Japan's Electronic Bookkeeping Act: Storing Invoices and Receipts, Search Exemptions, and Retention Periods
This guide covers the part of Japan's Electronic Bookkeeping Act that became mandatory in January 2024: keeping electronic transaction data. It explains the tamper-prevention and search requirements, when search is waived, retention periods, the relief for businesses that are not ready, and what Dokolo does.
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Who this is forSole proprietors and companies required to keep books and records for Japanese income tax or corporate tax (businesses that operate and file in Japan). If you live outside Japan, for example in Korea, and send PDFs to Japanese clients, see the first box.
Short answer
- Invoices, receipts, estimates and similar documents exchanged by email or online are "electronic transactions" (電子取引, denshi torihiki). Anyone required to keep records for Japanese income tax or corporate tax must keep that data in electronic form; a printout does not replace it[1][2].
- You need one of four tamper-prevention measures (ensuring authenticity, 真実性の確保) plus a display device and a search function (ensuring readability, 可視性の確保)[3]. Without dedicated software, you can meet the authenticity requirement by adopting and following internal rules (事務処理規程)[4].
- The search function is not required if your sales in the base period are 50 million yen or less, or if you keep printouts organized by date and counterparty. Either way, you must be able to comply when a tax official asks you to download and hand over the data[5].
- Companies generally keep records for 7 years (10 years for fiscal years with a blue-return loss, among others). Sole proprietors keep them for 5 or 7 years depending on the document and the type of return. Invoices that a business taxable for consumption tax (課税事業者) keeps for the input tax credit, and copies of qualified invoices issued, are kept for 7 years[6][7].
- In Dokolo, once a document you saved after signing in is "Delivered," it cannot be changed or deleted, and corrections are made as a revision. Search and bulk download are also available. It has not been confirmed that this alone counts as an authenticity measure, so also adopt internal rules (事務処理規程). The legal duty to keep the data for the required period stays with your business.
On this pageWhat Japan's Electronic Bookkeeping Act requires: keeping electronic transaction data
What Japan's Electronic Bookkeeping Act requires: keeping electronic transaction data
The Electronic Bookkeeping Act (電子帳簿保存法, Denshi Chōbo Hozon Hō, also translated as the Electronic Books Preservation Act) allows tax-related books and records to be kept as data. It also sets the duty and the method for keeping data when transaction information is exchanged electronically[10]. Keeping books or paper records as data is your choice; keeping electronic transaction data is mandatory[10][1].
An electronic transaction is one in which transaction information is exchanged electronically. Transaction information means what is normally written on purchase orders, contracts, delivery slips, receipts, estimates and similar documents[1]. Email bodies, attachments and exchanges through websites all count[1].
The duty covers more than what you receive. You must also keep the data for invoices, receipts and other documents you send, just as you would keep a paper copy[1]. Documents exchanged on paper are not electronic transactions, so you keep them on paper as before[1]. Estimates with simple mistakes, rough drafts made before a formal estimate, and unsolicited estimates do not need to be kept[1]. For how to write estimates, see How to write an estimate in Japan.
For income tax and corporate tax, the option of keeping electronic transaction data as printouts was abolished in the fiscal 2021 tax reform. The temporary relief (宥恕措置, yūjo sochi) that in practice still allowed printouts ended on December 31, 2023[2]. Data that consumption tax law requires you to keep, such as electronic invoices, is treated differently: it may still be kept as printouts for consumption tax purposes[2].
Storage requirements for electronic transaction data: authenticity and readability
When you keep electronic transaction data, you must meet requirements that ensure its authenticity and readability[3]. For authenticity, you must take one of the following four measures[3].
| Measure | What it involves | Watch out for |
|---|---|---|
| 1. Receive data with a timestamp | You exchange data that already carries a timestamp (タイムスタンプ)[3]. | Works only when the sender timestamps the data before sending. |
| 2. Timestamp after receiving | You add a timestamp promptly after receiving the data, or promptly after the normal processing period for that work[3]. | The "after the normal processing period" option requires written procedures covering the steps up to timestamping[3]. |
| 3. Use a system that records corrections and deletions (or does not allow them) | You exchange and keep the data in a system that logs corrections and deletions, or one that does not allow them[3]. | Both the exchange and the storage must happen inside that system[11]. |
| 4. Adopt and follow internal rules | You set, keep on hand and follow internal rules (事務処理規程) that prevent corrections and deletions without a legitimate reason[3]. | The NTA publishes sample rules[3]. This works even without dedicated software[4]. |
You may combine measures depending on how the data arrives[3]. For example, data exchanged inside a system can rely on measure 3, and data received by email on measure 4.
Ensuring readability: viewable on screen and searchable
- System overview document: Required only if you use software you developed in-house[3].
- Viewing equipment: A display, a printer and similar equipment. There are no requirements on their performance or number[3].
- Search function: (1) search by transaction date or another date, transaction amount and counterparty; (2) specify a range for dates and amounts; (3) combine two or more of these items[5].
If you can comply when a tax official asks you to download the data, (2) range search and (3) combined search are not required[5]. You still need to be able to search by the three items in (1). The next section explains when even (1) is waived.
Example: keeping data without dedicated software
The NTA gives this example for a sole proprietor who runs the business with a spouse and receives a PDF invoice by email. Storing it as follows meets the requirements[8].
- Put the date, counterparty and amount in the file name in a consistent pattern (for example, "20261130_SampleCo_110000")[8].
- Store files in folders organized by a set rule, such as by counterparty or by month[8].
- Adopt internal rules (事務処理規程), keep them on hand and follow them[8].
