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If your business scans invoices, stores records in accounting software, or keeps photocopies instead of paper originals, the Federal Tax Authority has now told you exactly how those copies must be maintained.
FTA Decision No. 4 of 2026, issued on 2 June 2026 and effective from 30 July 2026, sets out the rules and requirements for maintaining the information contained in accounting records and commercial books. In short: electronic copies and photocopies are acceptable, but only if they are complete, identical to the originals, clearly legible, and fully accessible to the FTA on request, including access to the systems where they are stored.
This article explains what the Decision requires, how it fits into the wider UAE record keeping framework, and what you should check in your own business before the rules take effect.
Reading the source helps. You can open the full text of FTA Decision No. 4 of 2026 (PDF).
What is FTA Decision No. 4 of 2026?
FTA Decision No. 4 of 2026 is a decision of the Chairman of the Board of Directors of the Federal Tax Authority. It was issued under the UAE Tax Procedures framework, specifically Federal Decree-Law No. 28 of 2022 on Tax Procedures and Cabinet Decision No. 74 of 2023, its Executive Regulation.
The Executive Regulation already allowed businesses to keep accounting records and commercial books as photocopies or electronic copies rather than paper originals, subject to conditions specified by the FTA. Decision No. 4 of 2026 now spells out those conditions in detail.
Two definitions sit at the centre of the Decision:
- Electronic Copy: a copy of a document or record created, saved, or converted into an electronic format, so that it can be viewed, retrieved, and read through electronic systems or media. This covers scanned PDFs, records generated inside accounting software, and documents stored in the cloud.
- Photocopy: an identical copy of the original document produced through photocopying, scanning, or photographic reproduction, preserving the content and form of the original in a clear and legible manner.
If your records exist in either of these forms, and for most modern businesses they do, this Decision applies to you.
The three core rules
Article 2 of the Decision sets out three rules that every person maintaining accounting records and commercial books must follow:
Complete and identical
Records must match the original documents exactly.
Clear and legible
Readable on screen, for the entire retention period.
Accessible to the FTA
On request, including system access, passwords and keys.
Each of these rules is then expanded into specific, testable requirements in Article 3. This is where the practical detail lives, and where most compliance gaps will show up.
What "complete and identical" means in practice
For electronic copies and photocopies, the Decision is precise:
- The copy must be an identical reproduction of the original document, containing all the data and details of the original.
- It must include all pages, in the same order as the original document.
- Partial scanning of any part of a document is not accepted.
That last point deserves attention. A common shortcut in busy finance teams is to scan only the first page of a multi-page contract, or the summary page of a supplier statement. Under the new rules, a partial scan is not a valid record. If the original is later discarded, the business may be left without an acceptable record at all.
A trading company receives a 6 page supplier agreement with pricing schedules in the annexes. The accounts team scans pages 1 and 6 (the commercial terms and the signature page) and shreds the original. Under Decision No. 4 of 2026, that scan does not satisfy the record keeping requirement, because it is not a complete, identical copy of the original.
Quality and legibility standards
The Decision also sets a quality bar. Records kept as electronic copies or photocopies must be of sufficient quality and resolution to keep the data clear and easily legible. Specifically:
- The details in the copy must be clear and easily legible when displayed on a computer screen.
- For physical photocopies, the ink and paper must be of a quality that prevents fading during the entire record keeping period.
- A non-coloured photocopy of a coloured document is allowed, provided the data and details remain clearly legible.
Thermal paper receipts are a good illustration of why this matters. They fade, often within a year or two, while the retention obligation runs for years longer. A faded receipt is not a legible record. Scanning such documents promptly, at a readable resolution, is the safer approach, and the Decision explicitly supports it as long as the scan is complete and clear.
FTA access, including passwords and encryption keys
The third rule is the one most likely to catch businesses off guard. The FTA must be able to access records kept as electronic copies or photocopies on request. The Decision states:
- Where electronic copies, or the systems in which they are kept, are protected by encryption or passwords, the business must provide the encryption keys or passwords necessary to enable access for the Authority.
