The Federal Tax Authority has issued Decision No. 4 of 2026, setting out more detailed requirements for maintaining accounting records and commercial books in electronic, photocopy and original form, effective from 30 July 2026.

The Federal Tax Authority (FTA) has issued Decision No. 4 of 2026 on the Rules and Requirements for Maintaining the Information Contained in Accounting Records and Commercial Books. The Decision clarifies how taxpayers must retain accounting records and commercial books, whether in original form, as electronic copies or as photocopies, and confirms the standards the FTA will expect to see during a tax audit or information request.

Although the Decision does not fundamentally change the obligation to keep records under the UAE tax framework, it provides useful operational detail on the quality, completeness and accessibility of records maintained by businesses.

What are the key definitions?

The Decision introduces two important concepts. An Electronic Copy is a document or record saved or converted into an electronic format that can be viewed, retrieved and read through electronic systems or media. A Photocopy is a copy produced through photocopying, scanning or photographic reproduction, provided that the form and content of the original document are preserved clearly and legibly.

What are the general record-keeping requirements?

Under the Decision, accounting records and commercial books must comply with three fundamental requirements:

·        They must be complete and identical to the original records.

·        They must be clear and easily legible.

·        They must be accessible to the FTA upon request, including access to the system in which the records are maintained.

Requirements for electronic copies and scanned documents

The Decision is particularly relevant for businesses that rely on scanned documents, cloud accounting systems, electronic document management platforms or outsourced bookkeeping arrangements.

Businesses should ensure that:

·        Electronic copies and photocopies contain all pages of the original document in the same order.

·        Partial scans of documents are not acceptable.

·        Copies are maintained at a quality and resolution that allows information to be clearly read.

·        Photocopies remain legible throughout the applicable retention period.

·        Black and white copies of colour documents may be retained provided that all information remains clear and readable.

Access to records during an FTA review

A key feature of the Decision is its emphasis on accessibility. The FTA must be able to access records upon request, including records maintained electronically and the systems in which those records are stored. Where records are password-protected or encrypted, businesses must be able to provide the necessary credentials, keys or access details to enable the FTA to review the records.

Businesses should therefore consider not only whether records have been retained, but whether they can be retrieved, opened and presented efficiently during an audit or information request.

Can businesses use third-party providers?

The Decision confirms that businesses may engage third-party providers to maintain accounting records and commercial books. However, compliance responsibility remains with the taxpayer. The use of cloud storage providers, document management platforms or outsourced record-keeping services does not transfer responsibility for ensuring that records remain complete, accurate, legible and accessible.

What should businesses do now?

Businesses should use the Decision as an opportunity to review their record-retention processes, document management controls and audit-readiness. In particular, they should consider:

·        Reviewing document retention and archiving policies.

·        Testing the accessibility of electronic records.

·        Verifying that scanned records are complete and legible.

·        Confirming that records can be readily provided to the FTA when requested.

·        Assessing whether third-party service providers meet the required standards.

Reminder: Corporate tax records, including ledgers, invoices and financial statements, must generally be retained for seven years after the end of the relevant tax period, in line with Article 56 of the Corporate Tax Law. By contrast, VAT records are generally subject to a five-year retention period, although longer periods may apply in specific cases, including certain real estate records.

Altair Tax Insight

Decision No. 4 of 2026 is a practical reminder that tax record-keeping is not limited to retaining documents somewhere in the business. Records must be complete, readable and capable of being produced in a form that allows the FTA to review them effectively.

With corporate tax and VAT imposing different retention periods, and with the Decision formalising access and quality requirements for electronic and photocopied records, businesses should reassess their document-management processes now. The objective should be simple: audit-ready records that can be retrieved, opened and provided to the FTA whenever required.