Can You Prove You Captured What You Were Supposed To?
Why reconciliation is becoming fundamental to trusted regulated communications data
Regulated institutions have spent years investing in communications capture, recording and archiving.
Yet there is a deceptively simple question many organizations still find difficult to answer. Today's regulated communications estate is increasingly fragmented. Microsoft Teams, trader voice, mobile, collaboration platforms and specialist recording technologies can sit alongside generations of legacy infrastructure and historical archives.
Having records in an immutable archive is a key step to meet regulatory obligations, however it does not, by itself, establish that the dataset is complete. As regulated communication data is increasingly used for compliance, surveillance, investigations, analytics and AI, confidence in the underlying data becomes critical. This is where reconciliation matters.
Recording is only the beginning
Regulators expect firms to maintain reliable records of regulated communications in a WORM archiving system. The precise obligations to record-keeping and archiving retention periods vary by jurisdiction and activity, but firms need to refer to the core intention of the regulatory obligation, and be able to prove that the communications records, it is required to maintain, are complete, accurate, unaltered and available when needed.
An archive tells you what you have. Reconciliation helps identify what your organization might not have.
From captured to reconciled
Imagine a source system indicates that 100 communications should have been captured.
The archive contains 98 perfectly valid records. Looking only at the archive, everything may appear healthy. But two expected records are absent.
Reconciliation compares what was expected with what was captured, helping identify outcomes such as a complete match, missing media, missing metadata or a mismatch between expected and captured records. With reconciliation, clients can establish whether what was captured corresponds with what was expected to be captured.
That provides a much stronger basis for regulated communication data governance. The communication estate of regulated firms has effectively become a data estate. This challenge becomes harder as communications environments grow more complex.
A financial institution might operate Microsoft Teams alongside Cisco Webex, trader voice, mobile and specialist platforms while retaining years of historical communications across legacy recording systems. Different systems create the communications. Different technologies capture them. Different platforms retain them. And different compliance, surveillance and analytics systems ultimately consume them.
Gartner's research into Digital Communications Governance and Archiving (DCGA) reflects this broader evolution. Its research considers capabilities extending beyond conventional archiving into areas including communications connectors, retention, search, investigations, historical reconstruction, supervision, surveillance and data insights.
The challenge is no longer simply storing recordings. It is establishing trust in communications data across its lifecycle.
Connecting data isn't enough
Centralizing fragmented communications can make data easier to govern, access and use.
But centralization alone doesn't prove completeness. The same principle applies whether an organization is migrating years of historical recordings or capturing current communications from platforms such as Microsoft Teams.
That's why reconciliation is an important part of what Custodia calls Connected Truth.
Connected Truth is about establishing a trusted foundation across fragmented regulated communications environments: connecting current and historical communications, assuring the recording estate, reconciling what was expected against what was captured, preserving required records, and making trusted data accessible to the systems and people authorized to use it.
Reconciliation isn't Connected Truth by itself. It is one of the mechanisms that helps establish whether the data forming that truth can actually be trusted.
Trusted data before AI
Trusted data has become even more important as financial institutions explore AI across compliance, surveillance and analytics. AI can process enormous volumes of voice, messaging and collaboration data. But sophisticated analytics cannot compensate for communication data that is absent from the underlying dataset. AI cannot analyze a communication it never received.
Gartner research into communications governance reflects the growing role of AI alongside the need to govern increasingly complex digital communications environments.
Regulators are also making clear that adopting AI doesn't remove existing responsibilities. FINRA's 2026 guidance states that existing rules continue to apply when firms use GenAI and specifically identifies supervision, communications and recordkeeping among the areas that can be implicated.
AI is not the reason organizations need trustworthy communications data. It simply makes the quality of that foundation increasingly consequential.
How connected is your communications truth? Here are 5 questions Custodia believes compliance and technology leaders need to consider right now as part of their review of compliance programmes,
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Do we know which communications we expect to capture?
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Can we establish whether those communications were actually captured?
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Can we identify missing media, metadata or discrepancies?
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Can we preserve and retrieve those records in a trustworthy form?
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Can our compliance, surveillance, analytics and AI systems rely on the resulting data?
If those questions are difficult to answer, the problem may be bigger than recording or archiving. It may be a communications-data trust problem.
Custodia helps regulated organizations address that problem by bringing together fragmented, current, and historical communications, validating what has been captured, and creating a trusted data foundation for compliance and downstream use.
If you want to understand where the gaps might exist in your communications data, talk to Custodia about your communications estate and how reconciliation can help establish greater confidence in the data you already have.
