Policy Evolution and Implementation Progress of Electronic Accounting Archive Management

The Fifth Plenary Session of the 19th Central Committee of the Communist Party of China proposed that China's economic and social development should accurately grasp the new development stage, thoroughly implement the new development philosophy, and accelerate the building of a new development pattern. In the financial and tax fields, the green development philosophy is largely reflected in the promotion and application of electronic bills and the realization of electronic accounting archives management (Liu Meiling, 2018). Since the first electronic invoice was issued in 2013, the application scope of electronic accounting vouchers in China has continued to expand, and now covers electronic invoices, electronic fiscal bills, electronic passenger tickets, electronic itineraries, electronic special payment books for customs, bank electronic receipts, etc. Along with the emergence of a large number of electronic accounting vouchers, the Ministry of Finance, the National Archives Administration and other authorities put forward specific requirements for the compliance of the financial processing of electronic accounting vouchers, issuing the Measures for the Management of Accounting Archives (hereinafter referred to as the Management Measures) in December 2015, the Notice on Standardizing the Reimbursement, Booking and Archiving of Electronic Accounting Vouchers (Cai Kuai [2020] No. 6, hereinafter referred to as the Notice on Reimbursement, Booking and Archiving) in March 2020, and the Notice on Further Expanding the Pilot Work of Electronic Reimbursement, Booking and Archiving of VAT Electronic Invoices (Dang Ban Fa [2021] No. 1) in February 2021. At the same time, to achieve the overall goal of "managing tax through information," the State Taxation Administration and other departments officially launched the pilot work of VAT electronic special invoices in September 2020, and launched the pilot work of fully digitalized e-invoices (comprehensively digitalized electronic invoices) in Shanghai, Guangzhou and Inner Mongolia in December 2021, aiming to rapidly promote and apply electronic invoices (including VAT electronic ordinary invoices and VAT electronic special invoices) and gradually realize the modernization of tax governance.

Electronic accounting archive management is the final link in the paperless reimbursement, booking, and archiving of electronic accounting vouchers. It is an important prerequisite for realizing paperless reimbursement, booking, and archiving of electronic accounting vouchers, and is also an area currently vigorously promoted and piloted by various regulatory authorities and actively explored and practiced by many enterprises. This article discusses the policy evolution and implementation progress, business logic and typical scenarios, implementation paths, and future prospects of electronic accounting archive management, aiming to clarify the basic issues of electronic accounting archive management and thereby effectively promote the compliant construction of electronic accounting archive systems and the effective implementation of electronic accounting archive management in various units.

(1) Policy Evolution

The management model of electronic accounting archives under the Measures and related regulations has evolved as "single paper-based set — dual paper-electronic sets — single electronic set." The Measures has undergone three versions in 1984, 1998 and 2015, and the defined scope of enterprise accounting archives has continued to expand. In the 1984 version of the Measures, accounting archives referred to professional accounting materials such as accounting vouchers, accounting books and accounting statements, which are important historical records and evidence documenting and reflecting economic business, including accounting voucher category, accounting book category, accounting statement category and other categories; at that time, accounting archives management was a single paper-based set management model. Under the single paper-based set management model, electronic documents also had to be printed as paper documents for archiving. In the 1998 version of the Measures, accounting archives referred to professional accounting materials such as accounting vouchers, accounting books and financial reports, which are important historical records and evidence documenting and reflecting a unit's economic business, including accounting voucher category, accounting book category, financial report category and other categories; at that time, accounting archives management was also a single paper-based set management model. In the 2015 version of the Measures, accounting archives refer to accounting materials in various forms such as text and charts that a unit receives or forms in the course of accounting, which document and reflect the unit's economic business matters and have preservation value, including electronic accounting archives formed, transmitted and stored through computers and other electronic devices, divided into accounting vouchers, accounting books, financial accounting reports and other accounting materials. Article 7 of the Measures states that a unit may use information technology means such as computers and network communications to manage accounting archives, i.e., electronic accounting archives management is permitted; Articles 8 and 9 respectively regulate the conditions that must be met for electronic accounting materials formed internally by a unit and received externally by a unit that fall within the archiving scope to be preserved only in electronic form, i.e., the conditions for paperless archiving. It can be seen that this version of the Measures permits a single electronic set management model for accounting archives, i.e., for native electronic documents that meet the conditions, only the electronic documents may be kept, without the need to print paper documents for archiving. Under the single electronic set management model, electronic documents are complete accounting archives, including native electronic documents (such as PDF-format and OFD-format files of electronic invoices received externally) and electronic documents converted from paper (such as image copies of paper VAT special invoices), while paper documents include only native paper documents (such as native paper contracts, native paper VAT special invoices, etc.).

