Record retention and electronic archiving of business records in Switzerland

Who must keep accounts and retain records?

All legal entities, as well as sole proprietorships and partnerships with sales revenue of more than CHF 500,000 in the last financial year, must keep accounts and prepare financial statements (Art. 957 para. 1 CO).

Below this threshold, they may limit themselves to “accounts on income and expenditure and on their asset position” (Art. 957 para. 2 CO). The recognised accounting principles still apply by analogy (para. 3): every entry is supported by a voucher and remains traceable (Art. 957a para. 2 CO).

Accounting voucher

“Any written record on paper or in electronic or comparable form that is required to be able to verify the business transaction or the circumstances behind an accounting entry” (Art. 957a para. 3 CO).

For an accounting firm, these rules apply client by client, each with its own financial year-end.

How long to keep business records in Switzerland: 10 years, but from when?

Accounting records, vouchers, the annual report and the audit report are kept for ten years, and “the retention period begins on expiry of the financial year” (Art. 958f para. 1 CO). The invoice date does not count: the financial year in which the document is booked sets the deadline.

Worked example

The first two invoices, issued nine months apart, can be destroyed on the same day: so archive by financial year, and purge a whole financial year at a time.

Work instructions and the archive's access logs are kept as long as what they document (Art. 4 and 8 GeBüV). The retention period calculator gives the date for each type of document, with its legal basis.

Paper or electronic: can you scan and destroy the originals?

Yes, for accounting vouchers. The CO allows them to be retained “on paper, electronically or in a comparable manner”, provided the link to the underlying transactions is guaranteed and they can be made readable again at any time (Art. 958f para. 3 CO).

An invoice received as a PDF therefore does not need to be printed. A paper invoice can be scanned and the original destroyed, provided the copy is placed in an archive that complies with the GeBüV (next section).

Before destroying an original

• The scan is complete: front and back, attachments, annotations relevant to the entry.
• The file is readable and linked to the entry it supports.
• The copy is placed in the archive before the original is destroyed.
• The scanning procedure is described in your work instructions (Art. 4 GeBüV).

For VAT, since 1 January 2018, Art. 122 of the VAT Ordinance (MWSTV) has applied Art. 957 to 958f CO and the GeBüV to electronic supporting documents.

Be careful with a contract signed by hand: accounting law governs how it is retained, not its value as evidence in a dispute. Keep the original. The guide to supplier invoice capture describes the full chain, from receipt of the document to the entry.

GeBüV requirements for electronic archiving

The GeBüV (SR 221.431) gives effect to Art. 958f CO. On a modifiable medium, meaning almost any IT medium (hard drives, SSDs, tapes: Art. 9 para. 2), electronic archiving requires a process that guarantees integrity (for example an electronic signature), tamper-proof evidence of the recording date (for example a time stamp), compliance with the rules specific to the process, and documented procedures with their logs (Art. 9 para. 1 let. b). A simple shared folder is not enough.

What German-speaking vendors call “revisionssicher” (audit-proof) archiving can be checked article by article, with a question to ask your provider for each.

Two answers matter more than the others: how to get the archive out if you leave the provider (Art. 10), and how to prove who viewed what (Art. 8).

VAT: 10 years, 20 for immovable property, and not 26

For VAT, books of account and records are kept “until the right to establish the tax claim has prescribed” (Art. 70 para. 2 VAT Act), that is, ten years after the end of the tax period in which the claim arose (Art. 42 para. 6 VAT Act). The CO period also applies: if the two dates differ, use the later one.

Documents needed to calculate own use of, or a subsequent input tax deduction on, immovable property are kept for 20 years (Art. 70 para. 3 VAT Act). The Federal Tax Administration (FTA, ESTV in German) specifies that this period is extended if the absolute limitation period has not yet been reached.

Why not 26 years?

The figure of 26 years appears neither in the current VAT Act nor in the former VAT Act, both of which provided for 20 years for immovable property. It circulates among some advisers as a safety margin. If you adopt it, record it as an internal choice, not as a legal obligation.

Is a qualified electronic signature required?

No. The FTA states that it sees no need to require qualified signatures for VAT purposes. It considers regulated electronic signatures and seals (Art. 2 let. c and d of ZertES, the Federal Act on Electronic Signatures) particularly suitable for proving the origin and integrity of a document; otherwise, the principle of free consideration of evidence applies (Art. 81 para. 3 VAT Act). See the electronic signature guide.

Where to store the archive: the FADP does not require Switzerland

The revised FADP, in force since 1 September 2023, does not require an archive to be hosted in Switzerland. It regulates processing by processors and the disclosure of personal data abroad, and accounting records often contain such data: names, salaries, bank details.

• Processors (Art. 9): a contract (or the law) provides for the assignment; you make sure the processor guarantees data security; it may only subcontract with your prior authorisation.
• Abroad (Art. 16 and 17): disclosure is permitted to a state whose data protection the Federal Council has recognised as adequate (including the EU, the EEA and the United Kingdom; the United States only for organisations certified under the Swiss-U.S. Data Privacy Framework). Elsewhere, safeguards such as standard contractual clauses, or an exception, are required.
• Penalty (Art. 61): a fine of up to CHF 250,000, on complaint, for a private person who intentionally breaches these rules. It targets natural persons, not the company.

Hosting in Switzerland is still often justified by professional secrecy, a client contract or the wish not to analyse every transfer. Ask where the data and the backups are located, and for the named list of subprocessors. The sovereignty page describes this for Dossivio.

Checklist: a compliant accounting archive in ten points

1. Determine your regime: full accounts or accounts on income and expenditure (Art. 957 CO).
2. Assign each document to a financial year, client by client.
3. Calculate the destruction date: end of the financial year plus 10 years; for VAT, end of the tax period plus 10 years; 20 years for immovable property.
4. Keep the annual report and the audit report printed and signed.
5. Write your work instructions: who receives, scans, approves and archives, with which software (Art. 4 GeBüV).
6. Choose an unalterable medium, or a system that guarantees integrity and time-stamps every record (Art. 9 GeBüV).
7. Log consultations and access, and keep this log as long as the records (Art. 8 GeBüV).
8. Destroy a paper original only after a complete scan has been placed in the archive.
9. Check integrity regularly and document each migration in a record (Art. 10 GeBüV).
10. Sign a data processing agreement that names storage locations, backups and subprocessors (Art. 9 FADP).

One test covers almost everything: export all the documents of a closed financial year, readable, with their access log. If that is laborious, start there.

What Dossivio does for your records

Dossivio Capture receives documents by email, portal, photo or scan, assigns them to the right client and the right financial year, and prepares the entry for your accounting software. This assignment also sets the end of the retention period.

Every document processed is archived with its log: receipt, approvals (who, when, on which version of the document), corrections made to the system's proposal. Hosting, backups and logs are in Switzerland, with providers named in the contract.

Dossivio does not issue a “GeBüV certification”: compliance depends on how your entire accounting is kept and retained. Nor does it replace your archive of record; at the end of the relationship, the log of operations is handed over to you in a usable format (see keeping control). Ask us the questions in the table above: the answers are written into the contract.