Why you need a document retention policy
In a Swiss SME, invoices, bank statements, VAT records and payslips pile up quickly. Without explicit rules, the risk is twofold: keeping too little—with penalties during an audit, VAT inspection or tax assessment—or archiving everything indefinitely, with storage costs, data protection risks and difficulty finding what you actually need.
The Code of Obligations (CO) sets a uniform ten-year period for accounts and supporting documents. The Federal Tax Administration (FTA) and VAT law require you to be able to justify returns and calculations for comparable periods. An internal retention policy turns these duties into operational procedures: who archives what, in which format, where and for how long, including secure destruction when the period expires.
This guide summarises the federal requirements relevant to SMEs, offers a practical document map and explains how to align digital archiving and accounting software such as Accountex with day-to-day compliance.
Legal framework: CO, VAT and FTA
Retention obligations for financial documents derive mainly from company law and federal tax law. Cantons and social insurance schemes may prescribe longer periods for individual categories (for example HR documents); the table below summarises the most common bases for routine SME management.
| Area | Legal basis | Indicative period | Operational note |
|---|---|---|---|
| Accounts and supporting documents | Art. 958f CO | 10 years from closure of the financial year | Books, entries, relevant accounting correspondence, vouchers |
| VAT documentation | Art. 70 VAT Act (LIVA/MWSTG) | Until absolute limitation (10 years from end of tax period) | Issued and received invoices, registers, returns, consideration; 20 years for documents on taxation of capital goods and own consumption of real estate (art. 70 para. 3 VAT Act) |
| Direct federal tax (profits) | Art. 126 para. 3 DBG (LIFD) | 10 years (aligned with accounts) | Documents supporting financial statements and tax return; retain calculations and attachments |
| Withholding tax | Art. 126 para. 3 DBG (LIFD); cantonal practice | 10 years | Forms, certificates, exemption or correction decisions; payslips and employer documentation |
| Electronic archiving | Art. 958f para. 3 CO; GeBüV | For the full retention period | Readability, integrity, accessibility and traceability over time; the management report and audit report remain in written and signed form (art. 958f para. 2 CO) |
| Corporate documents | CO (statutory books, resolutions) | 10 years (many records permanent) | Articles of association, general meeting and board minutes: distinguish legal retention from historical archive |
The CO ten-year period runs from the end of the financial year to which the document relates, not from the issue date of an individual invoice. In practice it is advisable to archive by “tax year / financial year” rather than by isolated month, so you can easily calculate the expiry of the obligation for the whole batch.
What to retain: map for SMEs
An effective policy classifies documents by category, owner and medium (paper or digital). The goal is not to keep every email, but everything that allows you to reconstruct transactions, taxes and payroll.
Receivables and payables
Customer and supplier invoices, credit notes, orders linked to billing, contracts with recurring billing clauses, bank statements and reconciliations, payment documentation (bank transfers, QR invoices, card receipts).
In digital accounting, attaching or linking the voucher to the entry avoids duplicates and simplifies exports for audit or VAT inspection.
Accounting and reporting
General journal and ledger (export or year-end printout), trial balances, approved balance sheets and income statements, management report attachments, documentation of adjustments and reversals with rationale.
For companies with mandatory or voluntary audit, also retain significant correspondence with auditors relating to material adjustments.
VAT and taxes
VAT registers, periodic and annual returns, tax payment receipts, deduction calculations and corrections, documentation for exports, foreign supplies or exemptions where applicable.
The FTA may require proof of consistency between general ledger and VAT registers: avoid “gaps” between software and scattered paper.
HR and social security
Payslips, payroll registers, OASI/IV/EO and occupational pension (2nd pillar) declarations, salary certificates, documentation on allowances and tax-relevant reimbursed expenses.
The FADP and cantonal periods also apply here: records are often kept beyond ten years for disputes or insurance; company policy may set different expiry dates for HR than for pure accounting.
Compliant digital archiving
Art. 958f para. 3 CO allows books and documents to be kept in electronic form if they remain readable for the full retention period and correspondence with the underlying facts is ensured; the GeBüV specifies requirements for mutable media (integrity, timestamps, logs). “Saving a PDF” is not enough: you must ensure the file is identifiable, protected from unauthorised alteration and recoverable after software or cloud provider changes.
For SMEs, a pragmatic approach combines a central repository (DMS or document area in the accounting system), regular backups with restore tests, naming conventions by financial year and document type, and an audit trail for deletions. E-invoices should be treated as digital originals where the law permits, avoiding printing out of habit when electronic archiving is robust.
- Integrity:hashing or versioning, limited modification rights, separation between final archive and working drafts.
- Readability:open or widely supported formats (PDF/A for long-term documents); migration plan before a format becomes obsolete.
- Access:who may view tax and payroll documents; logging access to sensitive data.
- Destruction:secure deletion or anonymisation when the obligation expires, unless other constraints apply (disputes, insurance periods).
Drafting internal policy in five steps
A one- or two-page document, approved by management, is often enough to align admin, sales teams and external advisers.
- Inventory: list flows (sales, purchases, bank, payroll, VAT) and where each voucher originates today.
- Rules by category: minimum legal period, any extended retention, owner and storage location.
- Digital workflow: capture (scan, certified email, bank import), link to accounting entry, year-end closure of the financial-year archive.
- Controls: semi-annual sample review (random invoice → entry → archive); backup verification.
- Training: brief onboarding for new staff on what not to delete (a WhatsApp photo of a receipt does not replace structured archiving).
Risks, controls and the role of accounting software
Premature destruction of documents can lead to fines, official tax estimates or difficulties in a VAT inspection. Conversely, having no policy leads to chaotic shared folders where nobody dares delete anything, increasing exposure in the event of a data breach.
SME-focused accounting software such as Accountex supports compliance when every transaction has a linked document, VAT periods can be closed with traceability and exports by financial year feed the DMS or auditor without manual reconstruction. The retention policy does not replace mandatory books, but defines how to keep evidence beyond simple bookkeeping.
When ceasing operations, merging or transferring ownership, planning archive handover (including ten years of accounting history) avoids gaps that surface only years later, when a departing partner or buyer requests documentation for an assessment.
Quick compliance checklist
| Question | Objective |
|---|---|
| Does every significant accounting entry have an archived voucher? | Meet art. 958f CO and facilitate audit |
| Are batches organised by financial year with a calculated destruction date? | Avoid premature or indefinite deletion |
| Are VAT registers and returns kept for ten years and consistent with the accounts? | Reduce risk in FTA inspection |
| Are digital archive backup and restore tested at least once a year? | Ensure readability over time |
| Do HR and management know distinct periods for payroll and the FADP? | Align retention and privacy |
Updating the policy when software, organisation or tax obligations change (for example new VAT methods or e-invoicing requirements) keeps the SME ready for inspections without last-minute emergencies.