Your Scanned Records Now Have a Legal Standard in the UAE
The Federal Tax Authority published Decision No. 4 of 2026 on 20 August. It sets out the rules and requirements for keeping the information contained in accounting records and commercial books where a business holds copies rather than originals. The Decision was issued on 2 June and took effect on 30 July 2026, so it is already law; most UAE businesses are only seeing it now. If your finance team scans invoices and disposes of the paper, or relies on a document management system to hold its tax records, this Decision tells you the standard those copies must meet. It is stricter than common practice.
Why the Decision exists
Article 4 of Cabinet Decision No. 74 of 2023, the Executive Regulation of the Tax Procedures Law, allows a business to meet its record-keeping obligation in one of two ways: create the record and keep the original documents supporting each entry, or create the record and keep the information those documents contain, in photocopy or electronic form. The second route has always carried conditions, and the same article gave the FTA power to set the rules for maintaining that information and to impose reasonable requirements ensuring it will be available as if the original records themselves had been preserved. Decision No. 4 of 2026 is the FTA exercising that power.
Three rules, and what they demand in practice
The Decision sets three rules. Records and commercial books must be complete and identical to the original documents. They must be clear and easily legible. And access must be given to the FTA on request, including access to the system in which they are held.
The requirements behind those rules are specific. An electronic copy or photocopy must contain all the data and details in the original and must include every page, in the same order as the original. Partial scanning of any part of a document is expressly not accepted, the familiar habit of scanning the first page of a multi-page contract, or one side of a two-sided invoice, now fails outright.
On quality, the details and data must be clear and easily legible when displayed on a computer screen. For paper copies, the ink and paper must be of a quality that ensures the copy does not fade during the record-keeping period. A non-coloured copy of a coloured document may be retained, but only where the data and details remain clearly legible.
Encryption and passwords are not a shield
The access rule has the sharpest edge. Where electronic copies, or the systems holding them, are protected by encryption or passwords, the business must provide the FTA with the encryption keys or passwords needed to open them. Where copies are held on paper, access must extend to the places where they are stored. A business that cannot open its own archive during an audit, because the system was retired, a licence lapsed, or the person who held the password has left – is in breach of the Decision, whatever the records themselves would have shown.
You can outsource the storage, not the responsibility
The Decision permits a business to engage a third party to maintain its records and commercial books. It then states plainly that the business remains legally responsible for maintaining them and for ensuring their safety. A cloud platform, an outsourced bookkeeper or an offsite archive changes who does the work. It does not change who answers to the FTA.
The periods, and the price of failure
The standard must hold for the full retention period set by Cabinet Decision No. 74 of 2023: five years following the tax period for a taxable person, five years from the end of the calendar year in which the document was created for anyone else, and seven years for real estate records. Those periods extend by a further four years where there is a dispute with the FTA, an ongoing tax audit, or notice of an intended audit before the original period expires, and by one year where a voluntary disclosure is filed in the fifth year.
Failure to keep the required records and information carries an administrative penalty of AED 10,000 for each violation, rising to AED 20,000 for each repeated violation within 24 months of the last one. The figure is the same under the Tax Procedures Law penalties and the Corporate Tax penalties. A separate AED 5,000 penalty applies where tax records and documents are not submitted to the FTA in Arabic when requested.
What to do this month
Take one month of scanned records and test them against the standard: complete, every page, in the original order, legible on screen without enhancement. List every system that holds tax records and confirm that someone can open each one today. Read your outsourcing and software contracts for a clause obliging the provider to meet the FTA’s requirements and to surrender records and access on demand. Then put a name against the archive, because the Decision leaves the responsibility with you.
Speak to us
Altus Citadel Services FZCO is reviewing clients’ record-keeping against Decision No. 4 of 2026, sampling scanned files against the completeness and legibility tests, checking retention against the extended periods, and closing the access gaps that tend to surface only during an audit. If you are not confident your archive would withstand an FTA request tomorrow, contact us. This Decision is not on the horizon; it took effect on 30 July.
Contact us at: www.altuscitadelservices.com | +971 50 961 6354 or +971 50 161 9605 or info@altuscitadelservices.com
