General Requirements for Books and Records

GST/HST memorandum 15-1
September 2026

This version replaces the one dated June 2005. This memorandum has been updated to include amendments to the Excise Tax Act regarding keeping books and records, including the information that may be required for inspection and the issuing of electronic notices by the Minister of National Revenue.

Table of Contents

• General information
• Record-keeping requirements
  • Records to be kept
  • Invoicing requirements
  • Information for input tax credit purposes
  • Electronic records and imaging
  • Inadequate records
• Retention of records
  • Permission for earlier disposal
  • Records held by third-party
  • Place of retention
• Records related to objection or appeal
• Demand by Minister
• Access to records
  • Obligation to give access to an authorized person
  • Requirement to provide documents or information
  • Authorization to make copies of documents
  • Foreign-based information or document
• Penalties

General information

1. The purpose of keeping proper books and records is to ensure that any tax liability or entitlement to an input tax credit (ITC) or a rebate can be determined or supported by documentary evidence.

2. The word record is defined in subsection 123(1) to include "an account, an agreement, a book, a chart or table, a diagram, a form, an image, an invoice, a letter, a map, a memorandum, a plan, a return, a statement, a telegram, a voucher, and any other thing containing information, whether in writing or in any other form". In this memorandum, reference is made to document and information. While the term information is not defined in the Excise Tax Act (ETA), the term document is defined in subsection 123(1) to include "money, a security and a record".

Record-keeping requirements

3. Under section 286, the following persons are required to maintain all records that are necessary to enable the determination of the person's liabilities and obligations under the GST/HST or the amount of any rebate or refund to which the person is entitled:

• every person who carries on a business or is engaged in a commercial activity in Canada
• every person who is required to file a GST/HST return
• every person who makes an application for a rebate or refund

4. The Minister of National Revenue (the Minister) may specify the form a record is to take and any information the record must contain. Unless otherwise authorized by the Minister, a record must be kept in Canada in English or in French.

Records to be kept

5. Records may be kept in various formats, including any of the following:

• traditional records including source documents produced and retained in paper or electronic format
• records retained in an electronically readable format that can be related back to the source documents and that are supported by a system capable of producing accessible and usable copies
• supporting documents such as an accountant's working papers, whether in writing or in any other format that assist in the determination of the GST/HST obligations and entitlements

6. All records and source documents that originate in paper format must be retained in such format except where an acceptable imaging or microfilming program is in place. Paper format also includes paper source documents that are entered into an electronic record keeping system.

7. Where records are maintained electronically, registrants are encouraged to follow best practices for digital record keeping, including the use of secure cloud-based accounting systems, regular data backups, and ensuring that records are stored in formats compatible with Canada Revenue Agency (CRA) audit tools. For more detailed guidance, refer to GST/HST Memorandum 15-2, Electronic Records.

Invoicing requirements

8. In order for the books and records to meet the standards required, certain information must be included in invoices, receipts, or written agreements. Under subsection 223(1), the ETA imposes certain requirements with respect to the disclosure of the GST/HST on invoices, receipts, or in written agreements providing recipients with sufficient information that enables them to determine their liability for tax on taxable supplies.

9. A registrant who makes taxable supplies (other than zero-rated supplies) of property or services, and is required to collect the GST/HST, must indicate either of the following to the recipient, either in prescribed manner or on receipts, invoices, or in written agreements:

• the consideration paid or payable by the recipient and the GST/HST payable in respect of the supply in a manner that clearly indicates the amount of GST/HST
• the amount paid or payable includes the GST/HST payable in respect of the supply

10. Subsection 223(1.1) further requires that if the registrant indicates the GST/HST on invoices, receipts, or in written agreements, the total amount of the GST/HST payable or the total of the rates at which the GST/HST is payable must be indicated on the invoices, receipts or in agreements.

