E-ledger certification: deadlines and the annual election

Under the e-ledger regime the journal and general ledger are kept electronically, and a summary of each period's ledger is uploaded to the tax authority as a certificate file. The certificate proves the ledger existed on that date and has not been changed since. The ledger itself stays with the taxpayer; what goes to the authority is the certificate.

Monthly or quarterly?

Taxpayers elect whether to upload certificates monthly or in advance-tax quarters. The election is notified at the start of the accounting period and cannot be changed during the year. Where no notification is made, monthly upload applies.

Consequences of late upload

• A special irregularity penalty may arise, assessed under the provisions on failure to certify ledgers.
• The evidential force of the ledger becomes contestable. During an audit, an uncertified period can be raised against the validity of the records.
• Waiting once a delay is noticed makes matters worse; the upload should be made as soon as possible and the circumstances recorded in writing.

Points to watch

• No entries can be added to a period once its certificate is uploaded, so late documents must be processed beforehand.
• The validity of the financial seal or electronic signature must be monitored; discovering an expired seal on upload day means missing the deadline.
• Where an integrator is used, responsibility for the upload still rests with the taxpayer; a system delay is not an excuse.
• The approval status of the uploaded certificate must be checked; sending and approval are not the same.
• Ledger files and certificates must be retained by the taxpayer for the statutory retention period.