- For physical photocopies, access must be available, including to the places where they are stored.
This has real operational implications:
- If your records live inside cloud accounting software, a document management platform, or an ERP system, you need a practical way to give the FTA access to those records when requested.
- Password protected archives, encrypted drives, and access controlled folders are fine for security, but you must be able to hand over the keys.
- If records are stored offsite, for example in a warehouse or with a storage provider, the FTA must be able to reach them.
A sensible internal control is to document, in one place, where every category of record is stored, who holds access, and how access would be granted in an audit. If that answer currently depends on one employee's personal login, that is a risk worth fixing now.
Outsourcing record keeping: allowed, but responsibility stays with you
Article 4 of the Decision confirms that a business may engage a third party, such as an accounting firm, to maintain its records and commercial books. However, the business remains legally responsible for maintaining those records and ensuring their safety.
This matters for the many UAE SMEs that outsource bookkeeping. Handing your records to an external accountant does not transfer the legal obligation. If the provider loses documents, stores illegible scans, or cannot produce records during an FTA audit, the penalties fall on the business, not the provider.
When outsourcing, it is worth confirming in writing:
- Where your records are physically and digitally stored
- How complete scans are verified before originals are handled
- How you would retrieve everything if you changed providers
- How access would be arranged if the FTA requested it
A professional accounting and bookkeeping partner should be able to answer all four questions without hesitation.
How this fits into the wider UAE record keeping framework
Decision No. 4 of 2026 governs how records must be maintained. It sits alongside existing rules that govern what must be kept and for how long. The main retention periods are:
| Requirement | Retention period | Legal basis |
|---|---|---|
| Taxable persons (general tax procedures rule) | 5 years following the relevant tax period | Cabinet Decision No. 74 of 2023, Article 3 |
| Persons other than taxable persons | 5 years from the end of the calendar year the document was created | Cabinet Decision No. 74 of 2023, Article 3 |
| Real estate records (tax procedures) | 7 years from the end of the calendar year the document was created | Cabinet Decision No. 74 of 2023, Article 3 |
| Corporate Tax records and documents | 7 years following the end of the relevant tax period | Federal Decree-Law No. 47 of 2022 (Corporate Tax Law) |
| VAT real estate records | 15 years | UAE VAT legislation |
Additional retention periods can also apply, for example where a tax dispute is ongoing, a tax audit is underway, or a voluntary disclosure has been submitted. Because different laws can apply to the same document, many businesses simply adopt the longest applicable period across the board.
The point to take from the table is this: whichever retention period applies to you, the records must remain complete, identical, and legible for that entire period, in line with Decision No. 4 of 2026. A scan that is unreadable in year six of a seven year Corporate Tax retention period is a compliance failure, even though the scan was made on day one.
What happens if you get it wrong
Failure to keep the required records and information is an administrative violation under the UAE tax penalty framework. The penalty for failing to keep required records has generally been set at AED 10,000 for a first violation, rising to AED 20,000 for a repeated violation within 24 months.
The financial penalty is only part of the exposure. In an FTA audit, missing or inadequate records can lead to:
- Disallowed input VAT recovery, where supporting documents cannot be produced
- Challenges to Corporate Tax deductions and positions that lack documentary support
- A longer, more intrusive audit process
- Estimated assessments where the FTA cannot verify your figures from your records
Good records are not just a compliance formality. They are your evidence in any disagreement with the tax authority.
A practical compliance checklist before 30 July 2026
Use this as a starting point for an internal review:
- Map your records. List where every category of record lives: accounting software, cloud storage, email, physical files, offsite storage, and records held by external accountants.
- Audit your scans. Check a sample of scanned documents for completeness (all pages, correct order) and legibility on screen. Re-scan anything partial or unclear while originals still exist.
- Fix fading risk. Scan thermal receipts and low quality prints promptly. Do not rely on paper that will not survive the retention period.
