Whether there are loopholes in archival crime is not an self-evident proposition. Through the doctrinal interpretation of relevant provisions on archival crime and the examination of the connection in administrative law and criminal law, the preliminary exploration of loopholes in archival crime can be completed. There are currently regulatory gaps in archival crime in China in terms of the protection of legal interests and types of behavior. The former is reflected in improper arrangement of the accusation system and insufficient protection of the archival carrier itself. The latter is reflected in the failure of the Criminal Law to effectively regulate the behavior of simply using archives as a means, unauthorized buying, and misappropriation of National Archives buildings. The preliminary analysis of loopholes in archival crime can provide prerequisite and foundation for subsequent discussions on the identification and filling of loopholes in archival crime at the legislative level. On the other hand, it clarifies the current regulatory scope of archival crime, which can also guide judicial practice and provide criminal protection for the development of archival work.