11. The prescribed manner of disclosure is set out in the Disclosure of Tax (GST/HST) Regulations. The prescribed manner is to give clearly visible notice (for example, a posted sign) to the recipient of a taxable supply at the place where the supply is made.

12. Under subsection 223(2) a person who makes a taxable supply to a recipient must provide, upon request from the recipient, sufficient information, in writing, to support a claim by the recipient for an ITC or rebate. There is no requirement that the information needed to support a claim for an ITC be contained in a single document. For example, invoices, receipts, and written agreements may need to be provided in order to satisfy the documentary requirements needed to claim an ITC.

Information for input tax credit purposes

13. Subsection 169(4) outlines the requirements for documentation that a registrant must obtain and keep in support of an ITC claim. While these requirements do not impose any restrictions on the format of the documents issued or maintained, they do require that certain information be contained in or on those documents or records. Details concerning the information that registrants are required to provide to their customers on request in order for those customers to support their ITC claims is available in GST/HST Memorandum 8-4, Documentary Requirements for Claiming Input Tax Credits.

Electronic records and imaging

14. A person who uses computerized systems to generate books and records must retain the electronic records in an electronically readable format. Electronically readable format means information presented in a format supported by a system capable of producing accessible and usable copies. An electronic copy must be kept, even when a hard copy is also retained.

15. Every person should ensure that proper backup procedures are implemented at all times so that records or electronic data files are backed up or copied to an electronic medium that will be accessible at a later date. If any machine-sensible records or electronic data files required to be maintained are lost, destroyed, or damaged, the person must report this situation to the CRA and recreate the files within a reasonable period of time. Steps will need to be taken to recreate the lost or destroyed files. This might involve using backup copies, if available, or recreating the records from source documents. The recreated files must be in an accessible and usable format for CRA officials. For further information, refer to Your responsibilities and the requirements associated with records the law requires you to keep, or call the CRA at 1‑800‑959‑5525.

16. For more information on electronic records and imaging refer to GST/HST Memorandum 15-2.

Inadequate records

17. Under subsection 286(2), if a person fails to keep adequate records, the Minister may specify the records that the person is required to keep. In this instance, the CRA will ordinarily request a written agreement that the records be maintained as required. Within a reasonable period of time, usually not less than a month, the CRA will follow up the request by letter or visit to make sure there is compliance with the agreement.

Retention of records

18. Every person required to keep records for GST/HST purposes is required under subsection 286(3) to retain them for a period of six years after the end of the year to which they relate.

19. Under subsection 286(3.1), every person required to keep records, who does so electronically, is required to retain the records in an electronically readable format for the retention period discussed in paragraph 18.

20. The retention period for records is generally determined by the last year when a record may be required for purposes of the ETA, and not the year when the transaction occurred and the record was created. For instance, records supporting the purchase of a vehicle used by a registrant individual less than exclusively (90%) in commercial activities, the individual is required to claim their ITCs based on the capital cost allowance (CCA) claimed each year for the vehicle. These records need to be maintained until the day that is six years from the end of the year to which they relate. If the particular purchase transaction took place on April 15, 2015, and the CCA claims occur until 2022, the corresponding records are required to be retained until December 31, 2028.

Permission for earlier disposal

21. Under subsection 286(6), a person required to keep records may dispose of these records before the end of the normal retention period if written permission for their disposal is given by the Minister. To obtain such permission, the person must apply in writing to the director of the nearest CRA Tax Services Office. The request must be signed by the person or an authorized representative, and must contain the following information:

• specific identification of the books, records, or other documents to be destroyed
• type of documents such as electronic records stored on tapes or disks
• the years for which the request for disposal of records applies
• indication of any outstanding appeal, objection, or reference
• details of any special circumstances which would justify destruction of the books and records at an earlier time than is normally permitted
• any other pertinent information

22. Permission for early disposal of GST/HST books and records applies only to the GST/HST records. Such permission does not extend to other laws and authorities that require the retention of records.

