我國的檔案法自1999年立法至今已有8年之久。當時的檔案法是在長期欠缺一致的檔案管理制度下， 各機關各自為政的情況下所制定出來的。經過這些年來我國檔案各界的努力下。如今，舉凡各機關的公文歸檔作業，保存年限之規劃，目錄彙送之執行、應用機制之實踐、資訊化作業之普及、乃至典藏環境之改善等事項，均有了相當之成果。然而，檔案法現經過8年的運行後，其間經歷了行政程序法、國家機密保護法、行政資訊公開辦法等法之相繼施行。檔案法實應依據國內現實運作狀況，並參照先進國家檔案管理制度，改善我國檔案管理制度並修訂檔案法。鑑於中共在1987年頒布《中華人民共和國檔案法》及其《實施辦法》，並依據其實施經驗於1996年修訂檔案法。無論是在檔案管理法規、組織…都已具有完善之管理制度。且與我國又有同文同種之便，因此，蒐集相關資料探討其檔案管理制度，並將海峽兩岸檔案法做一對照比較，參照其優點，以提供我國檔案管理制度建置規劃和檔案法修訂之參考。 The current Archives Act of the Republic of China had been implemented for 8 years since 1999. The background for enacting such an Act was due to that a standardized archives management system had been lack for a long time， so that various governmental authorities had to build their own systems without accordance to the others. However， after years of arduous efforts paid by various archive-managing organizations， the issues such as the file-storing procedure for all authorities， the rule for determining the period for archive preservation， the transfer and collection of catalogue information， the application of the management mechanism， the popularization of the Archives management digitalization and the improvement of the environment for archives preservation etc.， have been concerned and reached fruitful achievements. Nevertheless， following the declaration of the current Archives Act in 1999， the Administration Procedure Act， the National Secret Protection Law and the Administration Information Disclosure Regulation were also subsequently declared since then. Therefore， the current Archives Act urgently needs some amendments and the domestic archives management system should be improved in accordance with the domestic operating condition as well as with the advanced archives management systems adopted by some foreign countries. On the cross-strait， the “Archives Act of the Peoples’ Republic of China” and its application regulation were both promulgated by the authority of Mainland China in 1987， yet the China authority later revised the Archives Act in 1996 according to their experience of applications. Based on such legislative background and application experiment， their archives management regulation， organization systems or other related mechanisms have been well constructed. With the convenience of common races and languages of two sides， this paper hence attempts to collect and analyze the references of the archives management systems of PRC and further compare it with our current archives systems. Hopefully， this paper expects to propose a valuable reference for the installation pan of the archives management system as well as the amending direction of the Archives Act of our country by adopting the advantages of the system of the other side of the strait.