Archiving Accounting Documents in Belgium: Retention Rules

In Belgium, every entrepreneur, whether self-employed as a sole trader or the manager of a company, must keep their accounting documents for a precise legal period. Failing to meet these obligations can lead to severe financial penalties, or even tax reassessments. This complete guide explains exactly which documents to keep, for how long, in what format, and how to organise your archiving efficiently and in compliance with Belgian legislation in 2026.

The legal framework: which laws govern archiving in Belgium?

The obligation to retain accounting documents in Belgium rests on several fundamental pieces of legislation:

The Code of Economic Law (CDE)

Book III of the Code of Economic Law (formerly the Act of 17 July 1975 on business accounting) forms the main legal basis. Article III.86 requires every company to keep its accounting books and documents for 7 years from 1 January of the year following their closure.

The VAT Code

Article 60 of the VAT Code (CTVA) requires invoices and VAT-related documents to be kept for 7 years from 1 January of the year following the closing date of the period to which they relate. This provision is supplemented by Royal Decree No. 1 of 29 December 1992, which specifies the arrangements for keeping invoices.

The Income Tax Code (CIR 92)

Article 315 of the CIR 92 grants the tax authorities the right to investigate the 7 preceding tax years in cases of suspected fraud (compared with 3 years under normal circumstances, art. 354 CIR 92). This means that even though the normal audit period is 3 years, it is prudent to keep accounting documents for at least 7 years.

The Companies and Associations Code (CSA)

For companies, the CSA imposes additional obligations, notably the retention of general meeting minutes, management reports and annual accounts.

Which accounting documents to keep, and for how long?

Here is a summary table of retention periods by document type:

Special case: investment assets and VAT

For investments in real estate, the VAT revision period is 15 years (art. 48, para. 2 CTVA). You must therefore keep all documents relating to the acquisition, construction or renovation of buildings for at least 15 years. For movable investment assets, the revision period is 5 years (art. 48, para. 2 CTVA).

Special case: limitation periods for fraud

In cases of tax fraud, the tax authorities have an extended investigation period of 10 years (art. 354, para. 2 CIR 92, as amended). It is therefore recommended to keep all your accounting and tax documents for 10 years as a precaution.

When does the retention period start?

Calculating the starting point is essential, and is often a source of confusion:

• General accounting documents: the 7-year period starts running on 1 January of the year following the closure of the accounting year to which they relate.
• VAT invoices: the period runs from 1 January of the year following the invoice date or the closing date of the relevant VAT period.
• Contracts: the period runs from the end of the contract, not its signature date.

Concrete example: an invoice dated 15 March 2026, for an accounting year closing on 31 December 2026, must be kept until 31 December 2033 (7 years from 1 January 2027).

Paper or digital archiving: what does Belgian law say?

The Act of 21 July 2016 (Digital Act)

Belgium has adopted the Act of 21 July 2016, which establishes a legal framework for trust services and electronic documents. This Act recognises the evidential value of digital copies of original paper documents, provided certain requirements are met.

The conditions for valid digital archiving

For a digital document to have the same evidential value as a paper original, the following conditions must be met (in accordance with the Royal Decree of 9 March 2003 and the Act of 21 July 2016):

1. Integrity: the document must be kept in a format that guarantees its integrity (no possible alteration). The recommended formats are PDF/A (ISO 19005 standard) or TIFF.
2. Legibility: the document must remain legible throughout the retention period.
3. Accessibility: documents must be accessible at any time in the event of a tax audit.
4. Timestamping: it is recommended to use a qualified electronic timestamp to prove the date of digitisation.
5. Documented procedure: the company must have an internal procedure describing the digitisation and archiving process.

The eIDAS Regulation

The European eIDAS Regulation (No. 910/2014), directly applicable in Belgium, sets the framework for electronic signatures, electronic seals and trust services. A document signed with a qualified electronic signature has the same legal value as a handwritten signature.

Can paper originals be destroyed after digitisation?

Yes, under certain conditions. Since the Act of 21 July 2016, it has been possible to destroy paper originals after digitisation, provided that:

• The digital copy is a faithful and durable reproduction
• The digitisation process is documented
• The integrity of the digital document is guaranteed

Warning: certain documents must always be kept in paper original, notably notarial deeds, title deeds and certain employment documents.

How to organise your archiving: a practical guide

Recommended filing structure

Here is a filing structure that has proven effective for Belgian entrepreneurs:

Accounting archive/
|-- Financial year 2026/
|   |-- 01-Sales/
|   |   |-- Invoices issued/
|   |   |-- Credit notes issued/
|   |-- 02-Purchases/
|   |   |-- Invoices received/
|   |   |-- Credit notes received/
|   |-- 03-Finance/
|   |   |-- Bank statements/
|   |   |-- Cash records/
|   |-- 04-VAT/
|   |   |-- Periodic returns/
|   |   |-- Annual customer listing/
|   |-- 05-Tax/
|   |   |-- Corporate or personal tax return/
|   |   |-- Tax assessment notices/
|   |-- 06-Social/
|   |   |-- Payslips/
|   |   |-- NSSO documents/
|   |-- 07-Legal/
|   |   |-- Contracts/
|   |   |-- General meeting minutes/
|   |-- 08-Miscellaneous/
|       |-- Important correspondence/
|       |-- Insurance documents/

Digital archiving tools suited to the Belgian market

Several digital archiving solutions are suited to Belgian requirements:

• Doccle: a Belgian platform for archiving administrative documents, connected to many Belgian institutions (health insurance funds, insurance companies, administrations).
• Isabel 6: the Belgian banking platform Isabel offers financial document archiving features.
• ClearFacts: a Belgian pre-accounting solution that includes digital archiving of supporting documents with automatic sending to the accountant.
• Yuki: a Dutch platform very popular in Belgium, which allows automatic digitisation and archiving of accounting documents.
• Dext (formerly Receipt Bank): a solution for scanning and automatically filing invoices and receipts.

