record-retention

---
name: record-retention
description: Works out how long each record a UK hospitality business holds must be kept, in what format, under which regime (VAT, PAYE, Companies Act, Self Assessment, food safety), then produces a dated retention schedule and a plan for any record already missed. Use when sorting old paperwork or setting a shredding policy.
---

# How long you must keep it, in what form, and what to do once a deadline has passed

You give this your business structure, VAT and employer status, and your records with their dates and format. You get back a retention schedule with the legal minimum and citation for each, a format check, and a plan for anything missed. It will not guess a period, or reconstruct a lost record.

## What it does

1. **Fix which regimes apply**, often several at once: sole trader or landlord under Self Assessment, limited company under Companies Act, VAT registered under VAT law, employer under PAYE.

2. **VAT rule.** Notice 700/21 sets "at least 6 years," 10 under OSS/MOSS; till rolls count as records.

3. **Companies Act rule, for a limited company.** Section 388(4) sets "three years" for a private company, but HMRC asks six years from the financial year end, longer with a long-life asset, late return or open enquiry. Use the longer.

4. **Self Assessment rule.** Section 12B, TMA 1970, sets business records to "the fifth anniversary of the 31st January," penalty to £3,000; non-business records 22 months on time, 15 if late.

5. **PAYE rule.** Regulation 97 sets "not less than three years," "in any form or by any means."

6. **Map till rolls, Z-readings and invoices onto the longest applicable period, never their own**: named records under both VAT and Companies Act law.

7. **Food safety rule has no fixed number.** Regulation 852/2004 requires an "appropriate period" undefined; the FSA says keep diary pages "until your next visit from a local authority food safety officer."

8. **Hand the mechanical work to Codex**, run from the record list's folder:

   ```
   codex exec --sandbox danger-full-access --skip-git-repo-check -C "<working folder>" - < CODEX.md
   ```

9. **Plan any record already missed.** Get copies first, then a "provisional" or "estimated" figure in the "any other information" box, never invented. Record the breach, regime and date.

## Then it checks

1. Every regime is named, with its start date.
2. Every record carries its legal minimum and citation, nothing invented.
3. Till rolls, Z-readings and invoices carry the longest applicable period.
4. The food safety entry states plainly that no fixed period exists.
5. Every missed record is a named breach with a date.

Any check fails: name it, redo that step once. Failed twice: say what is wrong and stop.

## Rules
- Public information only.
- Never invent a fact, a number or a quote.
- Anything sent in someone's name says whose name it is.
- Never give one period for a record under several regimes; the longer governs.
- Never fill in what a lost record would show; record it missing, follow HMRC's steps.
- Never recommend a till, bookkeeping or archiving product.
- Working document for the owner's accountant, and, where a missed period sits inside an HMRC enquiry or Companies House matter, the business's solicitor. Not legal or tax advice.