- Document system access. Record how the FTA would be given access to each system, including who holds administrator rights, passwords, and encryption keys.
- Review outsourcing arrangements. Confirm in writing how your external provider stores, verifies, and returns your records, and remember that legal responsibility stays with you.
- Align retention settings. Check auto-deletion policies in email, cloud drives, and software subscriptions against your retention obligations. A system that deletes documents after 3 years is incompatible with a 5, 7, or 15 year obligation.
This review is also timely for another reason. With the UAE's e-invoicing framework being phased in from 2026, structured digital records are becoming the default. Businesses that tighten their digital record keeping now will find the transition considerably smoother.
Key takeaway
FTA Decision No. 4 of 2026 does not ban digital record keeping. It legitimises it, and then holds it to a clear standard: complete, identical, legible, and accessible, for the full retention period. From 30 July 2026, "we scanned it" is no longer enough on its own. The scan has to be complete, readable, and retrievable, and you must be able to open the door, digital or physical, when the FTA knocks.
Frequently asked questions
Can UAE businesses keep scanned copies instead of original documents?
Yes. The Tax Procedures framework allows records to be kept as electronic copies or photocopies, and FTA Decision No. 4 of 2026 sets the conditions. The copy must be complete, identical to the original including all pages in order, clearly legible on screen, and accessible to the FTA on request. Partial scans are not accepted.
When does FTA Decision No. 4 of 2026 come into effect?
The Decision was issued on 2 June 2026 and applies from 30 July 2026.
Does the FTA really get access to my accounting system and passwords?
If the FTA requests access to records kept electronically, and those records or systems are protected by passwords or encryption, you must provide the passwords or encryption keys needed to enable access. For physical records, access must be available to the storage locations.
How long do I need to keep accounting records in the UAE?
It depends on which law applies. The general tax procedures rule is 5 years, real estate records under tax procedures require 7 years, Corporate Tax records require 7 years after the relevant tax period, and VAT real estate records require 15 years. Longer periods can apply during audits, disputes, or after a voluntary disclosure. When multiple rules apply to the same document, follow the longest period.
Are black and white scans of coloured documents acceptable?
Yes. A non-coloured photocopy of a coloured document may be retained, provided all data and details remain clearly legible.
If my accountant keeps my records, am I still responsible?
Yes. The Decision expressly allows a third party to maintain your records, but the business remains legally responsible for maintaining them and ensuring their safety. Choose your provider carefully and document how records are stored and returned.
What is the penalty for not keeping proper records?
Failing to keep required records is an administrative violation. The penalty has generally been AED 10,000 for a first violation and AED 20,000 for a repeat violation within 24 months. Inadequate records can also lead to disallowed VAT recovery, challenged Corporate Tax positions, and estimated assessments during an audit.
How Stevva can help
If you are not certain your current records would pass an FTA review, it is far better to find out now than during an audit. Stevva's team works with UAE businesses on accounting and bookkeeping, Corporate Tax compliance, and VAT compliance, including reviewing whether your record keeping practices meet the new requirements.
Not sure your records would stand up to an FTA request? Speak to Stevva for a record keeping health check before 30 July 2026.
Disclaimer: This article is based on an unofficial translation of FTA Decision No. 4 of 2026 and related UAE tax legislation, and is provided for general information only. It does not constitute tax or legal advice. Requirements can change, and their application depends on your specific circumstances. Seek professional advice before acting.
Sources: Federal Tax Authority Decision No. 4 of 2026 on the Rules and Requirements for Maintaining the Information Contained in Accounting Records and Commercial Books; Federal Decree-Law No. 28 of 2022 on Tax Procedures; Cabinet Decision No. 74 of 2023 on the Executive Regulation of Federal Decree-Law No. 28 of 2022 on Tax Procedures (tax.gov.ae); Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses.
Published 21 August 2026 · Reviewed against official FTA sources. This article is general information, not regulated tax or legal advice.