply

    Supply the documents.

  5. Follow

    Correct the remarks.

To have at hand

An inspector

Medal: Loïe Fuller (obverse), Pierre Roche (1900)
« The best inspection is the one where the operator shows us what it has perfected since last year. »
Inès Moreau, inspector

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

Roman Ruins, Villa Pamfili, Hubert Robert (1774)
Roman Ruins, Villa Pamfili, Hubert Robert (1774)
Legal Affairs DepartmentParis — Headquarters+33 1 00 00 02 00juridique@oimap.exampleMonday to Friday, 9 am – 5 pm

Discover anti-money laundering

Creamer, Louis Rorimer (c. 1910)

Another strand of compliance.

Anti-money laundering
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