A record retention schedule for Kenyan clients
How long a Kenyan client must keep tax, VAT, company, ownership, NSSF and employment records under each law, in one schedule a firm can share.
By Achekam · · 5 min read · For Accountants & audit firms in Kenya
Clients ask the question in two forms. The cautious ones ask how long they must keep everything. The ones running out of storage ask what they can throw away. Both deserve a better answer than "keep it all for seven years to be safe", because Kenyan law sets different periods under different Acts, counts them from different starting points, and in some cases asks for much longer.
This article brings the main periods together in one schedule a firm can share with clients, explains where each comes from, and shows how Achekam controls disposal of the records it governs.
Tax records: five years under the Tax Procedures Act
Section 23 of the Tax Procedures Act, in the consolidated version on Kenya Law dated 1 September 2026, requires every person to keep the documents a tax law requires. They must be in an official language, kept so that the person's tax liability can be readily ascertained, show amounts in Kenya shillings, and be kept for five years from the end of the reporting period to which they relate.
Two qualifications matter. Documents relating to an amended assessment, or to proceedings started within the five years, must be kept longer. And under section 82, failing without reasonable cause to keep them attracts a penalty of the higher of ten per cent of the tax payable for the period or, where no tax is payable, one hundred thousand shillings. The full section is on Kenya Law's page for the Tax Procedures Act, which also covers PIN registration, electronic tax invoices, assessments and objections.
The tax rule's wider implications are discussed in keeping tax records for five years.
VAT records: five years from the last entry
The VAT Act, as published on Kenya Law in the consolidated version dated 1 July 2026, requires a full and true record of every transaction, in English or Kiswahili and in electronic or other form. The record includes serially numbered copies of tax invoices, credit and debit notes, purchase invoices, customs entries and stock records. It must be kept for five years from the date of the last entry.
Note the starting point. "From the date of the last entry" is not the same as "from the end of the period". For a ledger or register still in use, each new entry moves the start date forward.
Companies Act: seven years for accounting records
Section 630 of the Companies Act, 2015, in the version dated 27 December 2024, requires a company to keep its accounting records at its registered office, open to inspection by its officers, and to preserve them for not less than seven years from the date they were created.
This is the period most clients remember, and for a company it is the longest of the routine periods. More on what counts as accounting records is in accounting records under the Companies Act.
Beneficial ownership: ten years after a person ceases
Under section 93A(7) of the Companies Act, every company must keep records of its beneficial owners' information for at least ten years from the date a person ceases to be a beneficial owner.
That period runs from cessation, not from when the record was made. A founder who sold out last year has their ownership records kept for another ten years from that sale, however long they were an owner before.
Employment and NSSF records
Written particulars of employment. Section 10 of the Employment Act requires the written particulars of employment to be given no later than two months after employment begins, and the employer must keep them for five years after the employment ends. If the employer cannot produce the written contract or particulars in legal proceedings, the burden of proving the terms falls on the employer, which is a strong reason to keep them.
NSSF earnings records. Section 19(7) of the NSSF Act requires a registered employer to keep an up-to-date record of employees' earnings, produce it on demand to an NSSF compliance officer, and retain it for the period the NSSF Board prescribes. The Act caps that period at ten years. Check the Board's current prescription; until confirmed, keeping these records for the full ten years is the safe reading. Inspection rights over employee records are covered in employee records and inspection.
The schedule in one table
| Record | Law | Minimum period | Clock starts |
|---|---|---|---|
| Documents a tax law requires | Tax Procedures Act, section 23 | Five years, longer for amended assessments or proceedings | End of the reporting period |
| VAT transaction records, invoices, notes, stock records | VAT Act, as on Kenya Law | Five years | Date of the last entry |
| Company accounting records | Companies Act, section 630 | Seven years | Date the record was created |
| Beneficial ownership information | Companies Act, section 93A(7) | Ten years | Date the person ceased to be an owner |
| Written particulars of employment | Employment Act, section 10 | Five years | End of the employment |
| Employees' earnings records | NSSF Act, section 19(7) | As the Board prescribes, at most ten years | As prescribed |
Where one document falls under several rows, such as a payroll record that is also a tax record, keep it for the longest period that applies.
Retention and disposal controls in Achekam
Achekam treats disposal as a controlled step for the records it governs. It disposes of a governed record only after its retention period has ended and no legal hold applies, with three different people requesting, reviewing and approving the disposal. The disposal certificate keeps proof that the record existed and was disposed of, but not the content.
There is a limit to know about. Achekam keeps Nigerian and Kenyan till records for South Africa's 7-year retention period until Nigerian and Kenyan retention policies exist; Kenyan periods have not yet been researched for that purpose. For till records, that default is longer than the five-year tax and VAT periods above, but the firm should not read it as the Kenyan rule.
Share the schedule with clients
Send each client the table above with a short covering note, and ask them to tell the firm before destroying any records older than five years. A two-line confirmation now avoids a missing ledger during a tax audit later.
General guidance only, not advice on your own circumstances. Tax and payroll rules change: check the current position with the authority or your adviser.
