An employee file, VAT invoice, shareholder register and annual accounts are not necessarily subject to the same retention period under UAE law. UAE record-keeping requirements depend on the document, the company’s legal structure, its licensing authority and its activities.
Companies reviewing how long they must keep business records should consider the relevant corporate, employment, tax, beneficial ownership and anti-money laundering rules.
Record-Keeping Is a Statutory Obligation
Article 26 of Federal Decree-Law No. 32 of 2021 on Commercial Companies requires companies within its scope to keep accounting records that show their transactions and accurately disclose their financial position. The records must generally be retained at the company’s headquarters for at least five years after the end of the relevant financial year. Electronic copies may be maintained where permitted.
Federal Decree-Law No. 50 of 2022 Promulgating the Commercial Transactions Law imposes additional record-keeping obligations on companies within its scope. Outgoing and incoming business correspondence, invoices and other business documents must be retained for at least five years from issue or receipt. Commercial books and supporting documents must be retained for at least five years from the date on which the relevant book is marked as complete.
Longer periods may apply where the same records are governed by tax, employment, beneficial ownership, anti-money laundering or sector-specific legislation.
Financial and Accounting Records
Accounting records should be complete enough to explain the company’s transactions and financial position. They commonly include ledgers, annual accounts, audit reports, invoices, bank records, payroll information, asset registers and supporting contracts.
For companies governed by the Commercial Companies Law, the general minimum is five years after the end of the relevant financial year. Before destruction, the company should confirm that the document is not still required for a tax return, VAT treatment, unresolved liability or pending audit.
Corporate and Ownership Records
A company’s corporate file should establish its legal existence, ownership and authority to act. It commonly includes constitutional documents, licenses, ownership registers, resolutions and powers of attorney.
Cabinet Resolution No. 109 of 2023 Regulating the Real Beneficiary Procedures requires legal persons within its scope to maintain a real beneficiary register and a register of partners or shareholders. Changes must generally be recorded within 15 days after the company is informed of, or becomes aware of, them.
On dissolution or liquidation, the liquidator must deliver the registers, or exact copies, to the registrar within 30 days and retain the relevant records and data for at least five years. Financial free zones are excluded from this federal regime and apply their own beneficial ownership rules.
Employment Records
Federal Decree-Law No. 33 of 2021 Regulating Labour Relations requires employers to retain each worker’s file and records for at least two years after the end of employment.
The file may include contracts, work permit documents, payroll and leave records, disciplinary correspondence, end-of-service calculations and termination documents. Payroll records may also need to remain available for five or seven years under accounting or tax rules. Documents connected with an unresolved claim should not be destroyed merely because the employment-law period has expired.
Tax, Corporate Tax and VAT Records
Cabinet Decision No. 74 of 2023 on the Executive Regulation of Federal Decree-Law No. 28 of 2022 on Tax Procedures, as amended by Cabinet Decision No. 17 of 2026, covers accounting records, commercial books and supporting information. The amendments took effect in April 2026.
Unless a specific tax law provides otherwise, the principal periods are:
- five years following the relevant tax period for a taxable person;
- five years from the end of the calendar year in which the document was created for a person other than a taxable person; and
- seven years from the end of the calendar year in which a real estate record was created.
Additional periods apply in specified circumstances. Records must be retained for a further four years, or until final settlement if later, during a dispute with the Federal Tax Authority. A further four years applies during an ongoing tax audit or where the FTA gives notice of an intended audit before the ordinary period expires.
A voluntary disclosure filed during the fifth year extends the retention period by one year. Under the 2026 amendment, records relating to a tax refund application may also need to be retained for a further two years where the application remains pending.
Corporate tax has a separate seven-year minimum. Under Article 56 of Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses, taxable persons must retain the records supporting their tax returns and taxable income for seven years after the end of the relevant tax period. Exempt persons must keep the records required to establish their exempt status for the same period.
Under the VAT legislation, records relating to real property must be retained for 15 years after the end of the tax period to which they relate.
Minimum Retention Periods at a Glance
| Record category | General minimum period |
| Accounting records under the Commercial Companies Law | 5 years after the relevant financial year |
| Commercial correspondence and invoices | 5 years from issue or receipt |
| Commercial books and supporting documents | 5 years after the book is marked complete |
| Employee files | 2 years after employment ends |
| General records of a taxable person | 5 years after the relevant tax period |
| General tax records relating to real estate | 7 years from the end of the year of creation |
| Corporate tax records | 7 years after the relevant tax period |
| VAT records relating to real property | 15 years after the relevant tax period |
| ADGM company accounting records | 10 years from the date made |
| AML records for covered businesses | At least 5 years; starting point depends on the record |
Where one document falls into several categories, the longest applicable period should be used.
Additional Rules for Businesses Subject to AML Obligations
Financial institutions, designated non-financial businesses and professions, and virtual asset service providers are subject to additional requirements under Cabinet Resolution No. 134 of 2025, the Executive Regulations of the federal anti-money laundering legislation, effective since December 2025.
Covered businesses must retain transaction records for at least five years after completion of the transaction or termination of the customer relationship. Customer due diligence materials, account files, identification documents and suspicious transaction reports are also subject to prescribed five-year periods.
Depending on the record, the period runs from the most recent applicable event, including account closure, completion of an occasional transaction, a supervisory inspection, an investigation or a final court judgment.
Where and How Records Should Be Stored
The Commercial Companies Law requires accounting records within its scope to be kept at the company’s headquarters. Tax records may be stored electronically where the information is identical to the original, remains available throughout the retention period and can be reproduced in readable form when requested by the FTA.
An electronic archive should allow prompt retrieval, preserve document integrity, restrict access, maintain backups and suspend deletion during audits, disputes or investigations. Originals should be retained where required by law, an authority or evidentiary considerations.
Mainland and Free-Zone Rules May Differ
The Commercial Companies Law does not apply to a free-zone company on matters for which the relevant free-zone legislation contains a special provision. Federal tax obligations may still apply.
Under sections 375 and 377 of the ADGM Companies Regulations 2020, as amended, an ADGM company must keep adequate accounting records at its registered office or another place selected by its directors. Those records must be preserved for ten years from the date on which they are made. The DIFC and other UAE free zones must be reviewed separately.
Consequences of Inadequate Records
The consequence of a record-keeping failure depends on the applicable law and authority.
Missing documents may prevent a company from substantiating a tax return or VAT deduction, responding to an audit or proving corporate authority. Administrative penalties may also arise. Incomplete records can delay transactions, weaken an employer’s position in a labor dispute or obstruct due diligence and financing.
Establishing a Retention Policy
A company document-retention policy in the UAE should reflect the entity’s legal structure, licenses, activities and regulators. It should account for overlapping corporate, employment, tax, beneficial ownership and sector-specific requirements rather than applying a single period to every category of record.
The policy should:
- classify records by legal purpose;
- identify the event that triggers each retention period;
- apply the longest applicable period where requirements overlap;
- assign responsibility for approving and carrying out document destruction; and
- suspend deletion during disputes, audits, investigations and transactions.
Finance, human resources, management and compliance teams may each hold part of the same statutory record. The policy should be reviewed whenever the business or applicable legislation changes.
Kisser Legal’s regulatory compliance services include assessing UAE compliance and record-retention requirements and reviewing internal document-retention policies. This may include identifying gaps in corporate compliance under UAE law and the requirements applicable to a company’s structure and activities.