## Built from
- HM Revenue and Customs, "Record keeping (VAT Notice 700/21)", https://www.gov.uk/guidance/record-keeping-for-vat-notice-70021, the page states "Updated 18 March 2024", read 14 October 2026: the 6-year and 10-year OSS/MOSS retention periods, till rolls as business records, and the digital electronic account rule, in steps 2 and 6.
- GOV.UK, "Keeping VAT records", https://www.gov.uk/charge-reclaim-record-vat/keeping-vat-records, no last-updated date shown on the page, read 14 October 2026: the 6-year minimum and the 10-year OSS/MOSS and bad-debt figures, in step 2.
- The Value Added Tax Regulations 1995, SI 1995/2518, regulation 31, https://www.legislation.gov.uk/uksi/1995/2518/regulation/31, read 14 October 2026: the duty to keep VAT records, cited for the duty itself rather than any retention period, which regulation 31 does not state.
- Companies Act 2006, section 388, https://www.legislation.gov.uk/ukpga/2006/46/section/388, read 14 October 2026: the 3 years private company and 6 years public company retention periods, in step 3.
- GOV.UK, "Running a limited company: your responsibilities", company and accounting records page, https://www.gov.uk/running-a-limited-company/company-and-accounting-records, no last-updated date shown, read 14 October 2026: the 6 years from the end of the financial year rule, the £3,000 fine, till rolls as a named record, and the three extension triggers, in steps 3 and 6.
- Taxes Management Act 1970, section 12B, https://www.legislation.gov.uk/ukpga/1970/9/section/12B, read 14 October 2026: the fifth-anniversary business record rule, the first-anniversary rule for other taxpayers, and the £3,000 penalty, in step 4.
- GOV.UK, "Keeping your pay and tax records" and its "How long to keep your records" page, https://www.gov.uk/keeping-your-pay-tax-records and https://www.gov.uk/keeping-your-pay-tax-records/how-long-to-keep-your-records, no last-updated date shown, read 14 October 2026: the 22-month and 15-month non-business periods and the provisional/estimated lost-records procedure, in step 9.
- GOV.UK, "Business records if you're self-employed", how long to keep your records page, https://www.gov.uk/self-employed-records/how-long-to-keep-your-records, no last-updated date shown, read 14 October 2026: the 5-year self-employed business rule and the 15-month rule for a return sent more than 4 years late, in step 4.
- The Income Tax (PAYE) Regulations 2003, SI 2003/2682, regulation 97, https://www.legislation.gov.uk/uksi/2003/2682/regulation/97, read 14 October 2026: the 3-year PAYE retention period and the "any form or by any means" preservation rule, in step 5.
- GOV.UK, "PAYE for employers: keeping records", https://www.gov.uk/paye-for-employers/keeping-records, no last-updated date shown, read 14 October 2026: what counts as a PAYE record, the £3,000 penalty, and the lost-records instruction, in steps 5 and 9.
- Regulation (EC) No 852/2004, Article 5, https://www.legislation.gov.uk/eur/2004/852/article/5, read 14 October 2026: the documents and records duty in paragraph 2(g) and the "appropriate period" retention wording in paragraph 4(c), in step 7.
- Food Standards Agency and GOV.UK, "Safer Food Better Business (SFBB)", https://www.gov.uk/government/publications/safer-food-better-business-sfbb/safer-food-better-business-sfbb, the page states "Published 5 June 2025", read 14 October 2026: the instruction to keep diary pages until the next local authority visit, electronically or in print, in step 7.

# record-retention

## You are given
One UK independent hospitality business's record-retention position, already judged by Claude: its legal structure (sole trader, partnership, landlord or limited company), its VAT registration date, and its employer/PAYE start date. A list of every record type held, each with its item name, the date created or last entered, its current format (paper, digital file or named software), and which regime it falls under. For each applicable regime, the legal minimum period already looked up, with its citation, the date it starts running, and the format required, including the food safety regime, where the period has no fixed figure and the FSA's own instruction is given instead. Any record whose period has already been missed, with what happened and the owner's remedial plan and date. All judgement, including which regime governs a record under more than one, is already made and supplied.

## Produce
Write into `./record-retention-output/`:

1. `retention-schedule.csv` columns: `record_ref`, `record_type`, `regime`, `authority_and_citation`, `legal_minimum_period`, `period_start_trigger`, `format_required`, `date_record_created`, `earliest_safe_disposal_date`, `current_format_held`, `status`. `record_ref` is R001 upward. `earliest_safe_disposal_date` is calculated only from the supplied `date_record_created` and `legal_minimum_period`, left empty if either is missing. `status` is exactly one of `compliant`, `at risk`, `breached`, `cannot be determined`.
2. `format-check.csv` columns: `record_ref`, `record_type`, `format_required`, `current_format_held`, `format_compliant` (`yes`, `no`, `not stated`).
3. `missed-retention.md` one entry per record whose period lapsed early, naming the regime breached, the supplied penalty exposure, and the owner's remedial action and date, exactly as supplied.
4. `action-list.md` a dated numbered list, earliest `earliest_safe_disposal_date` first, naming the person responsible.
5. `gaps.md` every record with no supplied creation date, no citation, no stated format, or a regime marked `cannot be determined`.

