Topic

Order Audit Trails

What has to be recorded per order, for how long, and what an exchange inspection actually asks a broker to reconstruct.

Definition

What is order audit trails?: An order audit trail is the per-order record a stockbroker must be able to produce for at least five years, identifying the actual user and user ID behind each order and carrying the exchange-assigned identifier on every algorithmic order, so that any order can be reconstructed during an inspection.

3 pieces published on this topic · Updated 2026-09-01

Understanding order audit trails

The obligation is easy to state and surprisingly easy to fail. Five years, per order, identifying the actual end user rather than a shared integration account, with the exchange-assigned identifier attached to anything algorithmic. Most systems that fail it do not fail on retention. They fail because the record was assembled from broker responses, and the orders whose responses were lost are exactly the ones that get asked about.

The second common failure is presentational and expensive. A vendor answers the question with the words comprehensive logging or full auditability, and the evaluation stalls for weeks while somebody works out what those phrases mean. A field list is falsifiable and an adjective is not, which is the entire difference between a twenty-minute read and a six-week delay.

Under the framework the obligation sits with the broker, not the vendor. That is what entitles a broker to ask for the artefact itself, the field list, the retention period, the export format and a worked reconstruction of a real order from far enough back to prove the archive works, rather than a description of it.

Common questions

How long must an audit trail be retained?: At least five years, per NSE circular NSE/INVG/67858 of 5 May 2025, and it must be available rather than merely stored, a record that cannot be produced in usable form within an inspection's timeframe has not met the obligation.
Why is identifying the actual user so important?: Because the circular requires the actual user and user ID behind each order, which rules out attributing a batch of orders to a shared service or integration account. It is the single requirement that most often forces a change to an existing integration.
When should the audit record be written?: Before acknowledgement rather than after. A submission can be accepted by the broker while the response is lost in transit, and a trail written on response has no record of that order at all, a gap no amount of retention repairs.