The Canada Revenue Agency (CRA) revised its GST/HST memorandum on electronic records in September 2026. The update replaces the 2005 memorandum and reflects amendments to the Excise Tax Act, including provisions about books and records and information that may be specified for inspection.

That does not mean every Canadian business suddenly has a new retention period. The memo explains the GST/HST requirements for electronic records. It is a timely reason, however, to check whether your bookkeeping system can preserve, retrieve and provide the records your business is responsible for keeping.

What the CRA says about electronic business records

The CRA treats electronic record-keeping broadly: it includes business systems that create, process, store, maintain or provide access to records, including accounting software and online systems. A business required to keep GST/HST records electronically must retain them in an electronically readable format for six years after the end of the year to which they relate. Keeping a paper copy does not remove this electronic-record requirement.

The CRA also says a usable copy must be accessible in a format that can be processed and analysed with CRA software. “We can still log in to the old app” is not a complete continuity plan if an account closes, software changes or data cannot be exported in a usable form.

The responsibility stays with the business when accounting, bookkeeping, hosting or storage is handled by a third party. A software provider or bookkeeper can support the process, but outsourcing the work does not transfer the business’s record-keeping responsibilities.

A seven-point electronic-records checkup

1. List the systems that hold financial records

Write down where you create or keep invoices, bills, bank transactions, sales-tax records, payroll records, receipts, contracts and supporting documents. Include accounting software, point-of-sale tools, online stores, payment platforms, payroll systems, shared drives and outside service providers. Note who can access each system and who can retrieve a complete copy.

2. Keep evidence connected to the transaction

For an important transaction, can you move from the bookkeeping entry to the invoice, receipt, bill, bank line or other supporting record? Keep a consistent naming and filing practice, and make sure attachments remain available when a transaction is reviewed or exported.

3. Confirm readability and export options

Ask your provider how to export transaction details and supporting information in a readable, commonly used format. Test an export rather than relying on a sales page or a checkbox in settings. The CRA’s memo says businesses should ensure the system can export required information into a commonly used, non-proprietary format.

4. Test backup restoration

Confirm how often backups are made, where they are kept, who is responsible, and how long they are retained. Then test that a backup can actually be restored and read. A backup that cannot be opened when needed is not a useful recovery plan.

5. Preserve the audit trail

Check whether completed transactions can be changed or deleted without a trace. The CRA describes controls for safeguarding transaction accuracy and integrity, including controls against accidental or intentional editing or deletion, and adequate journal entries documenting changes. For a change, the history should make clear who changed it, when, what changed and why.

6. Document your record-keeping process

Keep a short, current description of the systems and procedures you use: how transactions enter the books, how reports are produced, how files are retained and archived, how backups work, and how authorized people can retrieve the records. The CRA’s updated memo says business-system documentation must be maintained and provided upon request. The detail should fit the complexity of your systems.

7. Plan software changes before they happen

Before switching bookkeeping platforms, closing an account or changing a service provider, decide how you will retain prior-period data, supporting documents, system documentation and the ability to retrieve readable records. Preserve a chronology of material system and file-format changes. Do not assume that an export or migration will include everything your business may need.

How long should you keep electronic records?

For the GST/HST electronic records covered by Memorandum 15-2, the stated period is six years after the end of the year to which the records relate, and electronic records must remain readable. Other record types, special circumstances, objections or appeals, and specific CRA demands can affect what must be retained and for how long. Check the rule that applies to each record type before deleting anything; ask the CRA or a qualified Canadian tax professional when your situation is not straightforward.

Does using cloud bookkeeping software make a business CRA-compliant?

No software label can guarantee compliance for every business. The CRA says the person required to keep the records remains responsible even when a third party provides the system or bookkeeping service. You need to understand your own retention, access, export, backup and documentation arrangements—and verify them in practice.

Awditify Books V7 includes a Files page that brings together organization files and files attached to invoices, estimates, bills, bank lines and journal entries. Its Audit log lists changes, shows before-and-after details where available, and can export the filtered view as CSV. These tools can help keep documents and activity history easier to find; they do not replace your retention policy, tested backups or review of your legal obligations. Read the Awditify bookkeeping features or book a demo to see whether the workflow fits your business.

Start with one test

Choose one recent GST/HST transaction and one older transaction. Trace each from the ledger to its supporting documents, export the available record, and confirm that an authorized person could read it. Then test a backup and write down who owns each step. That small exercise can expose missing attachments, unclear responsibilities or a migration risk before they matter.

This article summarizes public CRA guidance for general information. It is not tax or legal advice. Requirements and exceptions depend on your business and records; consult the CRA or a qualified Canadian tax professional for advice about your situation.

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