Instead of descriptive file names, you can number the files and track their contents in an index (索引簿), such as a spreadsheet[8]. Backups are not a legal requirement, but the NTA says keeping them is desirable so the data survives the full retention period[7].
When the search requirement is waived: sales of 50 million yen or less, or organized printouts
If either of the following applies and you can comply when a tax official asks you to download the data, the search function requirement is waived entirely[5][4].
- Sales of 50 million yen or less in the base period: For sole proprietors, sales from January 1 to December 31 two years before the year of the transaction; for companies, sales in the fiscal year two years before the fiscal year of the transaction[5].
- Organized printouts: You print the electronic transaction data, organize it by taxable period in date order and by counterparty, and can present or submit it. Sales size does not matter for this route[5].
The sales figure here is not the same as taxable sales for consumption tax (課税売上高). It is measured excluding consumption tax and includes tax-exempt sales, so even a business exempt from consumption tax can exceed 50 million yen[5]. In the year a new business starts and the following year, when there is no base period, the search function is not required (you must still be able to comply with a download request)[5].
If you rely on printouts, print and organize them as you go. If you cannot present or submit them without delay during a tax audit, you may be found not to meet the condition[5].
Retention periods for electronic transaction data: companies, sole proprietors and taxable businesses
Electronic transaction data is kept for the same period as paper books and records under the Income Tax Act, the Corporation Tax Act and other tax laws[7]. Rather than assuming "invoices are kept for 7 years," check which category you fall into.
| Category | Retention period | Counted from |
|---|---|---|
| Companies (blue or white return) | Records such as purchase orders, contracts and receipts: 7 years. 10 years for fiscal years in which a blue-return loss arose, among others[6][7]. | The day after the filing deadline for the final return[7] |
| Sole proprietors (blue return) | Cash and deposit records such as receipts: 7 years (5 years if business and real estate income two years earlier was 3 million yen or less). Other records such as invoices, estimates, contracts and delivery slips: 5 years[7][12]. | March 16 of the year after the year the record was created or received[7] |
| Sole proprietors (white return) | Invoices, delivery slips, shipping documents, receipts and other records created or received for the business: 5 years[7][12]. | Same as above[7] |
| Businesses taxable for consumption tax (課税事業者) and qualified invoice issuers | Invoices kept as a condition for the input tax credit (仕入税額控除), and copies or electronic records of qualified invoices issued: 7 years, regardless of the categories above[7][12]. | — |
If you sent an invoice as a PDF as a qualified invoice issuer (適格請求書発行事業者), you keep that data for 7 years, even as a sole proprietor[7]. For how to write a qualified invoice, see How to write an invoice in Japan.
When you cannot meet the requirements yet: the grace measure
If the district director of the tax office accepts that you have a "reasonable cause" (相当の理由) for not meeting the requirements, such as systems or internal procedures that are not ready, simply keeping the data is enough. The condition is that, during a tax audit, you can comply with both a request to download the data and a request to present or submit printouts of it[2][4].
This grace measure (猶予措置, yūyo sochi) needs no advance application to the tax office. A shortage of staff or funds is accepted as a reason[4]. Deleting the data and keeping only printouts is not allowed even under this measure[2].
Without a reasonable cause or similar grounds, failing to keep the data as required can lead to revocation of blue-return approval. The NTA says it decides by weighing the extent of the violation and other factors[2].
What to check when you set up your storage
- Are you keeping, without deleting, the data for invoices, receipts and estimates exchanged by email or online?
- Have you chosen an authenticity measure? Without dedicated software, have you adopted internal rules and are you following them?
- Can you search by date, amount and counterparty? If not, do you meet the 50-million-yen or printout condition, and can you comply with a download request?
- Do you have storage that will hold the data for the full period that applies to you (company, sole proprietor on a blue or white return, taxable business for consumption tax)?
FAQ
Is it enough to print invoices I receive by email and keep the printouts?
Not for Japanese income tax or corporate tax. Keeping electronic transaction data as printouts is no longer allowed; you keep the data itself[2]. Once the data is stored as required, keeping printouts alongside it for your own convenience is fine[3].
If my sales are 50 million yen or less, do I need to do anything for the Electronic Bookkeeping Act?
Yes. Only the search function is waived, and only if you can comply with a tax official's download request[5]. Keeping the data without deleting it, taking an authenticity measure and having a display and similar equipment are required regardless of sales[4].
Does using Dokolo make me compliant with the Electronic Bookkeeping Act?
Not by itself. Delivered documents cannot be changed or deleted in Dokolo, but measure 3 also requires the data to be exchanged inside the system and the measure to stay in place for the whole retention period[11], and it has not been confirmed that Dokolo's "Send by email" meets this. Adopt and follow internal rules (measure 4) for all your documents, including those created and delivered in Dokolo[3]. Search and bulk download, available after you sign in, support your storage. Deleting your account leaves nothing in Dokolo, so keep your own copy of the data for the legal period.
What happens to documents I delivered if I delete my Dokolo account?
All documents, including delivered documents, the PDFs stored at delivery and the records, are deleted, and nothing remains in Dokolo. If you have delivered documents, you cannot delete the account until you finish an export after your most recent delivery. In Settings, "Export data" → "All types (ZIP)" exports the PDFs as delivered, the list index.csv and the record history.json. If you keep the data yourself after deleting the account, you can still meet the authenticity requirement by adopting and following internal rules[4]. If your sales in the base period are 50 million yen or less and you can comply with a download request, the search function is not required[5].
What about invoices I receive on paper?
Documents received on paper are not electronic transactions, so you keep them on paper[1]. If you also received the same content as data and have decided to treat the paper as the original, keeping the paper is enough. If the data contains information the paper does not, keep both[9].
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令和8年7月Primary source
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