23. Subsection 286(3.2) authorizes the Minister, on such terms and conditions as are acceptable to the Minister, to exempt a person or class of persons from the requirement in subsection 286(3.1) to retain their records in an electronically readable format.

Records held by third-party

24. A person who keeps records, whether in writing or any other form, is not relieved of any of the record keeping, readability, retention, and access responsibilities because the person contracts out the record-keeping function to a third party such as a bookkeeper, accountant, Internet transaction manager, application service provider, cloud storage provider, or Internet service provider, through a time share, service bureau, or other such arrangements. The person must ensure that the requirements continue to be met in the event of third-party changes such as software or hardware conversions and upgrades, bankruptcy or migration to or from a third party. The person is responsible for keeping the records and for providing access to a person who is authorized by the Minister (authorized person), such as a CRA auditor or other officer.

Place of retention

25. Books and records must be kept at the person's place of business or residence in Canada or another place designated by the Minister, and must, upon request, be made available to an authorized person for inspection at all reasonable times. Books and records kept outside Canada and accessed electronically from Canada are not considered to be books and records kept in Canada. Access to electronic records means that the person must provide an acceptable copy of the electronic records in an electronically readable and usable format to an authorized person so that they can process the electronic records on CRA equipment.

26. All retained records must be clearly labelled and stored in a secure environment in Canada. However, authorization to maintain records outside Canada may be granted, subject to such terms and conditions as the Minister may specify in writing. These terms and conditions, which also apply to records maintained in Canada (including electronic records), specify that records stored outside Canada are to be made available to any authorized person for audit purposes at all reasonable times in accordance with the relevant provisions of the ETA. The person must also agree to cover all the travel and living expenses for the authorized person conducting an on-site audit outside of Canada in either of the following situations:

• the records are not made available when and as required to an authorized person at a designated Tax Services Office in Canada
• the records provided are inaccurate or incomplete

27. Authorization to maintain records outside Canada may be obtained by submitting a written request to the CRA Office responsible for the person's area. For non-residents of Canada, the address of the appropriate office may be found at Make a non-resident registration and security enquiry. The request must include both of the following:

• the reasons for keeping the books and records outside Canada
• an address where the books and records can be examined

28. Normally back-up copies of electronic records are stored at a site other than the business location for security and precautionary purposes in case of fire, flood, theft, or other cause. The CRA encourages this business practice and recommends that these backup copies be maintained at a location within Canada.

29. It is the person's responsibility to produce the records for inspection regardless of where these records are located.

30. Persons with businesses that operate via the Internet and that are hosted on a server located outside Canada should be aware of their responsibility to maintain their records within Canada. Persons with Internet-based businesses have the same responsibilities for record retention as those conducting business through other channels.

Records related to objection or appeal

31. Under subsection 286(4), every record that pertains to the subject matter of a notice of objection, appeal, or reference thereto must be retained until the objection, appeal, or reference thereto and any appeal therefrom is finally disposed of.

Demand by Minister

32. Where the Minister is of the opinion that it is necessary for the administration of the GST/HST, subsection 286(5) authorizes the Minister to, by a demand served personally or by registered or certified mail, require any person who is required to keep records under section 286 to retain those records for such additional period of time as is specified in the demand.

Access to records

Obligation to give access to an authorized person

33. Under subsection 288(1), an authorized person may, at all reasonable times, for any purpose related to the administration or enforcement of the GST/HST

• (a) inspect, audit or examine any documents, property or processes of a person that may be relevant in determining the obligations or entitlements of that or any other person under the GST/HST;
• (b) enter any premises or place where any business or commercial activity is carried on, where any property is kept, where anything is done in connection with any business or commercial activity or where any documents are or should be kept;
• (c) require any person to give the authorized person all reasonable assistance, to answer all proper questions relating to the administration and enforcement of the GST/HST and
  • (i) to attend with the authorized person at a place designated by the authorized person, or by video-conference or by another form of electronic communication, and to answer the questions orally, and
  • (ii) to answer the questions in writing, in any form specified by the authorized person; and
• (d) require the person or any other person to give the authorized person all reasonable assistance with anything the authorized person is authorized to do under the GST/HST.

