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Keep the ordinary commercial, accounting and tax evidence for each transaction, plus enough information to show who authorized the AI agent and reconstruct what it did. Indian law does not establish a separate, universal AI-agent recordkeeping category. Existing rules on electronic records already address systems programmed to operate automatically, while company, GST, tax, privacy and sector-specific obligations may apply according to the business and transaction.
This is India-wide general guidance current to 7 October 2026. Retention and applicability depend on factors such as legal form, tax status, sector, transaction and any audit, dispute or legal hold. Ask an Indian chartered accountant or lawyer to confirm the requirements for your circumstances.
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What to preserve for each AI-agent transaction
Build a transaction file that connects the agent’s authority and activity to the commercial outcome and the accounting record. The checklist below is a practical auditability design, not a statutory AI-log schema.
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- Authority and scope: Save the instruction, approval, delegation or policy that allowed the agent to act. Record the approving person or role, business identity, permitted actions, spending or other limits, and any human approval, escalation or override.
- Input and operating context: Preserve the transaction trigger or request, material data supplied to the agent, and the relevant workflow, system version, policy or configuration. Keep what is needed to explain what the agent was permitted to do; avoid retaining unrelated prompts or personal or confidential material without a business or legal reason.
- Agent activity and communications: Keep the transaction-relevant actions and messages, including the electronic record sent or received where available. Capture timestamps, recipient or counterparty, destination, and relevant tool or system interactions so the outcome can be reconstructed.
- Commercial evidence: Link the contract or terms, purchase order, invoice, receipt, delivery or service evidence, payment and settlement records, tax documents, and correspondence or acceptance that forms part of the transaction.
- Accounting and subsequent changes: Retain the accounting entry and its supporting documents, reconciliations and corrections. Where the applicable recordkeeping regime requires or supports it, preserve an edit history showing what changed, when, and by whom or which process.
- Integrity and retrieval: Keep records complete, legible and retrievable for the required period, in original form or an accurate representation. Maintain appropriate access controls and backups, and ensure the record can be produced later in the required jurisdiction and format.
- Personal data: Identify when inputs or outputs contain personal data and manage them under the data-protection obligations in force for the processing date. The Digital Personal Data Protection Rules, 2025 have staged commencement; do not assume every provision was in force on 7 October 2026.
What Indian rules say about electronic and automated records
The Information Technology Act, 2000 recognizes electronic records where a law requires information in writing, provided the information is available electronically and remains usable for later reference. Section 7 sets retention conditions: accessibility for subsequent use, preservation in the original format or an accurately representative format, and details identifying origin, destination, and dispatch and receipt dates and times. Section 11 attributes a record to its originator when it is sent by that originator, an authorized person, or an information system programmed by or on its behalf to operate automatically. These provisions make evidence of authority and a traceable record important, but they do not by themselves validate every agent contract or resolve other legal questions. Read the Information Technology Act, 2000.
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Retention and system requirements depend on the business and record
| Rule area | What it establishes | Practical effect |
|---|---|---|
| Electronic records under the IT Act | Later accessibility, faithful preservation and origin, destination and timing details for covered electronic records. | Design transaction records so they remain readable, attributable and reconstructible. |
| Company books kept electronically | For companies using accounting software to maintain books for financial years commencing on or after 1 April 2023, the software must record an audit trail for each transaction, maintain a dated edit log for each change, and ensure the trail cannot be disabled. Electronic books and relevant papers must remain accessible in India, complete and unaltered or accurately represented, and capable of legible display and retrieval. A daily backup must be kept on servers physically located in India. | Apply these requirements to companies and records within their scope; do not assume they automatically govern every Indian business form. See Companies (Accounts) Rules, Rule 3. |
| GST accounts and records | CBIC’s section 36 material gives a baseline retention period of 72 months from the due date for furnishing the annual return for the year to which the covered accounts and records relate. | Calculate the period from the relevant annual-return due date and document the calculation. The 72-month period is a GST rule for covered records, not a universal period for every business document. Check for audits, notices, disputes or other preservation duties before deletion. See CBIC’s GST Act section 36 material. |
| Income-tax transition | The Income Tax Department says the Income-tax Act, 2025 applies to tax years beginning from 1 April 2026; AY 2026–27 and earlier-year proceedings continue under the 1961 Act framework. | Label records by tax year and retain the evidence needed under the law governing the return, assessment or proceeding. See the Income Tax Department’s transition guidance. |
| Personal data and DPDP Rules | The Digital Personal Data Protection Rules, 2025 were published on 13 November 2025 with staged commencement. Rules 1, 2 and 17–21 commenced on publication; rule 4 is scheduled for 13 November 2026; rules 3, 5–16, 22 and 23 are scheduled for 13 May 2027. | As of 7 October 2026, the latter staged provisions were not yet in force under that schedule. Determine which duties apply to the processing date and facts, and retain consent, notice and sharing or processing evidence where applicable. See the Gazette notification. |
GST materials also contemplate electronic recordkeeping and production, backups, and audit-trail or interlinkage information when demanded. See the GST Council’s electronic-record material. Other laws or sector rules may prescribe additional formats or retention conditions.
How to make the records useful in an audit or dispute
- Link records with a transaction identifier. Make the instruction, agent events, counterparty communications, invoice, payment and ledger entry refer to the same order or transaction where practicable.
- Preserve the evidence, not just a summary. A final status such as “purchase completed” may not show who authorized the purchase, what was sent, or what the counterparty accepted. Retain the underlying transaction-relevant electronic records where available.
- Keep changes visible. Preserve corrections and edit history rather than silently overwriting the record. Companies subject to the accounting-software rule need its prescribed transaction trail and dated edit log.
- Test retrieval and readability. A record that technically exists but cannot be opened, read or connected to the transaction is of limited use. Ensure authorized staff can retrieve it throughout the applicable retention period.
- Apply retention by record class. A single deletion date may not suit accounting, GST, tax, personal-data and dispute-related records. Apply the relevant period and suspend routine deletion where an audit, notice, dispute or legal hold requires preservation.
- Limit unnecessary data. Keep transaction-relevant inputs and outputs for the applicable period, but do not treat the absence of a universal AI prompt-retention rule as a reason to keep every prompt indefinitely.
Does Indian law require a separate AI-agent log?
The cited official materials do not establish a universal AI-agent-specific log requirement. They do establish electronic-record principles and separate obligations for particular records and entities. The practical checklist above helps connect authorization, automated activity and business evidence; it should not be mistaken for a field-by-field statutory mandate.
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