The police register: what a French art gallery must actually keep

Two officials arrive at the gallery on a Thursday morning, perfectly polite, and ask to see the register. It is in the desk drawer, under the catalogues from the last fair. The last entry is three weeks old; since then, you have taken back two canvases from a collector and received a sculpture on consignment from an estate. Everything is in the stock file, nothing is in the register.

The livre de police, the police register of a French art gallery, is one of those obligations you learn from a colleague rather than from the text. Yet the text is short and precise. Here is who must keep it, what goes in it, on what medium, and what an omission costs.

Who must keep a police register in an art gallery?

Its official name is the register of movable goods (registre d’objets mobiliers). The obligation is set by Article 321-7 of the French Criminal Code, and the rules for keeping it by Articles R. 321-1 to R. 321-8.

Article 321-7 does not name galleries. It covers anyone “whose professional activity includes the sale of used movable goods, or goods acquired from persons other than those who make them or trade in them”. What decides is the way you work, not the word on the shop window.

A gallery that resells works bought from collectors, taken back from an estate or received on consignment from a private individual falls within this definition: those people did not make the work and do not trade in it.

The primary market is less clear-cut: a work received directly from the artist comes from the person who made it, and the text does not say in so many words how to treat it. But a single resale for a client, or one piece taken back from a collector, is enough for your activity to “include” what the article covers. If in doubt, ask the prefecture that receives your declaration.

If the gallery is a company, the obligation falls on its managers (Article 321-7, last paragraph, and Article R. 321-7).

Before the register: the declaration to the prefecture

Article R. 321-1 requires a prior declaration to the prefecture or sub-prefecture responsible for your main place of business, and to the Préfecture de police in Paris. It states, among other things, your identity, your nationality, the legal form of the business and its identification number.

You receive a receipt, to be shown whenever the police, the gendarmerie, the tax authorities, customs or the consumer fraud authorities ask for it. If the gallery moves, Article R. 321-2 requires a new declaration to the police station, or failing that the town hall, of both the place you leave and the place you move to.

What you record, line by line

The entries are set by Articles R. 321-3 to R. 321-5. For each person who sold you a work, brought it in exchange or left it with you on consignment for sale:

• their surname, first names, capacity and address;

• the type, number and date of issue of their identity document, with the authority that issued it;

• for a company, its name and registered office, and the identity of the person who acted for it.

For each work:

• its nature, provenance and description, with the “names, signatures, monograms, letters, figures, serial numbers, emblems and signs of any kind” that identify it: signature, date, inscriptions on the back, labels from past exhibitions, edition number;

• the purchase price and the means of payment; for a work received on consignment, exchanged or acquired free of charge, an estimate of its market value;

• the protection measure under the French Heritage Code, if you have been told the work is subject to one;

• a serial number (Article R. 321-4), which must also appear “visibly” on the work itself.

Grouping items into lots, allowed for low-value objects, excludes anything of artistic or historical interest: each work has its own line. And Article 321-7 requires a register kept “day by day”: a register caught up at the end of the month from the stock file does not meet that requirement.

Police register: paper or digital?

On paper, Article R. 321-6 is strict. Entries are written in indelible ink, “without blanks, crossings-out or abbreviations”. The register is numbered and initialled by the police commissioner or, failing that, by the mayor. Each establishment open to the public has its own, and it is kept for five years from the date it is closed.

Since 2013, Article R. 321-6-1 has allowed the register to be kept by automated processing, which removes the need for the numbered and initialled register. The digital register carries the same entries, and the processing must guarantee “the integrity, immutability and security of the recorded data”. The data is kept for ten years from the date it is recorded.

Article R. 321-8 leaves the technical detail to a ministerial order, which the official Service public Entreprendre guidance summarises as follows:

• processing that complies with the ISO 14641-1 standard;

• a record of every consultation, with the person’s identifier, the date, the time and the purpose of the consultation;

• those records kept for one year.

A spreadsheet that can be edited, sorted or emptied without leaving a trace does not guarantee that immutability. It is a useful working copy, but it does not replace the register.

What a missing or inaccurate police register costs

Article 321-7 punishes failure to keep the register, “including through negligence”, with six months’ imprisonment and a 30,000 euro fine. An oversight is enough, without any intent. Article 321-8 sets the same penalties for inaccurate entries and for refusing to show the register to the competent authority.

For a company found criminally liable, the fine is multiplied by five, to 150,000 euros (Articles 321-12 and 131-38), and some of the additional penalties in Article 131-39 may be added.

What MARMALADE actually does

• The police register starts from the artwork record: title, artist, medium, dimensions and provenance are carried over, and you complete the seller or consignor, their identity document, the price and the means of payment. A sales invoice records the sale in the register by itself, with the buyer, the price and a link to the invoice.

• Each line is first a draft, then an entry that can no longer be changed: you correct it with a new line, giving the reason, and the original stays visible. Lines are chained, every consultation leaves a trace in an access log kept for one year, and the register exports to CSV.

• For a gallery that arrives with its history, MARMALADE prepares drafts for sales already invoiced and for works that came in without a line. Nothing is recorded without you.

• The tool does not file the declaration with the prefecture or check identity documents: those steps remain the gallery’s own.

To compare on facts: our comparison of gallery management software and, if you use Artlogic, the page MARMALADE or Artlogic. The trial lasts 30 days, with no credit card.

Published on 16 October 2026, updated on 20 October 2026. It describes French law at the date of publication and is not legal advice.