Many UAE businesses have moved away from physical accounting files. Invoices are stored in the cloud. Contracts are scanned. Accounting records sit inside ERP systems. Supporting documents are maintained electronically. In many cases, the external accountant or bookkeeping provider maintains most of these records. Going paperless makes perfect business sense.
But an important question remains:
If the FTA asks for your accounting records, can you actually provide them completely, clearly and without delay?
The Federal Tax Authority has issued Decision No. 4 of 2026, dealing with the rules and requirements for maintaining information contained in accounting records and commercial books. The Decision was issued on 2 June 2026 and the published document states an effective date of 30 July 2026. The Decision is short, but there are some important practical lessons for businesses.
Electronic Records Are Fine — But They Must Be Complete
The Decision recognises records maintained as electronic copies or photocopies. However, simply scanning a document does not automatically mean the record has been properly maintained. The electronic or photocopied document must be identical to the original and contain all pages in the same order.
Importantly:
Partial scanning of a document is not accepted.
For example, imagine your company signs a 20-page agreement. The accounts team scans only:
- the first page;
- the commercial terms page and
- the signature page.
The original agreement may contain important information on the remaining pages. Under the Decision, if the document is being retained electronically as the record, the complete document should be maintained, not merely selected pages. This sounds simple, but it is worth reviewing how documents are actually being uploaded into your accounting system or document-management system.
Your Records Must Be Readable
The second requirement is equally practical. Electronic records must be of sufficient quality and resolution so that the information remains clear and easily legible when viewed on a computer screen. Physical photocopies must similarly remain readable during the applicable record-keeping period. Interestingly, a colour document does not necessarily have to be photocopied in colour. A non-colour copy may be maintained provided the information and details remain clearly readable.
The principle is straightforward:
Keeping a document is not enough if nobody can properly read it later.
Businesses should therefore be careful with poor-quality scans, cropped documents, missing pages and files that become inaccessible after software or system changes.
“Everything Is in the Cloud” Is Not the End of the Conversation
This is probably the most important operational point. The Decision requires accounting records and commercial books to be made available to the FTA upon request. This includes access to the system in which those records are stored.
So if your company maintains its accounting records electronically, you should know:
- where the records are stored
- who has access
- how historical records can be retrieved
- whether they can be produced when required.
Moving records to the cloud does not remove the obligation to make them accessible.
What If the System Is Password Protected?
Most accounting and document-management systems should, of course, be properly secured. The Decision specifically addresses this situation. Where electronic copies or the systems in which they are maintained are protected by encryption or passwords, the person must provide the necessary encryption keys or passwords to enable access by the FTA when required. The practical takeaway is not that businesses should weaken their cybersecurity.
Quite the opposite⏬
Maintain appropriate security, but also ensure that authorised personnel know how records can be retrieved and made available if the FTA requests access. A sophisticated accounting system is of little help during an inspection if nobody knows how to retrieve the historical records.
Your Accountant Keeps Everything. Are You Covered?
This is another important point for business owners. Many companies outsource their:
- bookkeeping;
- accounting
- document management
- financial record maintenance.
That is perfectly possible. However, outsourcing the work does not outsource the legal responsibility. The Decision specifically allows a person to engage a third party to maintain accounting records and commercial books, but the person itself remains legally responsible for maintaining those records and ensuring their safety.
So saying:
“Our accountant has all the documents.”
should not be the company’s entire record-management strategy. The business should understand where its records are maintained and ensure that it can access them when required.
What Should UAE Businesses Do Practically?
There is no need to overcomplicate this. A simple internal review can identify most issues.
- Check Completeness
Make sure electronically stored documents contain all pages, not selected pages or extracts.
- Check Readability
Open a sample of older invoices, agreements and supporting documents and confirm that they remain clear and readable.
- Check Accessibility
Confirm that accounting records and supporting documents can be retrieved quickly from the accounting, ERP or document-management system.
- Review System Access
Know who controls passwords, encryption keys and administrator access. Avoid a situation where critical historical records become inaccessible because an employee has left or an external service provider controls the only access.
- Review outsourced arrangements
If an accountant, bookkeeper or other third party maintains your records, make sure the company itself retains appropriate access and oversight.
Does This Decision Introduce a New Record-Retention Period?
An important distinction should be made. FTA Decision No. 4 of 2026 focuses on how information contained in accounting records and commercial books must be maintained. The three-page Decision itself does not establish a new general number of years for retaining those records. Businesses should therefore continue to consider the applicable record-retention periods under the relevant UAE tax legislation separately.
The Bigger Message for Businesses
Digital record keeping is clearly the direction in which modern accounting is moving. But digital does not mean informal. Whether your records are stored:
- physically
- on a company server
- in an ERP
- in the cloud
- with an external accounting provider
the fundamental expectations remain straightforward:
Complete. Readable. Accessible.
And there is one more point business owners should remember:
You can outsource the maintenance of your accounting records. You cannot outsource your legal responsibility for them.
That is probably the most important practical takeaway from FTA Decision No. 4 of 2026.
How RVG Can Assist
RVG Chartered Accountants can assist businesses in reviewing their accounting and tax record-maintenance processes, including electronic document retention, accounting-system controls and tax-compliance procedures. For assistance, please contact our UAE Tax & Accounting team.
Disclaimer: This article is intended for general information only and does not constitute tax or legal advice. Businesses should consider their specific facts and the applicable UAE legislation.
