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Keeping an invoice somewhere in email or cloud storage is not the same as maintaining a compliant accounting record. Federal Tax Authority Decision No. 4 of 2026 clarifies how information contained in accounting records and commercial books must be preserved when businesses rely on electronic copies or photocopies.
The decision was issued on 2 June 2026 and became effective on 30 July 2026. Its message is practical: records must be complete, identical to the originals, clear, readable and accessible to the FTA on request. When records are held inside software, encrypted storage or with an outsourced provider, the business remains responsible for making them available.
Key point: The new decision focuses on how accounting records and commercial books are maintained. It does not replace the separate rules that determine which records must be kept or how long they must be retained under each applicable tax law.
The three core record-keeping rules
Complete and identical
The retained accounting records and commercial books must be complete and identical to the original documents.
Clear and legible
The information must be easy to read. Poor scans, cut-off pages, blurred figures and inaccessible file formats create compliance risk.
Accessible to the FTA
The business must provide the FTA access on request, including access to the system in which the records and books are stored.
Requirements for electronic copies and photocopies
Keep every page in the correct order
An electronic copy or photocopy must contain all data and details included in the original. Every page must be retained in the same order as the original document. Partial scanning of any part of a document is not accepted.
Use sufficient quality and resolution
Electronic records must be clear and legible when displayed on a computer screen. For physical photocopies, the paper and ink should be suitable for the required retention period so the document does not fade. A black-and-white copy of a coloured document may be retained if all information remains clear and readable.
Make protected records accessible
Where electronic copies or accounting systems are protected by passwords or encryption, the person must provide the keys or passwords necessary for the FTA to access the records when requested. For physical copies, access must extend to the places where those copies are stored.
A business may appoint a third party to maintain its accounting records and commercial books. This can include an external accountant, bookkeeping firm, document-storage provider or cloud platform. However, the business remains legally responsible for maintaining the records and ensuring their safety.
This means management should know where the records are stored, who controls access, how backups work and how quickly complete documents can be produced. A service contract does not protect a taxpayer if files are missing, incomplete or unavailable during an FTA request.
The documents required depend on the tax, transaction and business. For corporate tax, the FTA has highlighted core records such as transaction records for the tax period, asset acquisition and disposal details, liabilities and ownership interests held at period end. Businesses may also need sales and purchase invoices, credit notes, contracts, bank evidence, expense support, payroll information, inventory records, tax calculations and reconciliations.
The important control is traceability. A reviewer should be able to move from the financial statements or tax return to the ledger entry and then to the complete supporting document without relying on one employee's memory.
Create a record-retention matrix showing the document type, responsible owner, storage location, applicable retention period and disposal approval process.
Scan the complete document in one file, preserve page order and check that totals, dates, tax registration numbers, signatures and attachments are visible.
Use consistent file names and folders linked to the accounting entry, supplier or customer, transaction date and document number.
Restrict editing and deletion rights, and keep a log of material changes to master data and accounting records.
Back up records in a separate, secure environment and periodically test whether files can be restored and opened.
Maintain access instructions for accounting software, cloud archives, password vaults and encrypted backups, with management oversight.
Include access, backup, confidentiality, handover and document-return clauses in contracts with outsourced accountants or storage providers.
Run sample retrieval tests: select entries from the trial balance and confirm that the complete supporting record can be produced promptly.
Saving only the first page of a multi-page contract or invoice.
Keeping an image that is readable on a phone but becomes blurred when enlarged on a computer screen.
Storing documents in an employee's personal email, device or unapproved cloud account.
Assuming the accountant or software provider is solely responsible for retention and access.
Failing to retain the evidence behind manual journals, year-end adjustments and tax reconciliations.
Using passwords or encryption without a controlled recovery process when the responsible employee leaves.
Deleting records based on a general company policy without checking the longer period required by the relevant tax legislation.
The retention period depends on the applicable tax law and the type of record. For corporate tax, taxable persons and relevant exempt persons generally need to retain supporting records for at least seven years after the end of the relevant tax period. VAT and other tax records may follow different periods, and special rules can apply to areas such as real estate. Businesses should therefore use a tax-specific retention matrix and apply the longest relevant period where the same record supports more than one obligation.
Young and Right can review your bookkeeping and document-retention process, identify missing evidence, organise tax-ready digital files, reconcile records to VAT and corporate tax returns, and prepare an audit-response pack. A clean archive supports more than compliance: it improves month-end closing, management reporting, cash-flow control and due diligence.
Ensure your digital and paper accounting records are properly maintained, accessible, and compliant with the latest FTA requirements.
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