How long Ontario dealers must keep deal records: the six-year rule explained
Registered Ontario motor vehicle dealers must keep vehicle and trade records for at least six years after the date of the contract or trade they relate to, and business records for six years after the record is made (O. Reg. 333/08 s. 56(1)); the garage register runs on the same six-year clock (s. 57). A general dealer keeps them at a non-dwelling place it trades from, or another non-dwelling place the Registrar approves (s. 56(2)). Electronic records are allowed — OMVIC's Electronic Record-Keeping Guideline confirms dealers may keep records electronically either instead of or alongside paper — but going electronic comes with two obligations most lots miss: telling the Registrar in writing when your records live somewhere new (including a cloud service), and keeping a backup separate from the primary copy. Here's how the six-year rule actually works, and what it means for a lot that's still filing deals in a cabinet.
Ask ten Ontario dealers how long they have to keep a deal file and you'll get four answers: five years, seven years, “forever, just in case,” and a shrug. The real answer is six — and the interesting part isn't the number, it's the two conditions attached to it that almost nobody at a small lot has actually read.
Registrants must keep records for six years, at a location approved by the Registrar. Electronic records are allowed — instead of paper or alongside it. If your records move off-site, including into a cloud service, you must notify the Registrar in writing within five days of a change in address for service. And OMVIC strongly recommends a backup kept separate from the primary copy.
Where the six years comes from
The rule is section 56(1) of Ontario Regulation 333/08 under the Motor Vehicle Dealers Act, 2002: a registered dealer shall retain a record required under section 52, 53 or 54 for at least six years. Those three sections are the list of what you have to keep:
- Section 52: a record of every vehicle that comes into your possession for the purpose of a trade, including the VIN, a copy of any safety standards certificate you were given, the results of any inspection, and the work you had done on it. In practice, the purchase side of every deal file.
- Section 53: records of each trade and each consignment contract, which is the sale side: the bill of sale, disclosures, trade-in paperwork and funding.
- Section 54: records of the business itself, including employees, their positions, pay and proof of payment, and the people associated with the dealer.
Section 57 adds the garage register: the record kept under Highway Traffic Act s. 60(1) and the one under section 4 of Regulation 595 both carry the same six-year minimum. OMVIC's Electronic Record-Keeping Guideline summarizes all of this as six years at a location approved by the Registrar; the regulation is where the detail lives.
Six years from when?
This is the question the summary versions skip, and the regulation answers it precisely. The clock does not start when you file the deal, close the month or sell the car. It starts on a date tied to the record:
| Record | Six years runs from | Rule |
|---|---|---|
| Vehicle record (purchase side, s. 52) | The date of the trade the record relates to | s. 56(1)(a) |
| Sale or consignment record (s. 53) | The date of the trade or consignment contract | s. 56(1)(a) |
| Business records: staff, pay, associates (s. 54) | The date the record is made | s. 56(1)(b) |
| Garage register entry (HTA s. 60(1)) | The date of the contract under which you bought or sold the vehicle | s. 57(2) |
| Regulation 595 s. 4 record | The date the record is made | s. 57(3) |
A worked example. You buy a car at auction on 14 March 2026 and sell it on 22 August 2026. The purchase record and the register's “in” entry are tied to the March trade; the bill of sale and the “out” entry to the August one. The earliest you could discard the purchase record is 14 March 2032, but the file isn't clear until 22 August 2032. Keep the whole jacket until the later date: splitting one car's file across two purge dates is how documents go missing.
On a lot doing 15 cars a month, that means roughly 1,000 deals sit inside the retention window at any time, plus the trades and the wholesale units. That is a filing-system problem long before it is a compliance problem.
One more rule worth knowing: if a record under section 52, 53 or 54 becomes unavailable because of force majeure (a fire, a flood), section 55 requires you to advise the Registrar in writing within five days and say what happened. Losing the records doesn't end the obligation; it starts a reporting one.
Where the records can live
Section 56(2) sets the place, and it is stricter than most dealers assume. A general dealer keeps its records at either:
- a place, other than a dwelling, from which the dealer is authorized to trade (your registered premises), or
- another place, other than a dwelling, that the dealer chooses and the Registrar approves.
So the boxes of old deals in the basement at home are not a compliant archive for a retail lot. The separate rule in s. 56(2)(a), which still requires the Registrar's approval, applies only to outside Ontario dealers, lease finance dealers, fleet lessors, and brokers or wholesalers who actually trade from a dwelling. If you wholesale from home, that is the rule you fall under.
For an approved off-site place, section 56(3) adds a condition: the person in charge of that place has to agree in writing to give the Registrar access for an inspection under section 15 of the Act during its normal business hours. And section 56(4) requires you to tell the Registrar which places you keep records at, before you keep them there, and which records are kept at which place. That is the regulatory root of OMVIC's guidance on notifying the Registrar when records move off-site, including to a cloud service.
A note from the lot floor
Lot Jacket was built inside two working lots, Afghan Automotive in Toronto and Momo Cars in Niagara Falls, and on a working lot the retention question is rarely whether to keep files. It is which date to count from, and where old boxes are allowed to go once the office fills up. The answer from the regulation, a trade date and a non-dwelling place, is less flexible than the habits most small lots fall into, and it is easier to set up correctly once than to reconstruct when an inspector names a car from four years ago.
