FTA Issues Decision on the Rules and Requirements for Maintaining Information in Accounting Records and Commercial Books
FTA Decision No. 4 of 2026, issued on 2 June 2026, sets out the rules and requirements that apply to the maintenance of the information contained in accounting records and commercial books. It takes effect from the date of its publication in the Official Gazette, which was 30 July 2026, so it is already in force.
The obligation to keep accounting records and commercial books, and the periods for which they must be kept, are already set out in Federal Decree-Law No. 28 of 2022 on Tax Procedures and in Cabinet Decision No. 74 of 2023. Decision No. 4 regulates the form in which the information may be held, and in particular the conditions on which a scan or a photocopy will be accepted in place of the original. The Decision is particularly relevant for businesses that have digitised their records or rely on outsourced providers to maintain them.
It is worth noting that the Decision is drafted by reference to a Person, not a Taxable Person. It therefore reaches anyone subject to the record-keeping obligations under the Tax Procedures Law, whether or not that person is registered for any tax.
The three governing rules (Article 2)
Article 2 sets out three rules that apply to the information contained in accounting records and commercial books.
- The records and commercial books must be complete and identical to the original documents.
- They must be clear and easily legible.
- They must be made accessible to the FTA on request, and that access extends to the system in which the records are held, not merely to the documents themselves.
Article 3 then translates each of those three rules into concrete requirements for records kept as an Electronic Copy or a Photocopy, both of which are defined in Article 1.
What “identical” means in practice (Article 3(1))
- An Electronic Copy or a Photocopy must be an identical copy of the original document and must contain all of the pages, in the same order as the original.
- A partial scan of a document would therefore not satisfy this requirement.
Legibility and durability (Article 3(2))
- An Electronic Copy or a Photocopy must be of sufficient quality and resolution that the data in the original document is clear and easily legible when displayed on a computer screen.
- The ink and paper used must be of a quality that ensures the Photocopy does not fade over the period for which the record must be kept. This is a practical problem for businesses that retain thermal till receipts and similar documents, which frequently become illegible well inside the statutory retention period.
- A black and white copy of a coloured document may be retained, provided that the data and details remain clearly legible.
Access, encryption and passwords (Article 3(3))
- Where Electronic Copies, or the systems in which they are held, are protected by encryption or passwords, the Person must provide the FTA with the encryption keys or passwords needed to give it access.
- Where records are held as Photocopies, access must be available to the FTA, including access to the places where those copies are stored.
Engaging a third party (Article 4)
A Person may engage a third party to maintain its records and commercial books. Responsibility, however, does not move with the function. The Person remains legally responsible for maintaining the records and for ensuring their safety, which means that a failure by an outsourced bookkeeper, an archiving company or a software provider remains the Person’s failure as far as the FTA is concerned.
What this means
Businesses should review their existing accounting records and archives, particularly scanned and electronically stored documents, to confirm that they are complete, legible and accessible in line with the Decision.
They should also ensure that their record-keeping and digitisation processes going forward, including arrangements with third-party providers, allow the required records and systems to be made available to the FTA when requested.