How long must a Canadian insurance brokerage keep its records?

General information, current as of September 6, 2026, not tax or legal advice for your brokerage. Retention rules change and your regulator may impose more than what is described here. Confirm your position with your CPA, the CRA, and your provincial broker regulator.

The CRA baseline: six years

Keep your books, records, and the supporting documents behind them for six years from the end of the last tax year they relate to. For a corporation that means six years from the fiscal year end, not six calendar years from the transaction date.

This comes from two statutes that both apply to a brokerage:

• Income Tax Act, subsection 230(4). Records and books of account are kept until six years from the end of the last taxation year to which they relate.
• Excise Tax Act, subsection 286(3). GST/HST records are retained until six years after the end of the year to which they relate.

Practically, the “supporting documents” half matters more than the ledger. A general ledger entry with no carrier statement, deposit slip, or invoice behind it is not an adequate record.

What pushes the period past six years

Four situations extend it, and three of them are common in brokerages.

• A late-filed return. If you file an income tax return late, the six years run from the date you filed that return, not from the year end.
• An objection or appeal. Keep the records until the latest of: the objection or appeal being resolved, the deadline for any further appeal passing, and the ordinary six-year period ending.
• Records that affect a sale, liquidation, or wind-up. The CRA says records covering long-term acquisition and disposal of property, the share registry, and other historical information that would affect the sale, liquidation, or wind-up of the business must be kept indefinitely. For a brokerage, that reaches the minute book, share ledger, and the purchase agreements behind any book of business you have bought.
• A written CRA direction. A CRA official can tell you, in person or by registered mail, to keep records longer than six years.

Going the other way, you can destroy records early only if the CRA gives written permission, requested on Form T137, Request for Destruction of Records. The CRA’s own wording is blunt: destroy paper or electronic records without permission and you may be prosecuted.

GST/HST and payroll

Most of a brokerage’s commission income is exempt, but the record obligation does not go away. Keep the GST/HST returns you filed, the working papers behind them, and the purchase invoices and receipts supporting any input tax credits or rebates claimed. The CRA specifies that ITC-supporting invoices carry particular information, so a credit-card statement line alone is not enough.

Payroll records for a brokerage include hours worked, amounts withheld for CPP, EI, and income tax, the signed TD1 (and TP-1015.3-V for Quebec employees), any CRA letter of authority reducing deductions, the information slips issued, and the returns filed. Same six-year clock.

What your provincial broker regulator adds

Your regulator’s rule sits on top of the CRA’s, and it is usually the one that dictates how the trust records are organized.

Ontario (RIBO). Regulation 991 under the Registered Insurance Brokers Act is specific. A member maintaining a trust account must keep a permanent account record of all trust and general receipts and disbursements, a remuneration book or billing copies showing commissions and fees charged, bank statements and cashed cheques and detailed deposit slips for both trust and general accounts, a record showing the monthly totals of trust assets and trust liabilities, and a listing of identified property held in trust. Records must be preserved for at least the six-year period previous to the member’s most recent fiscal year end. Separately, a Form 1 Position Report is filed within 90 days after fiscal year end, and a second one, as at the six-month point, within nine months of that year end. RIBO can inspect the books at any time.

British Columbia. Council Rule 7(9) of the Insurance Council of BC Rules requires a licensee to “keep books, records and other documents necessary for the proper recording of insurance transactions and related financial affairs.” The Council Rules do not state a numeric retention period, so the CRA’s six years is the operating floor unless the Council directs otherwise. Market conduct for insurers sits with BCFSA, but agency licensing and these record obligations sit with the Insurance Council.

Alberta. The Alberta Insurance Council licenses agencies and administers the Councils’ codes of conduct. The General Insurance Council Code of Conduct treats “failing to maintain proper and adequate books and records of insurance transactions and related financial affairs” as a competence failure, and requires an agent to safeguard and account for money entrusted to them. The Code does not set a retention period, so again, six years.

Quebec (AMF). The Regulation respecting the keeping and preservation of books and registers (D-9.2, r. 19) requires a firm to keep accounting books at its Quebec establishment and, where it collects amounts on behalf of others, a register pertaining to the separate account with the client name, contract number, amount, and purpose of each transaction. Accounting for the separate account is kept distinct from the general accounting. Retention is five years from closing (section 13), and separate-account information is retained at least five years after the last entry (section 14). These clocks do not start at the same point as the CRA’s six years from the end of the last tax year. Calculate both deadlines for the record and retain it until both have passed.

