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Audit Log Retention Requirements by Framework, With the Clause Behind Each Number

Most frameworks do not say how long to keep audit logs. The ones that do range from 90 days to seven years, and several figures quoted everywhere are wrong or out of date. Here is each requirement with the clause behind it, checked against the source text on 12 November 2026.

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Adeola OkunolaFounder, Invoance12 November 2026·9 min read
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On this page
  1. The short answer
  2. Frameworks that state a number
  3. Frameworks that leave it to you
  4. Three numbers that get misquoted
  5. How to choose your period
  6. Retention is not much use without integrity
  7. What to write in your policy
  8. How Invoance Audit Logs handles retention

The short answer

Most frameworks do not give a number. SOC 2, ISO 27001, GDPR, NIST SP 800-53 and HIPAA's audit controls all leave the retention period for logs to you. The frameworks that do set one range from 90 days to seven years, and they apply to specific industries or kinds of data.

If you need a starting point and none of the specific rules below applies to you, twelve months of audit logs, with the most recent three months quick to search, is the figure PCI DSS uses and the one enterprise customers most often expect. Treat that as a common default, not as a rule.

Every row below was checked against the regulation or standard itself on 12 November 2026, except where the note says otherwise. This is a summary, not legal advice, so confirm the rules that apply to you with your auditor or counsel.

Frameworks that state a number

These set a period in their own text. Check the scope before you adopt a number: most apply only to certain organizations, systems or records.

FrameworkClauseWhat it saysPeriod
PCI DSS v4Requirement 10.5.1Keep audit log history, with the most recent three months immediately available for analysis12 months
NYDFS Cybersecurity Regulation23 NYCRR 500.6(b)Records to reconstruct financial transactions for five years; audit trails for detecting cybersecurity events for three5 years and 3 years
EU AI ActArticles 19(1) and 26(6)Providers and deployers of high-risk AI systems keep the automatically generated logsAt least 6 months
US federal agenciesOMB M-26-14, Appendix BLogs searchable for at least six months and retrievable for a year after creation6 months searchable, 12 months retrievable
CJIS Security Policy v6.1AU-11Keep audit records for at least one year, or until no longer needed for administrative, legal or audit purposes1 year minimum
IRS Publication 1075AU-11Audit records for systems handling federal tax information7 years
NERC CIP-007-6R4, Part 4.3Event logs for high impact systems, and medium impact ones at control centers, where technically feasible90 days
CIS Controls v8.1Safeguard 8.10Retain audit logs across enterprise assets90 days minimum
Australian ISMISM-1988Event logs kept searchable12 months minimum
FDA 21 CFR Part 11Section 11.10(e)Audit trail kept at least as long as the electronic record it describesSame as the record
The EU AI Act duties for high-risk systems apply from 2 December 2027 (Annex III uses) and 2 August 2028 (Annex I products), after Regulation (EU) 2026/1744 moved the dates.
  • EU AI Act, Regulation (EU) 2024/1689 Articles 12, 19 and 26 cover logging and how long logs are kept.
  • OMB Memorandum M-26-14 The May 2026 memo that replaced M-21-31.
  • 21 CFR 11.10 The FDA rule on audit trails for electronic records.

Frameworks that leave it to you

These require logging, or evidence that relies on it, and set no retention period for logs. Your own policy becomes the requirement, and an auditor will check you against it.

FrameworkClauseWhat it says about retention
SOC 2Trust Services Criteria, CC7.2 and relatedNo period. The auditor needs evidence for the whole audit period, so in practice you need at least that long
ISO/IEC 27001:2022Annex A 8.15No period. The organization decides and documents it
HIPAA Security Rule45 CFR 164.312(b)No period for audit logs. The six-year rule in 164.316(b)(2)(i) covers required documentation
GDPRArticle 5(1)(e)No period. Personal data is kept no longer than necessary, which limits how long you keep logs that contain it
NIST SP 800-53 Rev. 5AU-11A period the organization defines, consistent with its records retention policy
FedRAMPAU-11Organization-defined under the 2026 rules. FedRAMP has removed most of its own assigned values
NIST SP 800-171 (CMMC Level 2)3.3.1Keep records to the extent needed for monitoring and investigation. No number
DORADelegated Regulation (EU) 2024/1774, Article 12The financial entity sets the retention period for its logs
NIS2Implementing Regulation (EU) 2024/2690, Annex 3.2.5Logs kept for a predefined period. No number
SOX18 U.S.C. 1520 and SEC Rule 2-06Nothing on system logs. The periods cover the auditor's own workpapers
The SOC 2 and ISO 27001 rows rest on published summaries: the AICPA criteria need an account and the ISO standard is sold. The PCI DSS row above was read in PCI SSC's own v4.0 documents, not the v4.0.1 standard.