Practical tips for efficient archiving

1. Digitise immediately: get into the habit of scanning or photographing each supporting document as soon as you receive it. Mobile apps like Dext or ClearFacts let you do this in seconds.

2. Name your files consistently: use a standardised format, for example 2026-03-15_Supplier_Invoice-123.pdf.

3. 3-2-1 backup: apply the 3-2-1 backup rule: 3 copies of your data, on 2 different types of media, with 1 copy off-site (cloud).

4. Check legibility: thermal till receipts fade over time. Digitise them immediately or ask for an invoice instead.

5. Keep a destruction register: if you destroy paper documents after digitisation, keep a register showing which documents were destroyed, when, and by whom.

Penalties for non-compliance with archiving obligations

Failing to meet the obligations to retain accounting documents can have severe consequences:

Tax penalties

• Assessment ex officio (art. 351 CIR 92): if the tax authorities cannot verify your accounts due to missing documents, they can carry out an assessment ex officio based on signs and indications of income.
• Administrative fines: from EUR 50 to EUR 1,250 per VAT infringement (art. 70 CTVA), depending on severity and repeat offences.
• Tax increases: from 10% to 200% of the evaded tax (art. 444 CIR 92).

Criminal penalties

• In cases of tax fraud involving the use of false documents, prison sentences of 8 days to 2 years and fines of EUR 250 to EUR 500,000 may be imposed (art. 449 CIR 92).

Accounting and commercial consequences

• Inability to prove debts: without invoices, it is difficult to justify debts in the event of a commercial dispute.
• Denial of expense deductions: the tax authorities can refuse the deduction of business expenses not backed by supporting documents.
• Denial of VAT deduction: without a compliant invoice, input VAT deduction is refused.

GDPR and archiving: finding a balance

The General Data Protection Regulation (GDPR) imposes a principle of data minimisation and storage limitation. This means you cannot keep personal data beyond what is necessary for the purpose for which it was collected.

How to reconcile GDPR with accounting obligations?

• The legal retention obligations (7 years for accounting documents) constitute a valid legal basis under Article 6.1.c of the GDPR for keeping personal data contained in these documents.
• Once the legal period has passed, documents containing personal data must be destroyed or anonymised.
• Document your retention periods in your register of processing activities (mandatory under Article 30 GDPR).
• Appoint a Data Protection Officer (DPO) if necessary to oversee compliance.

The Data Protection Authority (APD), Belgium's competent authority for GDPR matters, can impose fines of up to EUR 20 million or 4% of annual worldwide turnover for serious GDPR breaches.

Archiving specific to the type of business

Self-employed sole traders (simplified accounting)

Self-employed people whose annual turnover does not exceed EUR 500,000 (excluding VAT) can keep simplified accounts (art. III.85 CDE). They must nonetheless keep:

• A revenue journal
• An expense journal
• A financial transactions journal
• Invoices issued and received
• Annual inventories
• All supporting documents

Companies (SRL, SA, SC)

Companies are subject to double-entry accounting and must keep, in addition to the standard documents:

• The annual accounts filed with the National Bank of Belgium (BNB)
• The minutes of general meetings and board meetings
• The register of units (for SRLs) or the register of shares (for SAs)
• The management reports
• The auditor's reports (if applicable)

Non-profit associations (ASBL)

ASBLs are subject to the same 7-year retention obligations. Since the CSA (2019), large and very large ASBLs must keep double-entry accounts and file their annual accounts with the BNB.

Electronic invoicing and archiving in 2026

The B2B electronic invoicing obligation

Belgium introduced the obligation to use structured electronic invoicing for B2B transactions from 1 January 2026 (Act of 6 February 2024). This means that:

• All invoices between VAT-registered businesses established in Belgium must be issued and received in structured electronic format (Peppol BIS Billing 3.0 format).
• The Peppol network is the official exchange network.
• Micro-enterprises benefit from a transitional regime.

Impact on archiving

Archiving structured electronic invoices must comply with the same 7-year periods. Accredited Peppol platforms in Belgium (such as Hermes from the FPS Finance) offer integrated archiving solutions. It remains the company's responsibility to ensure its electronic invoices are correctly archived.

Checklist: are you compliant?

Use this checklist to check that your archiving is compliant:

• All accounting documents from the last 7 financial years are kept
• Documents are filed in an orderly, accessible manner
• Invoices relating to real estate investments are kept for 15 years
• Digital copies are in PDF/A format or equivalent
• A digitisation and archiving procedure is documented
• Backups are regular and stored securely (3-2-1 rule)
• A document destruction register is kept
• Retention periods are documented in the GDPR register
• Peppol electronic invoices are correctly archived
• Employment documents are kept according to their specific periods

Conclusion

Archiving accounting documents in Belgium is not a mere administrative formality: it is a strict legal obligation, and failing to meet it can have major financial and legal consequences. In 2026, with mandatory B2B electronic invoicing coming into force, Belgian entrepreneurs must adapt their archiving practices.

Remember the essentials: a minimum of 7 years for most accounting and tax documents, 15 years for documents relating to real estate, and rigorous organisation with regular backups. Investing in a good digital archiving system will save you time, protect you in the event of a tax audit, and let you focus on what really matters: growing your business.

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This article was written by the Espero-Soft team for the blog dedicated to entrepreneurs in Belgium. For personalised advice, do not hesitate to consult a certified accountant or tax adviser.