If you operate in more than one province, map each applicable retention rule and its trigger date. Do not dispose of a record until every federal and provincial deadline that applies to it has passed.

Retention by record type

Record	Keep at least	Rule driving it
Trust bank statements, cashed cheques, deposit slips, monthly trust reconciliations	Until all applicable federal and provincial deadlines have passed	ITA s. 230(4); in Ontario, Reg. 991 (six years back from most recent fiscal year end); in Quebec, apply the separate five-year trigger dates in D-9.2, r. 19
Operating bank statements and reconciliations	6 years from the end of the last tax year they relate to	ITA s. 230(4)
Carrier statements and the reconciliations against them	6 years	ITA s. 230(4); support for commission revenue
Commission records: producer splits, contingent and profit-sharing calculations	6 years	ITA s. 230(4)
Client files, applications, binders, policy documents	Until both the CRA deadline for accounting-relevant records and any provincial client-record deadline have passed	ITA s. 230(4); in Quebec, D-9.2, r. 19 runs at least five years from the last of its specified client-record events; your E&O carrier may ask for longer
Payroll: hours, TD1s, source deduction remittances, T4s	6 years	ITA s. 230(4); CRA payroll records guidance
GST/HST returns and the invoices supporting ITCs and rebates	6 years after the end of the year they relate to	ETA s. 286(3)
Corporate minute book, share register, long-term property records	Indefinitely while the corporation exists	CRA: records affecting sale, liquidation, or wind-up

Track the federal fiscal-year clock and any provincial event-based clock separately. Archive consistently, and do not destroy a record until every applicable deadline has passed. Cherry-picking individual documents for destruction is how brokerages end up unable to support a commission figure five years later.

Format and where the records live

The CRA accepts records kept on paper, kept on paper and later converted to an accessible and readable electronic format, or kept electronically from the start. Records created electronically have to stay electronic. Imaged copies of paper documents must be accurate reproductions that do not obscure detail.

Location is the part brokerages get wrong. Both the Income Tax Act (s. 230(1)) and the Excise Tax Act (s. 286) require records to be kept at your place of business or residence in Canada unless the Minister authorizes otherwise, and the Excise Tax Act adds that records must be kept in English or French. If your Applied Epic data, document management, or backup sits on a server outside Canada, the CRA may accept copies where it is satisfied they are true copies and they are made available to CRA officials in Canada in an electronic format readable by CRA software. Confirm that with your BMS vendor and your backup provider rather than assuming, and get the CRA’s written permission where it is needed.

Electronic records must remain readable for the full retention period. A backup you cannot restore, or an archive in a format your current system no longer opens, is not a record.

When the brokerage is sold or wound up

• Share sale. The corporation continues, so its records obligation continues with it. The buyer inherits both the records and the outstanding filings. RIBO’s guidance on a change of ownership makes this explicit for Ontario brokerages: the purchasing brokerage and the new principal broker become responsible for mandatory filings not made before the sale, including late position reports.
• Asset sale (book of business). The seller’s corporation keeps its own tax records for the full period even after transferring the book. Agree in writing who holds the client files, and how the seller gets access to them if the CRA or the regulator asks.
• Dissolution. The CRA requires a dissolved corporation to keep records and supporting documents verifying its tax obligations and entitlements for two years after the date of dissolution. Under the Canada Business Corporations Act, a person granted custody of a dissolved corporation’s documents remains liable to produce them for the prescribed period, with a penalty for failing to do so without reasonable cause. Provincial corporate statutes have their own version, so check the one you incorporated under.
• A non-incorporated business ending. Records are kept for six years from the end of the tax year in which the business ended.

Before any of these closes, tell your regulator what happens to the trust account and the trust records. Do not let a wind-up be the moment you discover the reconciliation was never documented.

What this means month to month

Retention is only a problem for brokerages that reconstruct their books after the fact. If trust and carrier reconciliations are completed and filed every month, the six-year archive builds itself, and a CRA query or a regulator inspection is a retrieval exercise rather than a rebuild.

That is the operating discipline behind our monthly brokerage bookkeeping work: reconcile on a fixed calendar, document the reconciliation, and store it where it can still be read in year six. For how retention fits alongside trust rules, reporting, and filings, see our guide to Canadian brokerage financial compliance.