Three numbers that get misquoted

HIPAA and six years. You will often read that HIPAA requires audit logs to be kept for six years. The audit controls standard, 164.312(b), sets no period at all. The six years comes from 164.316(b)(2)(i), which covers documentation the rule requires: policies, procedures and records of required actions and assessments. Many organizations choose six years for logs to be safe, and that is a reasonable choice, but it is a choice. A rule proposed in January 2025 would add a retention duty for activity records, still without a number, and it has not been finalized.

SOX and seven years. The seven years is real, and it belongs to auditors. Section 802 of the Act sets five years in statute for audit workpapers, and SEC Rule 2-06 extends that to seven years after the audit concludes. Neither says anything about a company's system logs. If your logs support financial controls, your auditor may still want them for the period under audit.

Federal agencies and thirty months. Guides still cite OMB memorandum M-21-31: twelve months of active storage plus eighteen months of cold storage. That memo was rescinded on 22 May 2026. Its replacement, M-26-14, asks for logs searchable for at least six months and retrievable for a year. FedRAMP's baseline used to point to the old memo, and its 2026 rules now leave the period to the organization.

  • 45 CFR 164.316 The HIPAA documentation rule that carries the six years.
  • 17 CFR 210.2-06 The SEC rule on retaining audit and review records.

How to choose your period

Start with the rules that bind you. List the frameworks and contracts that apply, and take the longest period any of them sets for the logs in question. A payment company that also sells to New York financial firms has two different numbers to meet.

Read your customer contracts. For most software companies the binding number is not in a regulation. It is in a customer's security addendum, or in the answer you gave on their questionnaire. Larger customers commonly ask for at least a year.

Cover your own audit. If you are in a SOC 2 Type II audit, you need the logs behind your controls for the whole audit period, plus the time it takes to finish the report.

Then push the other way. Under GDPR and similar laws, keeping personal data longer than you need is itself a problem. Keep personal data in log entries to what the entry needs, and do not default to "forever". A written period you can justify is safer than an open-ended one.

Decide what "kept" means. PCI DSS and the federal memo both separate logs you can search now from logs you can retrieve later. Cheap archive storage is fine for the older part, as long as you have tested getting something back out of it.

Plan for holds. A dispute or investigation can require you to keep specific records past their normal period. Your deletion process needs a way to pause.

Retention is not much use without integrity

A retention period answers how long you keep a log. It says nothing about whether the log you produce in year three is the one that was written in year one. Several of these frameworks ask for both. PCI DSS requires that log files be protected from modification, and ISO 27001's logging control covers protection as well as storage.

So write the two together. When you set a retention period, also decide how you would show that a record has not changed during it, and how a deletion at the end of the period is recorded. A log that simply has fewer rows than it used to raises questions that a logged, scheduled deletion does not.

  • Tamper-evident vs tamper-proof vs immutable What each word promises, and which one you can claim.
  • What is audit logging? The plain guide to audit logs and audit trails.

What to write in your policy

An auditor or a customer wants to see four things: the period, what it covers, the reason, and what happens at the end. A short statement is enough.

"Audit logs of user and administrator activity are retained for 12 months. The most recent 90 days are searchable in the product; older entries are available by export. This period meets our PCI DSS obligations and our customer commitments. Entries are removed by a scheduled process after 12 months unless a legal hold applies, and each removal run is recorded."

How Invoance Audit Logs handles retention

In Invoance Audit Logs, retention is set for each customer organization, so one customer can be on twelve months and another on seven years. The longest period available depends on your plan: 30 days on the free Developer plan, one year on Builder, and seven years on Growth and Compliance. Recent events stay in a faster query window, from 30 days up to a year depending on plan.

Every event is signed and numbered when it is written, so an event read back in year three can be checked against the signature made in year one. Events past the retention period are sealed from the read endpoints. Customers who need their own copy for longer can take CSV or NDJSON exports, or stream events to their own systems as they happen.

Invoance does not decide your period for you, and it is not a records-management system for the rest of your logs. It covers the audit events your application sends.

  • Audit Logs Signed activity logs for each of your customers.
  • Pricing Retention and query windows for each plan.
  • How to export audit logs for enterprise customers Giving customers their own copy.

Start free: 10,000 signed audit events a month. The Developer plan needs no card and includes 2 customer organizations, 1 stream and 30 days retention: enough to try it on your own product.

Start freeRead the quick start
On this page
  1. The short answer
  2. Frameworks that state a number
  3. Frameworks that leave it to you
  4. Three numbers that get misquoted
  5. How to choose your period
  6. Retention is not much use without integrity
  7. What to write in your policy
  8. How Invoance Audit Logs handles retention
Adeola Okunola

Adeola Okunola

Founder, Invoance
About the author

I'm Adeola, founder of Invoance.

I build proof infrastructure for audit logs, AI attestations, and business records that need to stand up to security, compliance, and legal scrutiny.

Most systems document what happened. Invoance helps prove it.

All articles by Adeola
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