The operator's memory

The transaction register is a log in which the operator records, as they happen, each of its transactions: purchases, sales, deposits, agency contracts. It is the central piece of its compliance.
It must be kept chronologically, completely and tamper-proof. A timestamped digital register is recommended; a bound and initialled paper register is still allowed.
This page details the content, format and retention rules.
Transaction registers in figures
Source: OIMAP Legal Affairs Department.
What the register must contain
For each transaction, the register states: the date, the nature (purchase, sale, deposit, agency), the description of the work and its OIMAP number, the identity of the parties, the price and fees, the method of payment, the attached due diligence documents and the reference of the declaration sent to the Observatory.
It also keeps corrections: an error is never erased, it is corrected by a dated rectifying entry. This rule guarantees the integrity of the register.



Retention and access
The register is kept for ten years after the last transaction. It must be possible to produce it to the supervisory authority within fifteen days. The personal data it contains are protected: only authorised officers have access.
On transfer or cessation of business, the operator hands over its register to its successor or deposits it with the competent authority. An operator who disappears without doing so is liable to sanctions.
Register and due diligence
The register is the extension of the due diligence file: it refers to it for each transaction, so that an inspector can find, from one line of the register, all the checks carried out. This link is the key to compliance.
Operators that have adopted it note a double benefit: their inspections go faster, and their teams find information more easily to answer a client, an insurer or a court.
The mandatory fields
| Field | Content | Example |
|---|---|---|
| Date | Day of the transaction | 2025-03-14 |
| Nature | Purchase, sale, deposit, agency | Sale |
| Work | Description and OIMAP number | OIMAP-2023-001284-A |
| Parties | Identity of buyer and seller | Kept, not disclosed |
| Price | Price excluding fees and currency | €18,500 |
| Payment | Method and date | Transfer of 18 March |
| Due diligence | File reference | DIL-2025-0214 |
| Declaration | Receipt reference | DEC-2025-1043 |
Landmarks
- Obligation
Directive 2019-04.
- Standard template
Standardised register.
- Digital register
Timestamped version.
- 78% of registers digital
Steady progress.
A tamper-proof register
Paper or digital register

Paper
Bound and initialled register- Simple
- No technology
- Difficult to search
For small volumes.

Digital
Timestamped software- Fast search
- Secure archiving
- Sharing with authorities
Recommended.



Setting up a register
- Choose
Paper or digital.
- Configure
Adopt the standard template.
- Train
Inform the teams.
- Refer
Record as things happen.
- Back up
Archive regularly.
Points to check
An administrative director

« Our digital register has become our best management tool: we find everything in ten seconds. »
Vocabulary of the register
- Registry
- Chronological log of transactions.
- Rectifying entry
- Dated correction of an error.
- Timestamping
- Marking the date of an entry.
- Initialling
- Signature placed on each page.
Frequently asked questions
Is a spreadsheet enough?
If it is timestamped and protected against alteration, yes.
Who can consult the register?
Authorised authorities.
What to do in case of loss?
Declare it immediately to the authority.
Where can I find a template?
In the useful documents on this page.
Useful documents
Contacts

See the inspections
Image credits (16)
- Portrait of Gianfrancesco Gonzaga di Ròdigo, 1443–1496, Lord of Sabbionetta (reverse), Antico (1479) — Cleveland Museum of Art, CC0 1.0
- Chemin de fer de Toulouse à Bayonne. Pont de l'Aran (en trois arches de 17m d'ouverture chacune). Situation des travaux au 21 juillet 1861, Édouard Baldus (1861) — Cleveland Museum of Art, CC0 1.0
- Electrotype Replica of Tetradrachm: Head of Athena (obverse); Owl (reverse) (1838–1916) — Cleveland Museum of Art, CC0 1.0
- Teapot, Louis Rorimer (c. 1910) — 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
- Mercury (Budha), from a Mandi Astrology Series, Sanju (c. 1810) — Cleveland Museum of Art, CC0 1.0
- Solidus of Justinian I (c. 545–65) — Cleveland Museum of Art, CC0 1.0
- Beaker (c. late 600s–early 700s) — 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
- Seal Color Box (1662–1722) — Cleveland Museum of Art, CC0 1.0
- Medal Depicting Gian Lorenzo Bernini (1598-1680) from the Illustrious Men of the Kingdom of the Two Sicilies (obverse), V. Catenacci (1830–34) — Cleveland Museum of Art, CC0 1.0
- A Palace with an Arched Bridge (A Roman Villa), Hubert Robert (1760) — Cleveland Museum of Art, CC0 1.0
- Coin of Eukratides I (170–145 BCE) — 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
- Annunciation to the Shepherds: Leaf from a Book of Hours (1 of 6 Excised Leaves), Henri d'Orquevaulx (c. 1420–30) — Cleveland Museum of Art, CC0 1.0
- Scenes of Daily Life, Roads and Paths: Road to Market (Scènes de la vie quotidienne, Routes et Chemins: Route du Marché), Carle Vernet (1819) — 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.›
Transparency inspectionsHow the authority checks declarations and registers: course of an inspection, operator's rights, sanctions and remedies.›
Due diligenceThe checks every operator must carry out before buying, selling or presenting a work: guide, checklists and templates.›