## Rules
- Codex transcribes, sorts and calculates dates from supplied figures only. It never decides which regime governs a record, never sets a retention period, and never judges whether a format is adequate.
- Never calculate `earliest_safe_disposal_date` from an assumed or inflated creation date. Leave it empty where the input is missing.
- Never shorten a period because a record "seems unimportant." Only a supplied legal minimum sets the date.
- Never invent a penalty figure or a citation not supplied.
- British English, GBP as `GBP`, DD Month YYYY dates. No em dashes; any supplied text containing one is recorded verbatim and flagged in `gaps.md`.
- Every file ends with: working document for the owner's accountant, and, where a missed period sits inside an HMRC enquiry or Companies House matter, the business's solicitor. Not legal or tax advice.

## Return
Absolute path of every file written, row count of each CSV, count of records with `status` of `breached`, the oldest `date_record_created` and its item, count of `format_compliant` of `no`, and the `gaps.md` item count.

Sources for record-retention

Everything below was opened and read on 14 October 2026. Nothing is cited that could not be loaded.

1. HM Revenue and Customs, "Record keeping (VAT Notice 700/21)"

https://www.gov.uk/guidance/record-keeping-for-vat-notice-70021, the page states "Updated 18 March 2024", read 14 October 2026.

This is the primary source for the VAT retention rule in step 2. The core sentence is plain: "Generally, you must keep all your business records for VAT purposes for at least 6 years," rising to 10 years under the One Stop Shop or Mini One Stop Shop schemes. The notice also settles the till rolls question that owners most often get wrong, naming "records of daily takings such as till rolls" as business records in their own right, and it confirms that the underpinning paper evidence behind a digital daily gross takings figure, such as till rolls or Z-readings, does not itself have to be kept digitally even where the summary figure must be.

Where the skill departs: the notice runs to detailed sections on VAT accounting schemes, invoice content requirements and partial exemption, none of which bears on how long a record must be kept, so only the retention period, the till rolls classification and the digital/non-digital distinction are used.

2. GOV.UK, "Keeping VAT records"

https://www.gov.uk/charge-reclaim-record-vat/keeping-vat-records, no last-updated date shown on the page, read 14 October 2026.

This shorter public-facing page restates the 6-year minimum in plain language, "You must keep VAT records for at least 6 years," and gives the 10-year figure for OSS and the separate 4-year (10-year under MOSS) period for bad debt relief records, which the skill does not carry forward because bad debt relief sits outside the record types this skill covers.

Where the skill departs: the page's list of what to keep (invoices, self-billing agreements, debit and credit notes) is folded into the general "VAT records" category in step 2 rather than itemised, since Notice 700/21 is the fuller and more authoritative source for content.

3. The Value Added Tax Regulations 1995, SI 1995/2518, regulation 31

https://www.legislation.gov.uk/uksi/1995/2518/regulation/31, read 14 October 2026.

This is the statutory duty behind the VAT record keeping obligation, opening "Every taxable person shall, for the purpose of accounting for VAT, keep the following records." It is cited deliberately for the duty itself and not for a retention period, because the regulation does not state one: the period comes from HMRC's published notice under its own powers, not from this regulation directly, and the skill records that distinction rather than attributing the 6 years to regulation 31.

Where the skill departs: the regulation's detailed list of records (the VAT account structure, specific invoice retention rules) is not reproduced, since Notice 700/21 already gives the practical version.

4. Companies Act 2006, section 388

https://www.legislation.gov.uk/ukpga/2006/46/section/388, read 14 October 2026.

