Renaming a file should not move its data, right? So rename the file into .file.$(date -Iseconds).trash (but make sure that no legitimate files are ever named in this pattern). Then put that file path into a global /var/trashlist. To cleanup, you just check that file for expired trash and make the final deletion.

Beware race conditions when writing to /var/trashlist (assuming you mean "a file with one path per line.")

Proposed tweaks: symbolic link into /var/trashlist directory, where the name of the symbolic link is "<timestamp>-<random stub>-<original basename>". Timestamp first so we can stop once we hit the first too-recent timestamp, random stub to unique the original base name if two different files In different directories are deleted at the same timestamp, original file name for inspection.

It will when moving across disks.