Reconstruction is an evidence test
A transaction record should make it possible to understand the transaction, not merely prove that an entry exists. Section 107(1) of the Act requires sufficient records to reconstruct individual transactions relating to the designated service. The useful details depend on the service. Ask whether the record explains the parties, relevant amounts or property, timing and instructions. A payment entry can be one part of that story while leaving connected documents unclear. The practical reconstruction test follows the complete chain rather than a single system field.
- Instruction
Locate the original instruction and identify the parties.
- Action and changes
Link the work performed, changes and payment information.
- Completed result
Explain what occurred and why it differs from the original instruction, if applicable.
- Retrieval check
Ask another person to locate the records and identify any missing links.
Follow a transaction through its records
Suggested reconstruction exercise. Preserve actual history and mark later explanations as retrospective.
Follow the process from top to bottom.
Link the records together
A suggested design assigns a consistent reference to the matter or transaction and uses it across instructions, supporting documents and system entries. Keep clear relationships between an original instruction and a later change. Where several payments or steps belong to one transaction, show the connection rather than expecting a reviewer to guess. Record which entity provided the service. This is especially helpful when accounting, customer and document systems use different identifiers or when staff communicate through more than one approved channel.
Example: a revised instruction
Suppose a customer changes a payment instruction before completion. The file contains the original message and the final payment entry, but the link between them is missing. A useful reconstruction asks where the changed instruction was recorded, how it was handled and which evidence connects it to the completed step. This example does not prescribe payment verification controls. It shows why a final ledger balance cannot always explain the path taken or the reason the final transaction differs from the original instruction.
Run a retrieval exercise
Select a completed transaction and ask someone who did not handle it to assemble the relevant records. Note any missing links, unreadable formats or unexplained changes. Repair the process that caused the gap, rather than only repairing the sample file. Preserve the actual history when adding a later explanation and identify that explanation as retrospective. Check the separate retention rules for records your business creates and documents a customer provides. A reliable reconstruction should depend on preserved evidence, not the continued availability of one employee’s memory.
Record the retrieval result
Keep a short note of the reconstruction exercise, including which records were located and which links failed. Assign any process fix to an owner. This provides a repeatable way to check improvement after a system change, rather than claiming that a migration succeeded because the number of imported files matched.