In practical work, the electronic original vouchers provided by the seller include electronic invoices, electronic fiscal receipts, electronic tickets, electronic itineraries, electronic customs special payment statements, bank electronic receipts, etc. However, not all electronic original vouchers issued by enterprises directly meet the conditions for paperless archiving (for example, electronic receipts provided by some banks do not include electronic signatures). In addition, not all enterprises have the corresponding system conditions and management conditions for paperless archiving of electronic original vouchers received from external sources, and external users of accounting archives (including but not limited to external audit, inspection, financial and accounting supervision, tax inspection and other external supervision and inspection personnel) have relatively limited acceptance and utilization capabilities for electronic accounting archives. Enterprises will naturally tend to choose paper documents for accounting archiving, and some enterprises with the conditions (such as those that have implemented intelligent reimbursement systems and electronic accounting archive systems) will simultaneously use electronic documents for accounting archiving.

To regulate the reimbursement, posting, and archiving of various electronic accounting vouchers, the Notice on Reimbursement, Posting, and Archiving requires that "where a unit uses a paper printout of an electronic accounting voucher as the basis for reimbursement, posting, and archiving, it must simultaneously preserve the electronic accounting voucher from which the paper document was printed," and reiterates the conditions under which a unit may use only electronic accounting vouchers for reimbursement, posting, and archiving. The Notice clarifies that in the process of reimbursement, posting, and archiving, enterprises must preserve the original files of electronic accounting vouchers received from external sources, to ensure their legal effect as accounting vouchers, transaction vouchers, and tax vouchers. This gives rise to the dual paper-electronic management model of accounting archives, namely retaining one set of paper accounting archives and one set of electronic accounting archives, with both sets being complete accounting archives.

(II) Implementation and advancement

China issued its first electronic invoice on June 27, 2013. Nearly 10 years of development and evolution have since followed: in invoice type, from VAT electronic ordinary invoices to VAT electronic special invoices; in format, from PDF to OFD and then to XML; in system deployment, from decentralized deployment by provincial tax authorities to centralized deployment by the State Taxation Administration; and in encryption methods, from the use of tax control devices to the simultaneous use of tax control devices and digital signatures, and then to no tax control device. If electronic invoices are only electronic in the issuance and delivery stages and cannot be electronic in the reimbursement, accounting, and archiving stages, it will be difficult for electronic invoices to truly play important roles at the overall social level, such as saving costs, improving efficiency, preventing risks, and managing tax through information. To this end, the National Development and Reform Commission, the Ministry of Finance, the State Taxation Administration, and the National Archives Administration began organizing comprehensive pilot work on electronic invoices and electronic accounting archives as early as December 2013. The main tasks were to promote the receipt and archival preservation of electronic invoices and to connect electronic invoice systems with accounting systems, aiming to explore feasibility for the issuance of the 2015 version of the Measures for Administration.

In December 2015, as soon as the Management Measures were issued, some advanced enterprises carried out active and effective exploration of electronic accounting archive management. For example, enterprises such as Changhong Electric and Dahua Technology realized electronic single-set management of accounting archives at the first opportunity. To advance enterprise electronic document archiving and electronic archive management and implement electronic single-set archiving management, the National Archives Administration, together with the National Development and Reform Commission, began selecting units to carry out pilot work on enterprise electronic document archiving and electronic archive management in 2016, aiming to form promotable and replicable experience and practices, effectively help enterprise electronic document archiving and electronic archive management land, and effectively boost the rapid development and rapid evolution of China's digital economy. As of October 2021, a total of 47 enterprises in three batches completed pilot work on electronic document archiving and electronic archive management for selected business systems and passed pilot acceptance organized by the National Archives Administration.

At the same time, in order to advance the application and promotion of electronic invoices and support the development of the national digital economy, in accordance with relevant State Council requirements, the National Archives Administration, together with the Ministry of Finance, the Ministry of Commerce, and the State Taxation Administration, began pilot work in 2019 on electronic reimbursement, booking, and archiving of electronic invoices. As of April 2022, a total of 539 enterprises in three batches completed the pilot work on electronic reimbursement, booking, and archiving of electronic invoices and passed acceptance, forming typical experience that can be promoted and replicated, and providing relatively high reference and learning value for other enterprises in solving the problem of electronic reimbursement, booking, and archiving of electronic documents.

(3) Implementation difficulties

In fact, enterprises face the following difficulties in the specific process of carrying out electronic accounting archives management. First, multiple policy documents simultaneously regulate the paperless processing of accounting materials (Enterprise Accounting Informatization Work Standards <Cai Kuai [2013] No. 20, Articles 40 and 41>) and the conditions for paperless archiving (Articles 8 and 9 of the Administrative Measures, Article 3 of the Notice on Reimbursement, Booking, and Archiving), requiring external experts to help comprehensively sort out the conditions for paperless archiving and accurately judge whether enterprises meet the paperless conditions. Second, enterprises generally have relatively complete accounting systems deployed and can smoothly complete booking, but they need to simultaneously implement an intelligent reimbursement system and an electronic accounting archives system to more smoothly realize paperless processing of accounting materials and paperless management of accounting archives, which undoubtedly puts pressure on enterprise financial informatization construction. Third, because users of accounting archives, especially external users such as external audits, inspections, financial and accounting supervision, and tax inspections, have relatively limited acceptance and utilization ability for electronic accounting archives, this undoubtedly dampens the internal motivation of enterprises to implement electronic accounting archives management.

Source: internet

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