Mandatory accounting records and management data: how to tell them apart under Articles 2214 and 2215-bis

01

Where the distinction lies

Article 2214 identifies the mandatory accounting records: the journal, the inventory book, and any other records required by the nature and size of the business, together with the orderly retention of letters, telegrams and invoices received and sent. Article 2215-bis does not create a different category of 'management data'; rather, it establishes that those same records, when kept using digital tools, must remain accessible at all times and constitute primary and original information. The distinction useful for controls is therefore between the formal obligation (2214) and the digital method that fulfills it (2215-bis).

02

Related rules worth knowing

• Article 2215 requires progressive numbering and, where special laws require it, stamping or certification of accounting books.
• Article 2216 establishes that the journal must record day by day the operations of the business.
• Article 2217 requires the annual preparation of the inventory, closed with the balance sheet and profit and loss account.
• Article 2220 sets the retention of records and documents received or sent at ten years from the last entry.
• For limited liability companies, Article 2478 adds mandatory corporate books distinct from the records under Article 2214.

03

Verification sequence

Steps

1. List the mandatory records required by Article 2214 for the specific activity of the business.
2. Check whether the records are kept using digital tools under Article 2215-bis and whether they remain accessible at all times.
3. Verify that progressive numbering, and stamping where required, follows Article 2215.
4. Confirm that time-stamping and digital signature are applied at least once a year to digital entries.
5. Verify compliance with the ten-year retention period set out in Article 2220.

04

Hypothetical example

Hypothetical example: a trading business keeps the journal and the inventory book using digital tools, as permitted by Article 2215-bis. Every year it applies time-stamping and digital signature to the entries, thereby fulfilling the numbering and certification obligation applicable to digital record-keeping. Invoices received and sent remain archived together with correspondence, kept for ten years as required by Article 2220. During a review, the business demonstrates that the digital entries constitute primary and original information, not merely incidental management data.

05

Verification checklist

• Are the journal and the inventory book kept and updated under Article 2214?
• Are the other records required by the nature or size of the business identified and kept?
• Are correspondence and invoices received and sent kept in order for each transaction?
• If digital record-keeping is used, are time-stamping and digital signature applied at least once a year?
• Is the ten-year retention period of Article 2220 respected for all records and documents?

06

How software can support this distinction

• A management system can be configured to separate registers that constitute mandatory records from accessory operational data.
• It is useful to assign clear roles to those who enter, verify and time-stamp digital entries, as an operational choice consistent with Article 2215-bis.
• You can ask your software provider to track the date of each entry and keep records accessible at all times.
• Retention for the period required by law can be set as a retention policy within the document management system.

07

Quick clarifications

• The main distinction is between the formal obligation (Art. 2214) and the digital method of record-keeping (Art. 2215-bis).
• Small businesses are excluded from the record-keeping obligations under this framework.
• Digital record-keeping does not remove the ten-year retention obligation set out in Article 2220.

08

Next step

Steps

1. Map your business's mandatory records under Article 2214.
2. Check with your advisor whether digital record-keeping complies with Article 2215-bis.
3. Set up periodic monitoring of the ten-year retention period under Article 2220.