Subsection (4) is the statutory minimum used in step 3: "three years from the date on which they are made" for a private company and six years for a public company. This is the floor set by company law itself, separate from and shorter than the tax-driven period in source 5.

Where the skill departs: subsections (1) to (3), on where records must be physically kept and the requirement to send overseas accounts back to the UK, are not reproduced, since they govern storage location rather than duration.

5. GOV.UK, "Running a limited company: your responsibilities", company and accounting records page

https://www.gov.uk/running-a-limited-company/company-and-accounting-records, no last-updated date shown, read 14 October 2026.

This is HMRC's practical guidance layered on top of the Companies Act minimum, and it is the source of the longer, tax-driven figure the skill actually recommends following: "You must keep records for 6 years from the end of the last company financial year they relate to, or longer if" one of three conditions applies, including a long-life asset, a late Company Tax Return, or an open compliance check. It also supplies the £3,000 HMRC fine for failing to keep accounting records, and lists till rolls explicitly among the records to keep. The gap between this page's 6 years and section 388(4)'s 3 years for a private company is recorded openly in step 3 rather than resolved into one number, because both are true and the longer one governs.

Where the skill departs: secondary commentary on statutory registers and board minutes, which several non-official sources claim need 10 years, is not used, since no gov.uk or legislation.gov.uk page checked for this skill confirms that figure.

6. Taxes Management Act 1970, section 12B

https://www.legislation.gov.uk/ukpga/1970/9/section/12B, read 14 October 2026.

This is the statutory basis for the Self Assessment record-keeping duty in step 4. Subsection (1) requires a person to "preserve those records until the end of the relevant day," and subsection (2) fixes that day, for a person carrying on a trade, profession or business or a company, as "the fifth anniversary of the 31st January next following the year of assessment," with a shorter first-anniversary rule for anyone else. Subsection (5) sets the penalty at "a penalty not exceeding £3,000."

Where the skill departs: the subsection (6) extension that treats a person letting property as carrying on a trade for this purpose is folded into "landlord" in the skill's plain language rather than quoted separately.

7. GOV.UK, "Keeping your pay and tax records" and "How long to keep your records"

https://www.gov.uk/keeping-your-pay-tax-records and https://www.gov.uk/keeping-your-pay-tax-records/how-long-to-keep-your-records, no last-updated date shown on either page, read 14 October 2026.

These pages give the shorter, non-business Self Assessment periods used in step 4: "You should keep your records for at least 22 months after the end of the tax year the tax return is for" on time, or "at least 15 months after you sent the tax return" if late. The first page is also the source for the missed-records procedure in step 9: try to get copies first, then use a figure marked "provisional," meaning paperwork to confirm it will follow, or "estimated," meaning it cannot be confirmed, declared in the "Any other information" box of the return.

Where the skill departs: the pages' general statement that records can be kept "on paper, digitally or as part of a software program" with no required format is used only as the default position, since VAT MTD overrides it for VAT-registered businesses, which source 1 covers separately.

8. GOV.UK, "Business records if you're self-employed", how long to keep your records page

https://www.gov.uk/self-employed-records/how-long-to-keep-your-records, no last-updated date shown, read 14 October 2026.

This page carries the longer 5-year rule that actually applies to a sole trader's or landlord's business income and cost records, distinct from the shorter 22-month figure in source 7, which only governs non-business Self Assessment paperwork: "You must keep your records for at least 5 years after the 31 January submission deadline of the relevant tax year." It also gives the 15-month rule for a return filed more than 4 years late, and the instruction that "If you cannot replace your records, you must do your best to provide figures."

Where the skill departs: nothing is omitted; both the on-time and the very-late return rules on this page are used in full in step 4 and step 9.

9. The Income Tax (PAYE) Regulations 2003, SI 2003/2682, regulation 97

https://www.legislation.gov.uk/uksi/2003/2682/regulation/97, read 14 October 2026.

