Accounting Firms

Compliance for accounting & tax advisory firms

Accounting-record retention is chained to the tax-audit limitation period, and that changes what "enough backup" actually means.

Legislation

Your obligations

Record retention, Law 5104/2024, Article 13(2)

The retention floor is five (5) years from the end of the tax year, but it's chained to the audit-limitation period (Article 37) or to a case becoming final. Article 37 sets a 5-year base limitation (+1 year in specific cases), reaching 10 years only exceptionally (non-filing, new evidence). A longer period may be appropriate where an Article 37 exception applies or professional advice justifies it.

myDATA, AADE Decision Α.1138/2020 (amended Α.1156/2023)

Mandatory real-time transmission of invoice/expense data. myDATA keeps what you reported to the tax authority, not your actual files, your accounting software's database, or client folders.

Mandatory B2B e-invoicing, Law 5222/2025

Phase A (turnover >€1M): from 2 March 2026. Phase B (everyone): from 1 October 2026.

Professional secrecy, ΟΕΕ Code of Conduct

Licensed accountants carry a confidentiality duty over the client data they handle (Decision 57088/2013, Article 8).

Security of processing, GDPR Article 32

Explicitly requires "the ability to restore the availability and access to personal data in a timely manner", i.e. a documented backup/restore capability.

Recovery design

The file set that must come back

An accounting firm does not recover from one document; it recovers when ledgers, source records, and submissions can be tied together again.

The active tax period

The accounting application's database or supported export, source invoices, and mappings needed to reconcile with myDATA should share a coherent recovery point.

Payroll with restricted access

Payroll files, contracts, and employee records need separate permissions and controlled restores because they should not be visible to every user in the firm.

The audit trail

Returns, submission receipts, correspondence, and correction versions should be recoverable together so the firm can evidence what was filed, when, and from which records.

Enforcement

Recent enforcement

Two cases that show where oversight in your sector is focused:

PwC Business Solutions, €150,000

Fined for inadequate security and backup measures (GDPR Articles 5(1)(f) and 32), the sector's reference case.

Hellenic DPA Decision 48/2023

Reprimand of an accountant for processing an heir's data without a lawful basis.

Practical answers

Questions from accounting firms

Does myDATA replace an accounting firm's backup?

No. myDATA contains information transmitted to AADE, not necessarily the accounting application's database, source invoices, mappings, payroll files, or client correspondence. The recovery process must cover the agreed local file set and, where required, the application or a supported export from it.

What should an accounting-data restore test cover?

The test should follow a real work scenario: restore selected source records, exports, or an in-scope database; verify that they open with the required software; and confirm that restricted folders such as payroll remain available only to authorised users.

Must every accounting record be retained for ten years?

There is no single ten-year rule for every record and case. Retention should be set by data category, taking account of the ordinary tax period, any applicable exceptions or open matters, and advice from the firm's tax or legal adviser. ArvaSafe operates the schedule agreed in writing.

The Fix

How ArvaSafe covers this

  • Backup of files and folders on the agreed workstations; applications and databases require separate assessment
  • The retention period is defined in writing for each data category in the Order Form, based on the customer's instructions and legal or professional assessment
  • The selected storage region and relevant providers are recorded in the Order Form and DPA
  • Documentation limited to the technical and organisational measures ArvaSafe applies to the specific service

Contact

Ready to sleep easier?

Two simple ways to get started. Pick whichever feels right, both reach me directly.

Option 1, Fastest

Book a 20-min call

Pick a time that suits you. I'll review your backup setup, answer service questions, and explain what ArvaSafe can address, no obligation.

  • Free 20-minute check
  • I review your current backup and technical evidence
  • You leave with a clear next step

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Option 2, Send details

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