I must admit I never thought this was much of an issue.
If you read Art 30 alone it's pretty much current registration linked to retention.
If you read Art 30 alongside the need to demonstrate compliance that brings in other matters such as legal basis. Both could easily be satisfied by a good, well managed IAR.
How far you take it, as now, is a matter for the DC. Many DCs will be able to get away with a very cavalier approach - unless and until something happens to cause ICO to investigate. Then they will have big problems - not much different to where we are now.
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