Businesses that operate in the UAE have always been required to keep accounting records and commercial books. But now, FTA Decision No. 4 of 2026 changes the standard those records must meet, and where most businesses will find they fall short is not in what they have kept, but in how they have kept it.
This new rule was issued on 2 June 2026 and takes effect from 30 July 2026, setting specific requirements for completeness, legibility, accessibility, and document quality. It is especially relevant to businesses that already digitise paper records, store information across multiple systems, use encryption or password protection, or hand record management to an external provider.
The question the new law answers is not whether to keep records; in fact, it is whether the information inside those records can actually be produced when the Federal Tax Authority asks for it.
What FTA Decision No. 4 of 2026 Actually Means and Requires
Cabinet Decision No. 74 of 2023 defines what the accounting records and commercial books are in the UAE. This includes financial records, payroll, fixed asset, inventory, and supporting documents such as invoices, contracts, licences, correspondence, and documents underlying tax calculations.
What FTA Decision No. 4 of 2026 adds is a defined standard for being able to maintain the information those records contain, particularly when businesses retain copies rather than originals.
The retained information must be:
- Complete: every page and piece of content from the original
- Identical to what the original document contained
- Clear and easily legible at the point of access
- Accessible to the FTA upon request, without delay or obstruction
A file that is sitting in an archive satisfies none of these requirements on its own. The question now is whether the complete, readable content of that file can even be produced when required.
Also check: Accounting & Bookkeeping Services
What the Rules Say About Electronic Copies and Photocopies
When businesses choose to retain copies rather than have original documents, the copy must do more than just exist. It must fully reproduce what the original contained. FTA Decision No. 4 of 2026 sets two specific standards that apply to every electronic copy and photocopy held as part of the accounting records of a business in the UAE.
Document Completeness and Page Order
Partial scanning is not permitted; every page of the original document must be retained in the same sequence as the original, not only the pages that seemed important at the time of digitisation.
A seven-page supplier agreement that contains payment terms, pricing schedules, delivery conditions, and signatures is not adequately captured by scanning only the execution page. The compliance gap is the same whether it was created by deliberate selective scanning or a process that never required a completeness check.
Situations that commonly produce incomplete electronic records:
- Scanning only pages that are considered commercially significant
- Leaving out annexes, schedules, or attachments
- Saving pages in a different sequence from the original
- Stripping out content before uploading
- Disposing of the original after an incomplete scan
Every digitised document should be checked for completeness before the original is filed or destroyed.
Legibility and Scan Quality
A file that opens is not necessarily a file that will actually comply. Electronic copies must have sufficient quality and resolution to ensure that the information remains clear and legible, not only on the day of scanning but whenever the FTA requests access.
Open documents from an older archive and examine even the smallest details, figures, dated signatures, and reference numbers. If those details are difficult to read at normal zoom, the scanning standard is inadequate, and the archive needs to be reviewed before the FTA does it first.
Need Expert Advice?
Contact the team at Farahat & Co. for professional support and expert insights for businesses operating in the UAE.
Giving the FTA Access to Records and Records When Required
Being able to maintain UAE tax records is not only about how they are stored, but it is also about whether they can be reached when needed.
FTA Decision No. 4 of 2026 requires that records, and the systems that hold them, remain accessible to the tax authority when required. This obligation applies equally to digital systems, encrypted archives and physical documents.
Related: Accounting Review Services
Access to Records and Storage Systems
A business should be able to answer the following without any delay:
- Where are current and historical accounting records being held?
- Who controls access to each storage location or system?
- How can a specific document be located and retrieved on request?
- How can the relevant storage system itself be accessed?
These questions are straightforward when records are centralised and have been well indexed. They become difficult when records are spread across multiple platforms, older archives have not been indexed, or the people who built those archives are no longer with the business.
Encrypted and Password-Protected Records
Encryption and password protection are legitimate tools that are useful in being able to secure sensitive accounting and commercial books. They do not create a basis for withholding those records from the FTA.
Where records are protected, the necessary passwords or encryption keys must be made available when the authority requests access. Businesses should build this into their information security policies rather than treating it as a separate compliance matter.
