US Record Keeping Requirements: A Practical Guide for Businesses

When it comes to staying on the right side of the law, record keeping requirements are the backbone of compliance for any U.S. organization. Whether you run a small startup, manage a multinational export business, or provide healthcare services, you’ll face distinct rules that dictate what you must document, how long you keep it, and how you prove it when regulators ask.

Why Understanding the Landscape Matters

Miss a deadline or store data the wrong way, and you could be looking at hefty fines, forced shutdowns, or costly legal battles. The good news? By breaking down the mandates from each agency, you can build a single, streamlined system that meets every demand without duplicated effort.

Key Regulatory Domains and Their Core Obligations

Below is a quick snapshot of the eight major regulators you’ll encounter. Each entry includes the agency’s primary focus, the type of records it demands, and the minimum retention period.

• Bureau of Industry and Security (BIS): Controls export documentation under the Export Administration Regulations. Requires immutable electronic logs, written procedures, and a full audit trail. No set calendar limit; records must be retrievable indefinitely or until the transaction is no longer subject to export controls.
• Internal Revenue Service (IRS): Demands proof of income, deductions, and employment taxes. Keep all tax‑related documents for at least four years after filing; payroll tax records must survive that period, too.
• Occupational Safety and Health Administration (OSHA): Requires injury and illness logs (OSHA 300/301) to be retained for five years after the end of the calendar year they cover.
• Equal Employment Opportunity Commission (EEOC): Mandates payroll and personnel records for three years, plus documentation supporting discrimination investigations.
• Department of Labor (DOL): Calls for accurate employee data but leaves format open; records must be kept long enough to satisfy any DOL audit, typically three to five years.
• Global Investment Performance Standards (GIPS): Financial firms must preserve policies, procedures, and performance data - both current and historical versions - indefinitely to back up compliance claims.
• Connecticut Licensed Clinical Social Worker (LCSW): Requires client treatment plans, diagnosis justification, dates of service, and signed entries. Minimum retention: seven years from last treatment date, or three years after patient death.
• Department of Public Health (CT): Oversees LCSW compliance and can impose penalties for missing records.

Retention Periods at a Glance

Building a Unified Record‑Keeping System

Trying to run separate spreadsheets for each regulator quickly becomes a nightmare. Here’s a step‑by‑step approach that works for most midsize firms:

1. Map every business process to the regulatory requirements it touches. Use a simple matrix: process → regulator → record type → retention.
2. Select a core document management platform that supports immutable logs (e.g., a cloud WORM‑compliant service). Make sure it offers granular permission controls for HIPAA or export‑control data.
3. Define written procedures for each system - who creates, reviews, signs, and archives a record. BIS explicitly demands documented responsibility, and GIPS expects version‑controlled policies.
4. Implement automated retention schedules. Most DMS tools let you set rules that automatically purge or archive files after the stipulated period.
5. Run quarterly internal audits. Verify that records exist where they should, are properly signed, and that audit trails are intact.

When you follow this loop, you satisfy the “audit‑ready” principle demanded by the Office of Export Enforcement, the IRS, and the EEOC alike.

Common Pitfalls and How to Avoid Them

• Assuming one format fits all. Paper works for the IRS, but export logs need immutable electronic files. Mix‑and‑match at your peril.
• Skipping version control. GIPS auditors will flag any missing historical policy version. Use a system that logs every edit with timestamps.
• Neglecting third‑party records. If a cloud vendor stores your data, you remain responsible for compliance. Secure service‑level agreements that guarantee access to archived files.
• Overlooking state‑specific rules. Connecticut LCSW requirements are stricter than many other states. Make sure your health‑records module can retain seven‑year archives and flag post‑mortem timelines.
• Failing to train staff. Written procedures are meaningless if no one knows them. Conduct annual compliance workshops covering each regulator’s core obligations.

Preparing for an On‑Site Inspection

Regulators like BIS, OSHA, and the EEOC can show up unannounced. A quick checklist can make the difference between a smooth walkthrough and a costly citation:

1. Have a master index that points to the exact location (system, folder, or physical box) of every required record.
2. Ensure the index lists who created the record, when, and on what equipment - a BIS requirement.
3. Verify that access logs show who opened each file in the past 12 months.
4. Confirm that any paper records are stored in a fire‑proof, locked cabinet with controlled entry.
5. Provide a short briefing to the inspector showing your retention schedule and how you’ll retrieve records within the required timeframe (usually 24‑48 hours).

Key Takeaways

• Different agencies demand different record types, formats, and retention periods; a unified matrix keeps you organized.
• Immutable electronic logs are non‑negotiable for export‑control (BIS) and financial compliance (GIPS).
• Retention periods range from three years (EEOC payroll) to indefinite (GIPS, BIS).
• Third‑party service providers do not relieve you of compliance responsibility.
• Regular internal audits and staff training are the cheapest way to avoid costly regulator surprises.

Frequently Asked Questions

What records does the BIS specifically require for export transactions?

BIS mandates that every export license, shipping document, and related communication be captured in an immutable electronic system. The system must log who entered the data, when it was entered, and on which equipment, and must retain the full audit trail for as long as the transaction remains subject to export control.

How long do I need to keep IRS tax records for a small business?

The IRS requires you to keep all records that support income, deductions, or credits for at least four years after the filing date. If you file a claim for a loss or a credit that could affect future tax years, keep those documents for seven years.

Do I need to retain old versions of GIPS policies?

Yes. GIPS requires firms to keep every version of policies and procedures that were in effect during any reporting period you claim compliance for. This means a perpetual archive of historical documents, not just the latest edition.

What are the retention rules for OSHA injury logs?

OSHA 300 and 301 logs must be kept for five years after the end of the calendar year they cover. The logs must be available for inspection by OSHA or a state plan agency upon request.

How can a small practice meet Connecticut LCSW record‑keeping standards?

Maintain an electronic health‑record (EHR) system that timestamps each entry, forces a signature field that includes the "LCSW" designation, and automatically archives records for seven years after the last service date. If a client passes away, set the system to retain the file for three additional years.