Retention obligation and digital receipts: what to keep and how

How long must a business keep its records?

A Dutch business must keep its records for 7 years; data on immovable property and rights to it must be kept for 10 years. Businesses using the Union or Import scheme of the One Stop Shop (OSS) must also keep the data on those supplies and services for 10 years. The 10-year period for immovable property is linked to the revision of VAT deductions, for which the data may be needed that long.

The retention period only starts when a record loses its current value. A lease contract running for 4 years belongs to the current records for those 4 years, and only then does the 7-year period begin. For data other than the core records you can agree a shorter period with the Dutch Tax Administration; such an agreement only applies to the tax authority. If a client stops trading, the retention obligation still applies.

What exactly must you keep?

You keep all data about the business recorded on paper or digitally, with at its core the basic records that must always be kept for 7 years. Contracts, correspondence, bank statements and till data also belong to the records insofar as they are fiscally relevant. Entrepreneurs who rely on the hours criterion or the self-employed deduction must also keep their time records. According to the Dutch Tax Administration, the basic records are:

The form matters. You keep invoices in the form in which you sent or received them: an invoice received digitally is stored digitally and not printed and then deleted. If you store digitally, the tax authority must be able to work with your files during an audit. Only a small administration that can be audited within a reasonable time may be kept on paper. Mind the GDPR as well: personal data is not kept longer than necessary.

• The general ledger.
• The accounts receivable and accounts payable records.
• The stock records.
• The purchase and sales records, with all purchase and sales invoices.
• The payroll records.
• Data relevant to the taxation of others.

May you scan paper receipts and discard the original?

Yes, you may scan paper invoices and receipts and then discard the original, as long as the scan is a correct and complete copy of the original. The Dutch Tax Administration calls this conversion. You do not need permission, but you are responsible for ensuring the conversion meets the conditions. A paper balance sheet and profit and loss statement may not be converted, and exceptions apply to certain customs documents.

Complete means that every page with fiscally relevant information is scanned, including the back and any attachments. Authenticity features such as a logo, colour or watermark can be lost when scanning; you must compensate for that with technical or organisational measures. A blurry photo on which the VAT amount cannot be read therefore does not qualify. The conditions for conversion:

1. 1Transfer all data, including front and back and attachments.
2. 2Transfer the data correctly, so the scan is clearly legible.
3. 3Make sure the new data carrier remains available for the full retention period.
4. 4Make sure you can reproduce the data and make it legible within a reasonable time.
5. 5Make sure the tax authority can audit the converted data within a reasonable time.

What does the retention obligation mean for intake via portal, app and email?

For intake via portal, app and email, the retention obligation means that the delivered document itself, not just the booking, must be kept and remain retrievable. A PDF that arrives by email is the original and must be kept as a file. A photo of a paper receipt in the app is a conversion, so the photo must be complete and legible if the client throws the paper away.

Agree with clients what they deliver and how. Ask for photos showing the whole receipt, including date, amount and VAT, and for the original PDF rather than a forwarded screenshot. Record where the document ends up after processing: with the booking in the accounting software, in a document archive or both. An illegible or incomplete document is also a reason to ask the client a question, before the original is gone.

Why does an audit trail matter for retention?

An audit trail matters because the tax authority not only wants to see the documents, but must also be able to follow how they led to bookings and returns. Dutch law requires the authenticity of origin, the integrity of content and the legibility of an invoice to be guaranteed from issue until the end of the retention period. This can be done, among other ways, with business controls that create a reliable audit trail between invoice and supply.

In practice this means you must be able to go from a booking back to the source document, and from a document to the booking and the payment. Changes afterwards must be traceable too: who changed a booking, when and why. With automated processing, that also includes being able to see what the software proposed and what a person approved.

How do Autoboeker's audit logs and document storage relate to this?

Autoboeker records every action by users and AI in audit logs, so it is traceable what happened to a document and a booking. Every booking has a confidence score and an explanation, and with approvals, every approval and rejection is in the audit log, with person and time. The client question history keeps every question, answer and delivered document retrievable. Data is encrypted in transit (TLS) and at rest (AES-256).

Autoboeker is not a fiscal archive for the full retention period: client data is deleted when the account ends. Record, therefore, that the administration in the accounting software, with its source documents, or your own archive is where your clients meet the retention obligation. Documents arrive via the client portal, the iOS and Android app, a purchase or sales email address, WhatsApp, connected mailboxes and cloud storage. Check per package how documents are kept with the booking.