Outsourced bookkeeping and FTA Decision No. 4 of 2026

Outsourced bookkeeping is an established model, whether for a whole finance function, for transaction processing beneath an in-house controller, or for the smaller entities of a group. FTA Decision No. 4 of 2026, issued by the Federal Tax Authority (FTA) on 2 June 2026 and in force since 30 July 2026, confirms that it is permitted: a business may engage a third party to keep its records. It is equally clear on the other side. The business remains legally responsible for keeping those records, and for keeping them safe (Art. 4). If records are missing, incomplete or inaccessible, the penalty falls on the company, not on its provider.

What FTA Decision No. 4 of 2026 covers

The decision sets rules for how records are kept, including copies and electronic records. It builds on Cabinet Decision No. 74 of 2023, Art. 4, which already allowed photocopies and electronic copies provided they are identical to the original, available for the full retention period, reproducible as a readable copy on request, and stored so the FTA can verify compliance. FTA Decision No. 4 of 2026 adds detail (Arts. 2 to 3):

• Copies must be complete and identical to the original, with all pages in the original order. Partial scans are not accepted.
• Copies must be legible on screen.
• Photocopies must use ink and paper that will not fade during the retention period.
• The FTA must be given access on request, including passwords or encryption keys and access to the system that holds the records.

Who is responsible for what

The work can be outsourced. The responsibility cannot. A clear division looks like this:

Scans: what "complete" means

The usual failures are small and easily corrected once someone owns them. A photograph of page one of a three-page invoice or contract is not an acceptable copy; it must be every page, in order. Cropped or blurred phone images fail if they cannot be read on screen. Thermal till receipts fade, so they need scanning on receipt, because a faded original cannot be recovered later. And documents split across places, such as an invoice in one mailbox and its delivery note at a site office, should be filed against the same transaction.

Decide where scanning happens. If the business scans, agree the standard with the provider and have it reject anything incomplete. If the provider scans paper originals, agree who retains them.

Passwords and access: the point most often missed

The FTA can ask for access to the system that holds the records, including passwords or encryption keys. That becomes a real problem when the only administrator login to the accounting software, cloud storage or receipt-capture tool sits with a provider, a former employee or a contractor the business no longer uses.

Three points to confirm now:

1. The business, not the provider, owns the accounting software subscription.
2. At least one person inside the business holds administrator access to the accounting system, the document store and the bank feeds.
3. The business knows how to export its data in a readable form if the relationship ends.

How long the records must be kept

The retention clock does not reset when the provider changes. Corporate tax records must be kept for at least 7 years after the end of the tax period (Federal Decree-Law No. 47 of 2022, Art. 56), VAT real-estate records for 15 years, and anything linked to an open audit, dispute or refund claim for longer. Once e-invoicing starts, e-invoice data must also be stored within the UAE (Ministerial Decision No. 243 of 2025, Art. 11). Our guide to how long to keep business records has the full table.

Failing to keep the required records costs AED 10,000 per violation, or AED 20,000 for a repeat within 24 months, under both the VAT and the corporate tax penalty tables.

What to agree with an outsourced bookkeeping provider

These terms belong in the engagement letter, or in a short schedule to it:

1. Ownership. The records, the data and the software subscription belong to the business.
2. Access. Who holds administrator rights and who holds user rights, and how passwords and keys are stored and changed when people leave.
3. Scanning standard. Complete documents, every page, original order, legible, and who scans what.
4. Missing documents. How gaps are reported to the business, and how often.
5. Storage. Where documents and data are held, how they are backed up, and where e-invoice data will sit.
6. Retention. Records kept for the full period, including any extensions, and not deleted when the engagement ends.
7. FTA requests. Who assembles the documents, who arranges an Arabic translation if the FTA asks for one, and who responds. Records submitted to the FTA must be in Arabic, or in English with a translation if requested, at the business's cost; not providing them in Arabic when asked costs AED 5,000.
8. Handover. What the business receives back if it leaves, in what format, and how quickly.

A quick test of the current arrangement

Could the business produce a complete, readable copy of any purchase invoice from four years ago? Does someone inside the business hold administrator access to every system that stores its records? If either answer is no, it is better corrected before the FTA asks than after. A sample test of the last ten purchase invoices against the "all pages, in order, legible" standard is also worth running. Our bookkeeping health check covers the rest of the basics.

How ebs can help

When ebs Chartered Accountants keeps the books, you have a dedicated contact, with an engagement partner overseeing the work. Every package includes free setup and implementation: chart of accounts, software and Zoho Books training. If you leave, all records and documents are handed over within 7 working days. See bookkeeping and our fixed monthly packages, or contact us for a free first consultation.

This article is general information as at 17 September 2026, not advice on your specific circumstances. Rules change; check the current position before acting.