Record retention Current

Setting a client record retention schedule in Canada

Five years is the number, but it doesn't start on the same date for every record.

FINTRAC's record-keeping requirements for accountants set a five year minimum retention period, but that period starts from a different point depending on which record it is. This guide sets out how to schedule around that. It is general information, not legal or compliance advice.

Action plan

1 Apply the five year minimum across the record types that trigger it The five year period applies to several distinct record types, not one blanket file.

FINTRAC's record-keeping guidance for accountants sets a minimum five year retention period for receipt of funds records, large cash transaction records, large virtual currency transaction records, and copies of large cash and large virtual currency transaction reports, suspicious transaction reports, and listed person or entity property reports. Build a schedule that covers each of these record types separately, rather than assuming one retention date covers a client's whole file.

  • Identify which of FINTRAC's listed record types apply to a given client relationship
  • Apply the five year minimum retention period to each
  • Don't assume a single retention date covers every record type in a client's file

Done when: Every applicable FINTRAC record type for a client has a tracked five year retention period

FINTRAC: record keeping requirements for accountants
2 Track the correct start date for each record type Some records count from when they were created; others count from when they were submitted.

FINTRAC's guidance sets the five year period for a receipt of funds record, a large cash transaction record, or a large virtual currency transaction record from the date the record was created. For a suspicious transaction report or a listed person or entity property report, the same five year period instead runs from the date the report was submitted to FINTRAC. Track these as two separate clocks rather than defaulting every record to the same start date.

  • Start the retention clock from the creation date for receipt of funds and large transaction records
  • Start the retention clock from the submission date for suspicious transaction reports and property reports
  • Don't apply a single start-date rule across every record type

Done when: Each record's retention start date matches whether FINTRAC counts from creation or from submission

3 Know the dollar threshold that creates a receipt of funds record in the first place The retention obligation only bites once the underlying record exists.

FINTRAC's guidance states that receiving an amount of $3,000 or more in funds creates the obligation to keep a receipt of funds record. Confirm which client transactions actually cross that threshold before assuming a retention schedule entry is needed, rather than applying the five year rule to transactions that never triggered the record in the first place.

  • Check which client transactions reach the $3,000 receipt of funds threshold
  • Only schedule retention for records FINTRAC's guidance actually requires you to create
  • Revisit the schedule whenever a new transaction crosses the threshold

Done when: Retention schedule entries exist only for transactions that actually crossed FINTRAC's stated thresholds

See storing client identity evidence securely