Who keeps your e-invoice records when you change providers?
Separate invoice archives from provider logs, confirm retention and storage requirements, and rehearse a complete export before changing systems.
A provider dashboard is not an exit plan. Before signing an e-invoicing contract, establish what records you can retrieve, how long access lasts and who keeps them after the relationship ends. “We store your invoices” leaves all three questions unanswered.
Rules checked: 30 September 2026. This is operational guidance, not legal or tax advice. Confirm your retention schedule, hosting arrangement and sector requirements with qualified advisers. The retrieval rehearsal below is a proposed exercise, not a tested Nesaku service or migration result.
Storage can be delegated. Responsibility cannot
Decision 243, Article 11, requires retention of electronic invoices, credit notes and associated data. MoF Guidelines Appendix 4 distinguishes those business records from an ASP’s transactional logs. Logs provide identifiers, routing and transmission status; they do not constitute the invoice content the business must retain.
The same guidance permits contracted ASP storage but leaves the person responsible for retention. FTA Decision 4 of 2026, Article 4, likewise allows third-party recordkeeping while preserving the person’s legal responsibility.
In practical terms, ask two separate questions: “Can you show how the document travelled?” and “Can you return the complete document and associated records?” A convincing answer to the first does not settle the second.
Specify the export before buying the archive
Use the following as a proposed evidence checklist, not a statutory file-format specification. Agree which party provides each item, including records held by your accounting system rather than the ASP.
| Record | What to request | Owner to name |
|---|---|---|
| Issued and received invoices | Structured electronic documents and a readable way to inspect them | Archive operator |
| Credit notes | Complete documents with original-invoice references | Finance and archive operator |
| Exchange and reporting evidence | Available confirmations, errors and identifiers linked to documents | ASP and integration operator |
| Source-to-provider mapping | Source numbers, provider identifiers and relevant conversion versions | Integration operator |
| Supporting business records | Relevant approvals, attachments and correction decisions | Finance |
| Archive access and protection | Retrieval instructions, permissions and controlled key recovery | Systems owner |
FTA Decision 4, Articles 2 and 3, requires complete, identical and legible records, authority access on request and necessary access to encrypted or password-protected records. Design secure authority-access procedures rather than removing encryption. Keep access credentials out of routine exports and ordinary support tickets.
Our recommendation is to retain the structured electronic document alongside a readable rendering. A PDF view alone does not establish that you preserved all the content of the exchanged electronic invoice. Nor does an accounting spreadsheet automatically preserve document links and reporting evidence.
Do not set one five-year deletion rule
Retention depends on the record, applicable tax law and circumstances. These examples show why a generic archive setting needs review; they are not an exhaustive schedule.
| Requirement | Source-backed position |
|---|---|
| General Tax Procedures records | Article 3 generally specifies five years after the relevant Tax Period for a Taxable Person, with different starting points for other persons and real-estate records, unless another Tax Law provides otherwise |
| Corporate Tax supporting records | Article 56 specifies seven years after the relevant Tax Period for covered taxable-person records and records establishing exempt status |
| VAT real-estate records | VAT Executive Regulation Article 71 specifies 15 years after the relevant Tax Period |
| Extensions and holds | Audits, disputes, qualifying voluntary disclosures and unresolved refund applications can extend general retention periods |
Sources: Tax Procedures Executive Regulation, consolidated with the 2026 amendment; Corporate Tax Law, Article 56; VAT Executive Regulation, Article 71. The 2026 Tax Procedures amendment includes an additional two-year period for qualifying unresolved refund applications. Do not rely solely on a provider’s older five-year summary.
Ask your adviser to approve a schedule by record category, start event, base period and extension or hold. The systems owner implements that schedule; they should not choose tax retention periods from a software dropdown. If one document supports several obligations, resolve those together before authorising deletion. Sector rules and legal holds may add requirements not covered here.
Resolve the storage-location conflict in writing
There is a material difference between the legislation and explanatory guidance. Decision 243, Article 11, expressly specifies storage within the State. MoF Guidelines section 5.4 says records may be stored inside or outside the UAE if secure, complete and accessible and reproducible for the FTA. Appendix 4 also says storage need not occur at a particular system layer.
Do not turn that guidance into a settled claim that overseas storage is always acceptable. Equally, do not present every possible architecture as subject to an unqualified UAE-only physical-server rule without acknowledging the guidance.
Document the intended locations of primary storage, backups and subprocessors. Obtain written regulatory clarification or acceptance for the proposed arrangement, with adviser review of applicable sector and data-protection requirements. An ASP’s commercial assurance alone does not resolve a conflict between legislation and guidance. Keep the written basis with the contract and revisit it when hosting changes.
Rehearse retrieval while you still have leverage
Before acceptance, choose a small representative set: issued invoice, received invoice, credit note and a document with a resolved error. Ask for a complete export and have someone other than the implementer retrieve it from the proposed archive.
Check that they can:
- Find a document using its original accounting reference.
- Read the content and inspect its structured version.
- Follow the credit note to the original invoice.
- Locate available exchange and reporting evidence.
- Identify missing records and obtain an explanation.
- Retrieve everything without the departing provider’s dashboard.
Record the observed result and gaps. This is a proposed acceptance exercise, not a guarantee that every provider offers identical exports. Include it in your acceptance plan.
Make exit a controlled handover
The contract should specify export formats, completeness, cost, delivery timing, post-termination access and responsibility for retention. Ask how outstanding submissions, incoming documents and participant migration will be handled. Plan a final reconciliation and retrieval check before cancelling access or approving any permitted deletion.
Finance signs off document completeness and outstanding corrections. The integration operator reconciles identifiers and statuses. The ASP handles its provider-side onboarding or offboarding procedures. A named business owner accepts the handover and confirms where remaining obligations sit.
Use the ASP contract questions and failure ownership runbook together. The readiness guide puts those decisions in the wider project.
If nobody can explain what survives a provider change, discuss a records and systems handover review with Nesaku. Resolve the boundaries before access ends.
Primary sources
Checked 30 September 2026. FTA English legislation PDFs identify their translations as unofficial. Confirm authoritative text and applicable amendments for legal reliance.
- MoF Decision 243 of 2025, Article 11.
- MoF Guidelines v1.1, section 5.4 and Appendix 4.
- FTA Decision 4 of 2026, Articles 2–4.
- Tax Procedures Executive Regulation, 2026 consolidation, Article 3.
- Corporate Tax Law, Article 56; linked statute text, not a complete consolidated amendment history.
- VAT Executive Regulation, September 2026 consolidation, Article 71.