No bulletin specifically requires a log of what an AI tool drafted for you. The reasons to keep one anyway are already written into the accountability and record-keeping duties you carry regardless of what wrote the first version.
Key takeaways
Search for a rule that specifically says “keep a record of AI-generated drafts” and you will not find one — not in RECO's bulletins, not in the REALTOR® Code, not in BCFSA's guideline. That absence is not the end of the analysis. Several existing duties already assume you can account for what happened in a client's file, and an AI-assisted draft does not get a pass from them just because the rule that would name it explicitly has not been written yet.
(BCFSA AI Guideline) ties accountability directly to accuracy: licensees who use AI-generated content remain accountable for the accuracy of any advertising they publish or representations they make, and AI systems may produce inaccurate results if their underlying data is outdated or incomplete. If a claim is ever challenged — a client disputes what they were told, a regulator asks a question about a piece of advertising — being able to show what the AI drafted, what you changed, and why is the difference between a five-minute explanation and a much longer one built on memory.
(REALTOR® Code, Art. 3.1) adds a specific, verbatim example: full disclosure to the client at the earliest opportunity of any information relating to the transaction, and (REALTOR® Code, Art. 3.9) ties dealing fairly to fulfilling fiduciary duties and following a client's lawful instructions. Neither article distinguishes between information you typed yourself and information an AI tool first drafted — the disclosure and fairness duties attach to what reached the client, not to which tool produced the first version of it.
FINTRAC's own record-keeping regime governs a different category of record entirely — transaction and identification records, not AI drafts — but the standard it sets for how records should be kept is a reasonable one to borrow. (FINTRAC, record keeping guidance) confirms that a record may be kept in machine-readable or electronic form, provided a paper copy can easily be produced, and that records generally need to be retrievable and provided within thirty days of a request. Building an AI-draft record around the same two properties — electronic is fine, and it should be findable quickly when you need it — is a sensible design choice even though FINTRAC's specific retention periods do not themselves apply to this category.
It does not need to be a legal file. A short note attached to the client file — what was asked of the tool, what it produced, what you changed before it was used or sent, and the date — is enough to reconstruct the decision later without becoming a second job. The version you actually sent or published matters most; the intermediate draft matters mainly as evidence of what you caught and fixed, which is itself useful if your review process is ever questioned.
An AI tool drafts a market update for a past client, and you catch and correct a stale statistic before sending it. A minimal but useful record is three lines: the date, a one-line description of what was corrected and why, and the fact that the corrected version, not the draft, was what was actually sent. If that client later asks where a figure came from, or a colleague questions a claim in the update, the record answers the question in seconds instead of requiring you to reconstruct a decision from memory.
The habit costs less time than it sounds like it would, and it pairs naturally with the checking routine described elsewhere in this library — the record is essentially a one-line summary of what that check found.
It is worth being precise about what (FINTRAC, record keeping guidance) actually covers, because it is tempting to assume it already handles this. The five record categories it sets out — reports submitted, large cash transactions, large virtual currency transactions, receipt of funds, and information records — exist to support anti-money-laundering and terrorist-financing compliance, and each has its own five-year retention period tied to a specific trigger event. None of them are defined around how a piece of client-facing content was produced. An information record captures who a client is; it says nothing about whether a market update sent to that client was AI-drafted or hand-written, and reading FINTRAC's categories as covering AI-draft documentation would be borrowing a real rule for a purpose it was not built for.
The honest position is therefore two separate obligations sitting side by side: FINTRAC's record keeping duties, which are mandatory, specific, and unrelated to AI as a drafting method; and the informal but sensible practice of noting what an AI tool drafted and what you changed, which no rule mandates by name but which the accountability standards above make worth doing anyway.
Not every AI-assisted sentence needs a record. A quick reorganisation of your own notes into a text message carries little of the risk that a public-facing market update or an advertising piece does. The proportionate approach is to reserve the habit for anything that will be published, sent to a client in a way that could later be relied on, or that involved a figure or claim you had to verify — not for every internal draft that never left your own screen.
Related: checking AI output against Canadian rules, data you should never paste anywhere and the guide on reviewing AI output before it ships.
No rule specifies one for this particular category. FINTRAC's five-year retention periods apply to its own defined transaction and identification records, not to AI-drafting notes — but matching your brokerage's general file-retention practice for the underlying transaction is a reasonable default.
BCFSA's guideline frames ongoing supervision of AI-generated content as a managing broker consideration, so a brokerage-level policy is worth having, but nothing stops an individual agent from keeping their own record in the meantime.
No — it does not create or reduce liability on its own. What it does is make the accountability BCFSA and CREA already place on you easier to demonstrate, which matters most exactly when something is being questioned.
Not routinely — it is an internal working note, not a disclosure document. The relevant disclosure duty under the REALTOR® Code is about the transaction information itself reaching the client, not about showing them your drafting process, though nothing prevents sharing it if a client specifically asks how something was produced.
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