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Review the overdue regulatory records

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RISK-REG-0001: eight-year voucher period (BEG IV) confirmed against
secondary sources and §147 AO. RISK-POL-0009/0002: positions unchanged; new
restore evidence noted as partial. RISK-POL-0012: receiving duty still
unowned; issuing phase-in dates added, flagged for confirmation.
RISK-POL-0011: stays dormant.

Co-Authored-By: Claude Opus 5 <noreply@anthropic.com>

Assistant: claude-code
Assistant-Model: opus
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tegwick 2026-09-22 08:26:43 +02:00
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docs/regulatory/policies/RISK-POL-0009-commercial-and-tax-retention.md
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@ -7,10 +7,11 @@ status: active
activates_when: "the estate keeps commercial books or issues and receives invoices — already true"
owner: risk-nexus
written: "2026-08-20"
cadence: instant
clean_streak: 0
last_checked: "2026-08-20T21:30:00Z"
next_check: "2026-08-20T21:30:00Z"
cadence: 1h
clean_streak: 1
last_checked: "2026-09-22T06:26:01Z"
next_check: "2026-09-22T07:26:01Z"
checked_by: "worsch"
---
# RISK-POL-0009 — commercial and tax retention
@ -31,9 +32,11 @@ made or the document created — not from the document's own date. That detail
is the one most often got wrong, and it always extends the period rather than
shortening it.
**The eight-year figure is recent and this repo has not verified it against the
current text.** Confirm before relying on it for a deletion decision; ten years
is the safe reading if nobody has.
**The eight-year figure was confirmed on 2026-09-22** (see `RISK-REG-0001`). It
comes from BEG IV, promulgated 2024-10-29, and has applied since 2025-01-01,
including to vouchers whose period had not run out by then. This rests on
secondary sources and the published §147 AO text, not on a qualified review.
Books and annual accounts stay at ten years.
## What it requires of systems
@ -64,3 +67,16 @@ retained period; a deletion routine that actually runs at expiry.
None of those exist yet. This policy is `active` in the sense that the duty
applies, not in the sense that it is demonstrably satisfied — and the register
says which.
**2026-09-22 review.** Some new evidence exists but it does not satisfy the
duty. Restores are now proven for `apps-pg` from the Scaleway primary and for
Forgejo from the Nextcloud secondary (RPF-WP-0029, RPF-WP-0038). Neither is a
restore from the oldest retained period, and neither lane holds books or
vouchers as a named record class. The secondary lane's 10 GiB quota holds about
two archives, which is far short of an eight-year horizon. There is still no
retention schedule and no expiry deletion routine, so the position above is
unchanged.
## Reviews
- **2026-09-22** — clean check: Position unchanged: duty applies, not demonstrably met; eight-year voucher period confirmed; new restore evidence (apps-pg, Forgejo) does not cover book/voucher classes or the oldest period. Cadence instant → 1h (1 clean in a row); next check 2026-09-22 07:26Z.