What is the archive register and who must maintain it
The archive register is the core record of all the registry material that a creator holds. Under public records and tax law, the obligation to maintain a records register applies to all legal and natural persons whose activity creates documentation of permanent or long-term value: companies, sole traders, public bodies, state-owned enterprises, institutions, law firms, accounting firms, medical practices and associations.
In other words, if your business issues invoices, signs contracts, runs a payroll or communicates with public authorities, you are required to keep an archive register. It does not matter whether you trade as a Ltd, PLC, sole trader or association. What matters is that documentation arises.
What must be recorded
The archive register does not capture every individual document, but rather the annual volume created per category from your records retention policy. Typical categories:
- Financial documentation: invoices, delivery notes, bank statements, cash reports, customer and supplier contracts, accounting records.
- HR documentation: employment contracts, payroll filings, leave records, decisions, settlement agreements, employee files.
- Legal acts and correspondence: general acts, articles of association, internal policies, board resolutions, minutes of general meetings and board meetings.
- Property documentation: sale and purchase agreements, lease contracts, vehicle registration, certificates, building permits.
- Court and tax documentation: claims, judgments, tax authority decisions, inspection reports.
- Technical documentation: drawings, certificates, test reports, site logs (for construction firms).
Entry format: what exactly you record
Each entry in the archive register typically includes:
- Sequence number running continuously from incorporation
- Year of creation of the documentation
- Number from the classification scheme (category)
- Content (short description, e.g. Outgoing invoices 2024)
- Quantity (number of folders, files, boxes or linear metres)
- Storage location (office, warehouse, external provider)
- Retention period in years
- Notes (e.g. digitised, disposed 2034)
Retention periods by category
| Type of documentation | Retention period |
|---|---|
| Financial and accounting | 6 years (HMRC), 7 years (IRS) |
| Payroll, employee files | 6 to 50 years depending on document type |
| Property contracts | 10 years after expiry |
| Articles, general acts, meeting minutes | permanent |
| Court cases | 10 years after final judgment |
| Tax assessments and audit reports | 6 to 7 years |
| Operational correspondence | 2 to 5 years |
Submission to the relevant archive
The archive register is maintained continuously, and a copy is submitted to the relevant national or regional archives once a year, in practice by 30 April for the prior year, where local rules require it. Jurisdiction follows the registered office of the company. London-based entities, for example, fall under the regional records office; entities outside the major centres come under regional historical archives.
Alongside the archive register, a proposal for disposing of valueless registry material (records past retention) is also prepared annually. Disposal is carried out only with archive approval, never on your own.
Electronic archive register
Under recent legal updates, the electronic archive register is legally equivalent to the paper one. That means you can keep it in software, store it digitally signed and submit it to the archive in electronic form (XML, PDF/A signed with a qualified electronic signature). Most relevant archives are moving to electronic intake from 2026, and some already accept it.
Advantages of the electronic form: zero loss (the register cannot be lost or damaged like a paper one), automatic registration as soon as the document is entered into the DMS, full-text search instead of leafing through pages, automatic disposal date calculated for every entry.
Penalties for incorrect maintenance
Inspections of archive material are carried out by the relevant archives authority and, in tax matters, by the tax authority (HMRC, IRS or the equivalent). Penalties typically range for legal entities from 5.000 to 50.000 EUR for failing to maintain the archive register, irregular entries, an unaligned classification scheme or unauthorised disposal of records. For the responsible person within the entity, additional fines apply. In practice, penalties are most often imposed after a complaint (e.g. by a former employee in a dispute) or as part of a tax audit.
Most common mistakes in practice
- No classification scheme: the archive register is kept by feel, with no grounding in a records retention policy. Inspectors spot it immediately.
- Entries without retention periods: what exists is recorded, but the retention period is not stated. Result: nothing is ever disposed of, the archive grows without limit.
- Unauthorised disposal: the company cleared out the warehouse because the records are more than 10 years old. Without archive approval, that is a breach, even if the retention period has actually elapsed.
- Mixing active and archived material: documentation from the current year is not entered into the archive register (it is tracked through the daily log). It only enters the archive register after the year is closed.
- Forgotten submission: the company keeps the register diligently but does not submit a copy to the archive. The submission obligation is separate from the maintenance obligation.