Going electronic: what you gain and what you owe
Electronic record-keeping is explicitly permitted. OMVIC's guideline states that, subject to its guidelines, registrants may keep electronic records — either instead of or alongside paper records — and remain in compliance with the law. Most small lots read that sentence, stop there, and move their files to a cloud drive. Two obligations come with the move:
- Tell the Registrar where the records live. Records must be at a location approved by the Registrar, and dealers keeping records off-site — cloud-based or on third-party servers — must notify the Registrar in writing within five days of any change in address for service. Switching to a cloud system without doing this is the quiet, extremely common version of non-compliance.
- Keep a separate backup. OMVIC strongly recommends dealers keep a backup of all electronic records separate from their primary source. “Separate” is doing work in that sentence — a second folder on the same laptop is not a backup.
The part that shows up in an inspection
Section 15 of the MVDA requires dealers to provide the relevant records related to an inspection without obstruction when the Registrar's representative asks for them. During an OMVIC inspection, that is the whole game. An inspector names a VIN and a date. You either put the complete file in front of them or you start explaining.
Paper lots fail this in a specific, predictable way: the file exists, but the 2022 deals are in a storage unit, the finance docs went to the lender and nobody kept a copy, and the one disclosure that matters was signed on a form that got superseded. Nothing was thrown out maliciously. The retention obligation just quietly outlived the filing system.
A retention plan that survives six years
Four things make the six-year rule a non-event rather than a risk:
- One home per deal. Every document for a car — bill of sale, disclosures, UVIP, safety, trade-in paperwork, funding — lands in the same jacket, not split across email, a shared drive, and a drawer. Scattered records are the root cause of most retrieval failures.
- Retrievable by VIN and by date. If finding a 2023 deal takes twenty minutes, you do not really have a six-year archive; you have six years of boxes.
- Backed up somewhere else. Per OMVIC's recommendation, separate from the primary copy.
- Registrar notified. In writing, within five days of a change in address for service — including the move to a cloud system.
How Lot Jacket handles it
Lot Jacket was built around this obligation rather than bolted on after it. Every document for a car lives in one audit-ready deal file — scanned, indexed by VIN and date, retained for the full six years, and retrievable in seconds when an inspector names a car. The electronic garage register is written by the same deals, so the register and the files never disagree.
You still own the Registrar notification — that's your letter to write, not ours — but the rest stops being a filing project. Book a free 15-minute demo and bring a deal from three years ago; we'll find it live.
This guide is general information for Ontario used-car dealers, not legal or compliance advice. OMVIC requirements can change — always confirm the current rules with OMVIC or a qualified advisor.
Sources
- Electronic Record-Keeping Guideline — OMVIC
- O. Reg. 333/08: General, ss. 52 to 57 (records, retention and place of retention) — Government of Ontario
- Motor Vehicle Dealers Act, 2002, S.O. 2002, c. 30, Sched. B — Government of Ontario
- Dealer Guidelines and Resources — OMVIC
Frequently asked questions
How long do Ontario car dealers have to keep records?
At least six years. Section 56(1) of O. Reg. 333/08 requires a dealer to retain the records required by sections 52 (vehicles that come into the dealer's possession), 53 (trades and consignments) and 54 (the business itself) for at least six years. Section 57 applies the same six years to the garage register kept under the Highway Traffic Act and Regulation 595.
Six years from when?
It depends on the record. Vehicle and trade records under sections 52 and 53 run six years from the date of the consignment contract or trade the record relates to (s. 56(1)(a)). Business records under section 54 run six years from the date the record is made (s. 56(1)(b)). The Highway Traffic Act s. 60(1) register runs six years from the date of the contract under which you bought or sold the vehicle (s. 57(2)), and the Regulation 595 s. 4 record six years from when it was made (s. 57(3)). A car bought in March and sold in August has two clocks; keep the whole file until the later one runs out.
Can I keep my dealership records at home?
Not if you are a general dealer. Section 56(2)(b) of O. Reg. 333/08 requires the records to be kept at a place, other than a dwelling, from which you are authorized to trade, or at another place, other than a dwelling, that you choose and the Registrar approves. Only brokers and wholesalers that actually trade from a dwelling, and outside Ontario dealers, lease finance dealers and fleet lessors, fall under the separate rule in s. 56(2)(a), which still needs the Registrar's approval of the place.
Can Ontario dealers keep records electronically instead of on paper?
Yes. OMVIC's Electronic Record-Keeping Guideline confirms that, subject to its guidelines, registrants may keep electronic records — either instead of or alongside paper records — and remain in compliance with the law. The MVDA does not specify the format records must be kept in, nor does it specify the treatment of original documents, backup copies, or the disposal of records.
Do I have to tell OMVIC where my records are stored?
Yes, and this is the step dealers most often miss when they move to a cloud system. Records must be kept at a location approved by the Registrar, and dealers must notify the Registrar in writing within five days of any change in address for service. Moving your deal files from a filing cabinet at the dealership to a third-party or cloud server is a change in where your records live.
Do I need a backup of my electronic dealer records?
OMVIC's guideline strongly recommends that dealers keep a backup of all electronic records separate from their primary source. It is a recommendation rather than a stated rule, but the practical logic is hard to argue with: a six-year retention obligation you cannot meet because a hard drive failed is still an obligation you did not meet.
What happens if OMVIC asks to see my records during an inspection?
You have to produce them. Under section 15 of the Motor Vehicle Dealers Act, dealers must provide the relevant records related to an inspection without obstruction when they are requested by the Registrar's representative. In practice, 'without obstruction' means an inspector should not be waiting while someone digs through boxes — being able to retrieve a specific deal quickly is part of meeting the obligation.
Go deeper
This guide is general information for Ontario used-car dealers, not legal or compliance advice. OMVIC requirements can change — always confirm the current rules with OMVIC or a qualified advisor.