34. Subsection 288(2) provides that where any premises or place referred to in subsection 288(1) is a dwelling-house, an authorized person may not enter that dwelling-house without the consent of the occupant, except under the authority of a warrant issued under subsection 288(3).

35. Section 287 defines a dwelling-house to mean "the whole or any part of a building or structure that is kept or occupied as a permanent or temporary residence, and includes

• (a) a building within the curtilage of a dwelling-house that is connected to it by a doorway or by a covered and enclosed passageway, and
• (b) a unit that is designed to be mobile and to be used as a permanent or temporary residence and that is being used as such a residence".

Requirement to provide documents or information

36. Under subsection 289(1), the Minister may give notice to a person requiring that the person provide any information, including a return, or document for any purpose relating to the administration or enforcement of a listed international agreement (as defined in subsection 123(1) of the ETA) or relating to the administration or enforcement of the GST/HST.

37. Under subsection 289(1.1), "A notice referred to in subsection (1) may be

• (a) served personally;
• (b) sent by registered or certified mail; or
• (c) sent electronically to a bank or credit union that has provided written consent to receive notices under subsection (1) electronically."

38. Under subsection 289(2), the provision of information or documents relating to one or more unnamed persons can be required from a third party only if the Minister first obtains the authorization of a judge under subsection 289(3).

39. Subsection 289(3) provides that, "A judge of the Federal Court may, on application by the Minister and subject to any conditions that the judge considers appropriate, authorize the Minister to impose on a third party a requirement under subsection (1) relating to an unnamed person or more than one unnamed person (in this subsection referred to as the "group") if the judge is satisfied by information on oath that

• (a) the person or group is ascertainable; and
• (b) the requirement is made to verify compliance by the person or persons in the group with any duty or obligation under [Part IX]."

Authorization to make copies of documents

40. Under subsection 291(1), where any document is seized, inspected, audited, examined, or provided under any of sections 276 and 288 to 290, the person who seizes, inspects, audits, or examines it or another officer of the CRA may make or cause to be made one or more copies of the document. This copy, certified as such by the Minister or an authorized person, has the same probative force as the original document. In the case of electronic records, this person may print out such electronic documents and the printout as well as the original electronic document will be considered evidence of the nature and content of the original document and will have the same probative force as the original document.

Foreign-based information or document

41. Under subsection 292(2) the Minister may, by notice served or sent in accordance with subsection 292(3.1), require a person resident in Canada or a non-resident person that carries on business in Canada to provide any foreign-based information or document. It is an offence not to produce any foreign-based information as and when required.

42. For the purposes of section 292 the term foreign-based information or document is defined under subsection 292(1) to mean "any information or document that is available or located outside Canada and that may be relevant to the administration or enforcement of this Part, including the collection of any amount payable or remittable under this Part by any person".

43. Subsection 292(3.1) indicates that "A notice referred to in subsection (2) may be

• (a) served personally;
• (b) sent by registered or certified mail; or
• (c) sent electronically to a bank or credit union that has provided written consent to receive notices under subsection (2) electronically."

44. Under subsection 292(4), if a person is served or sent a notice of a requirement under subsection 292(2), the person may, within 90 days after the day on which the notice is served or sent, apply to a judge for a review of the requirement.

45. Under subsection 292(6), a requirement to provide information or a document shall not be considered to be unreasonable because the information or document is under the control of or available to a non-resident person that is not controlled by the person on which the notice of the requirement is served, or to which that notice is sent, if that person is related to the non-resident person.

Penalties

46. The ETA provides for various penalties where a person fails to maintain adequate records or provide information as required. For more information on penalties refer to Chapter 16, Assessment and Penalties, of the GST/HST Memorandum Series.