This is the statutory PAYE retention rule in step 5: an employer must keep PAYE records "for not less than three years after the end of the tax year to which they relate," and the duty "may be discharged by preserving them in any form or by any means," which the skill reads as confirming no particular format is required.

Where the skill departs: the regulation's list of which specific PAYE records are covered is not reproduced in detail, since GOV.UK's own employer page (source 10) gives the practical list.

10. GOV.UK, "PAYE for employers: keeping records"

https://www.gov.uk/paye-for-employers/keeping-records, no last-updated date shown, read 14 October 2026.

This page restates the 3-year rule in plain language and lists what counts as a PAYE record (pay and deductions, reports and payments to HMRC, leave and sickness absences, tax code notices, taxable expenses or benefits). It gives the penalty, "HMRC may estimate what you have to pay and charge you a penalty of up to £3,000," and the lost-records instruction, "Tell HMRC as soon as possible if you do not have records and cannot replace them," used in step 9.

Where the skill departs: a commonly repeated claim that National Minimum Wage records must be kept for 6 years was found only in non-official secondary sources during research and could not be confirmed on a gov.uk or legislation.gov.uk page in the time available, so it is not included anywhere in the skill.

11. Regulation (EC) No 852/2004, Article 5

https://www.legislation.gov.uk/eur/2004/852/article/5, read 14 October 2026.

This retained/assimilated EU regulation is the legal basis for the food safety records duty in step 7. Article 5(2)(g) requires "establishing documents and records commensurate with the nature and size of the food business," and Article 5(4)(c) requires operators to "retain any other documents and records for an appropriate period," a deliberately open phrase the article does not itself define.

Where the skill departs: the article's detailed HACCP principles (hazard analysis, critical control points, monitoring procedures) are not reproduced, since the skill's scope is the retention question, not the design of a HACCP system.

12. Food Standards Agency and GOV.UK, "Safer Food Better Business (SFBB)"

https://www.gov.uk/government/publications/safer-food-better-business-sfbb/safer-food-better-business-sfbb, the page states "Published 5 June 2025", read 14 October 2026.

Because Article 5(4)(c) leaves the retention period open, this is the practical answer most UK hospitality businesses actually follow: "Store all your completed diary pages safely until your next visit from a local authority food safety officer," and "This can be done electronically or with printed copies."

Where the skill departs: nothing is omitted; the page's instruction is quoted in full in step 7 as the practical standard sitting alongside, not replacing, the undefined statutory duty.

The best public prompt found

A search of the anthropics/knowledge-work-plugins repository tree, read via api.github.com on 14 October 2026, found no skill named for record retention, document retention or anything UK tax-specific. The two closest matches by name are `legal/skills/compliance-check` and `operations/skills/compliance-tracking`. Neither covers how long a record must be kept: compliance-check runs a regulatory review of a proposed product or feature against GDPR, CCPA and similar privacy law, mentioning retention only as an exemption to a data deletion request; compliance-tracking monitors audit readiness against frameworks such as SOC 2, ISO 27001, GDPR, HIPAA and PCI DSS, tracking evidence and control deadlines but never a document retention schedule. Both sit in the repository with its overall star count of 29,621, read from api.github.com/repos/anthropics/knowledge-work-plugins on 14 October 2026; neither file carries its own separate count.

A search of the anthropics/skills repository tree, read the same way, found no file path containing "retention," "record" or "compliance" at all.

What was deliberately not copied. No public skill in either repository attempts a UK record-retention question, and the two named-adjacent compliance skills are built around US and EU data-protection and audit frameworks, not VAT, PAYE, Companies Act or Self Assessment retention law. Borrowing their scaffolding would import a privacy-and-audit shape onto a question that is actually about which of several overlapping UK statutory clocks runs longest on a given piece of paper, so a generic compliance prompt would be the wrong shape here even before any content was swapped in.