I realize that courts are looking at the spirit of the law and don't look kindly on loopholes, but this seems like it would be considered a reasonable option by

I realize that courts are looking at the spirit of the law and don't look kindly on loopholes, but this seems like it would be considered a reasonable option by a reasonable person, assuming you go through the diligence of ensuring the software remains available. Generally the paper retention laws I've worked with have more required that documents be produceable on demand on paper (and associated fined for failure).