One specific operational risk: where a single employee holds the only password or encryption key for an archive, the business loses access if that person becomes unavailable. An authorised backup process that has been documented, tested, and accessible to more than one person removes that dependency entirely.
Physical Records
Physical documents must be maintained in a way that allows the FTA to be able to locate and access them when required. A business may hold every required invoice while still facing a practical failure if those invoices are distributed across unlabelled boxes, stored at an inaccessible location, or damaged by poor environmental conditions.
The relevant internal test: ask an authorised employee who played no role in the original filing to locate a specific older document independently. If the process depends on institutional memory rather than a documented system, the retrieval process needs redesigning.
When a Third Party Manages Your Records
Businesses can engage an external provider to maintain their accounting and commercial books, as it is permitted under the new rule.
What is not permitted is the transfer of the legal responsibility. The business remains accountable for the proper maintenance and safety of its records regardless of who physically holds them.
Before such a business appoints an external provider, they must first establish the following in writing:
- How the provider verifies document completeness at intake
- What electronic backup procedures apply and how frequently they run
- How access is controlled, logged, and audited
- How quickly complete records can be retrieved when the FTA requests them
- What data security standards the provider applies
- What happens to records if the service arrangement ends or the provider changes
Note: That last point carries the most risk. A business that discovers that its critical UAE tax records are held in a proprietary format that cannot be exported without the cooperation of the provider faces a compliance problem at exactly the moment it can least afford one.
How Long to Keep Records and How to Keep Them
There are two separate obligations that govern UAE tax records: how long they must be kept, and how the information within them must be maintained.
FTA Decision No. 4 of 2026 tends to address the second of those questions. The first is governed by Cabinet Decision No. 74 of 2023 and the broader UAE tax legislative rule. Both must be satisfied simultaneously for full accounting records retention compliance.
| Question | Governing Source |
|---|---|
| How long must records be retained? | Cabinet Decision No. 74 of 2023 and applicable UAE tax legislation |
| How must the information be maintained? | FTA Decision No. 4 of 2026 |
A record kept for the correct period but held in incomplete or unreadable form fails the maintenance standard. Retention and maintenance are not interchangeable; they are in fact two distinct requirements that sit alongside each other.
Conclusion: Review Your Current Record Management Process
The decision by the FTA became effective on 30 July 2026. A structured review of current record management practices that covers both newly created records and historical archives is the most practical immediate step.
Historical archives deserve particular attention. Documents that have been scanned before 30 July 2026 under lower internal standards may be technically saved but not compliant with the current requirements under FTA Decision No. 4 of 2026.
As a business that wants to stay compliant, the goal is to identify those gaps now, as it is considerably easier than addressing them after an FTA request has already arrived.
Review Checklist
| Area | What to Check |
|---|---|
| Scanning procedures | Are complete documents captured rather than selected pages? |
| Document quality | Can all important details be read clearly in older archived files? |
| Page sequence | Are pages stored in the same order as the original document? |
| Retrieval | Can staff easily locate and produce specific older records without relying on one person? |
| System access | Can authorised personnel provide FTA access to every storage location? |
| Encryption controls | Are passwords and encryption keys backed up and accessible to more than one authorised person? |
| Physical storage | Are paper records organised, protected from damage, and retrievable? |
| Third-party arrangements | Can external providers retrieve complete records promptly and in a usable format? |
See also: Tax Agent in Dubai, UAE
Frequently Asked Questions (FAQs)
What is FTA Decision No. 4 of 2026?
Can businesses maintain accounting records electronically?
What does the prohibition on partial scanning mean in practice?
What quality standard applies to electronic copies?
What happens if accounting records are encrypted or password-protected?
Can a third party maintain a company's accounting records?
How does FTA Decision No. 4 of 2026 relate to record retention periods?
What should businesses prioritise immediately?
Need Expert Advice?
Contact the team at Farahat & Co. for professional support and expert insights for businesses operating in the UAE.
How Farahat & Co. Can Help
Farahat & Co. helps businesses review their accounting record management against FTA Decision No. 4 of 2026, covering scanning and digitisation standards, access and encryption controls, physical storage practices, and third-party record-keeping arrangements.
Contact Farahat & Co. today to discuss your accounting records compliance requirements.
