Scanned it, shredded the original - are your records still FTA-proof?
Created By :
Yeeshu Sehgal | UAE Tax Lead
A UAE business digitises its purchase invoices, saves each as a PDF and shreds the paper. Is the scan enough if the FTA comes knocking? Under FTA Decision No. 4 of 2026, issued 2 June 2026 and effective 30 July 2026, the answer is yes but only if the copy clears a specific set of integrity, legibility and access tests. The Decision sets the rules for keeping accounting records and commercial books as an Electronic Copy or a Photocopy, filling in the detail behind the record-keeping obligations.
The three rules that govern every copy
Article 2 sets three plain requirements. Records must be complete and identical to the originals; they must be clear and easily legible; and the FTA must be able to access them on request including access to the system where they are held. Everything else in the Decision is simply how each of these is tested in practice.
“Identical” and “legible”, defined
A copy must reproduce the whole document - every page, in the original order. Partial scanning is expressly rejected, so capturing only the signed page or the schedule you care about will not do. The copy must be readable on screen at a sensible resolution, and the ink and paper used for a physical photocopy must be good enough that it does not fade across the retention period. A black-and-white copy of a colour original is fine, provided nothing material is lost.
Giving the FTA access - including your passwords
Where records sit behind encryption or passwords, you must hand over the keys or passwords the FTA needs to get in. For physical photocopies, access extends to the places where they are stored. Access is not a formality you can gate - an inability to open your own system on request is a compliance gap.
Outsourcing is allowed - the responsibility is not
Article 4 lets you engage a third party to maintain the records - an accountant, a cloud provider, a document-management service. But you remain legally responsible for keeping them and for their safety. A vendor’s failure is your failure in the FTA’s eyes, so the obligation to produce complete, legible, accessible records never leaves your hands.
Does your copy pass?
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Scenario
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What the Decision requires
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Verdict
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Only the signed last page of a 12-page contract is scanned
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Identical copy of the original, all pages, same order; no partial scanning
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Not compliant
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A colour invoice is saved as a black-and-white PDF, still fully readable
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A non-coloured copy of a coloured document is allowed if data stays legible
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Compliant
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Records sit in an encrypted system; password not shared when the FTA asks
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Encryption keys or passwords must be provided to enable FTA access
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Not compliant until access is given
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Books are kept on an outsourced accounting firm's cloud platform
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A third party may be engaged, but you remain legally responsible
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Compliant - responsibility stays with you
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Thermal-paper receipts kept as originals, now fading
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Ink and paper must not fade during the record-keeping period
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Risk - convert to a durable copy
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What to do before the next FTA request
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Scan documents in full - all pages, in order. Retire any “key-page-only” scanning habit.
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Spot-check on-screen legibility of stored copies, especially older or compressed files.
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Digitise fade-prone originals (thermal receipts, faint carbon copies) to a durable copy.
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Keep encryption keys and passwords ready to share, and know where physical copies are stored.
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Confirm your outsourcing contract reflects that legal responsibility stays with you.
How we can help
AKM Global can review how your accounting records and commercial books are captured, stored and secured, test them against Decision No. 4 of 2026 and close any gaps before they surface in an FTA request.