Company accounting documents in Estonia: storage, archiving and business responsibility

In Estonia, accounting is about more than just reporting to the tax authorities. It is a legally significant system of documents that confirms every financial transaction, obligation and management decision of the company. This is why the requirements for storing and archiving accounting documents are strict, formalised and, importantly, applied in practice.

Many entrepreneurs underestimate this issue until they face an audit, a request from the Tax and Customs Board, or the need to restore data from previous years. It is at such moments that it becomes clear that a lack of proper archiving is not a minor violation, but rather a direct risk to the business.

Why is the storage of accounting documents the responsibility of the company and not the accountant?

One of the most common mistakes is assuming that the accountant or accounting firm is responsible for accounting documents. In reality, according to Estonian law, the company itself, i.e. its management board, is fully responsible for the safekeeping of accounting documents.

Even if accounting is completely outsourced, the company must ensure:

• the availability of all primary documents;
• their correct storage;
• the availability of documents for the period specified by law.

While an accountant can keep records, generate reports and assist with archiving, legal responsibility always remains with the company. This is a fundamental point that is particularly important for OÜ owners living outside Estonia to understand.

Which documents are considered accounting documents and must be stored?

In Estonia, the concept of accounting documents is interpreted broadly. These include not only invoices and reports, but also all documentation on which the company’s financial accounting is based.

Such documents include:

1.  primary documents (e.g. invoices, acts, cheques and contracts);
2. bank statements and payment documents;
3.  payroll and personnel documents;
4.  tax returns (including TSD and KMD);
5.  annual reports and explanatory notes;
6. internal calculations and accounting records.

It is important to understand that electronic transactions also require documentary evidence. The absence of a paper cheque does not exempt a company from the obligation to provide proof of a business transaction.

Retention periods for accounting documents in Estonia

Retention periods are clearly specified in legislation and are mandatory requirements, not recommendations.

Main retention periods

Type of document	Retention period
Primary accounting documents	7 years
Accounting registers	7 years
Tax returns	7 years
Payroll documents	7 years
Annual reports	7 years
Constituent documents	Permanently

The storage period begins at the end of the financial year to which the document relates, rather than from its creation date. This important detail is often overlooked.

What is permitted and what to pay attention to when storing electronic documents:

As Estonia is a digital country, electronic storage of accounting documents is completely permissible. Moreover, for most companies, this is the primary and most convenient format.

However, electronic storage is only permitted under certain conditions:

• Documents must be legible throughout their entire storage period and their integrity must be ensured (i.e. there must be no possibility of undetectable changes). Documents must also be available upon request by the tax authorities.
• Chaotic storage of files in emails, instant messaging apps or on the owner’s personal Google Drive is not considered a proper archive. Such “archives” are often not accepted as full evidence in the event of an audit.

Archiving and accessibility of documents during audits

The Estonian Tax and Customs Board has the right to request accounting documents for previous years, and companies are obliged to provide them within a reasonable timeframe. If documents are missing, lost or cannot be recovered, this is automatically considered a violation.

In practice, this means:

• additional questions;
• additional tax assessments;
• fines;
• in complex cases, an audit of all the company’s activities.

Companies that are particularly vulnerable are those that:

1. changed accountants without transferring archives;
2. closed old bank accounts without keeping statements;
3. did not keep records of transactions with non-residents.

Document storage for outsourced accounting

For companies that use outsourced accounting services, it is crucial to clearly define where and how documents are stored. Ideally:

• The company should have access to the archive at any time; documents should be stored centrally; and the archive format should be clear and structured.
• Leaving documents with the former accountant is a direct violation of the company’s interests and poses a serious risk to the owner.

What happens to documents when a company is liquidated?

Even after liquidation, the obligation to store accounting documents does not disappear. Documents must be stored for the period specified by law, and a responsible person must be appointed in advance.

Failure to comply with this requirement can lead to problems after the company has closed, particularly if the tax authorities initiate an audit of past periods.

The following are typical mistakes we see in practice:

•  lack of primary documents for old transactions;
•  discrepancies between documents and accounting data;
•  loss of archives when changing accountants;
•  storage of documents in an unstructured form;
•  lack of backup copies.

All these mistakes have one thing in common: they do not seem critical until the first official request is made.

Why is proper archiving important for your business?

Properly organised storage of accounting documents is not just a formality or bureaucracy. It is a tool for protecting the company, its owners and management.

Having a complete and structured archive allows you to:

• pass tax audits with confidence;
• confirm expenses and deductions;
• defend yourself in disputes;
• maintain control over the business even when changing contractors.

In Estonia, accounting documents form the basis of a company’s financial and legal security. The law clearly defines what needs to be stored, for how long, and in what form. Failure to comply with these requirements will inevitably lead to problems that will always cost more than the timely organisation of accounting and archiving.

For entrepreneurs, this means one simple thing: accounting is not just about reports; it’s also about preserving the memory of the business. If that memory is lost or damaged, it can be extremely difficult to recover.