Advancing Digital Recordkeeping in Bahrain
On 28th December 2025, Ministerial Decision No. (113) of 2025 concerning the Exemption of Institutions, Companies, and Banks that use Electronic Computers for their Accounting from Maintaining Paper-based Commercial books (the “Ministerial Decision”) was published in the Official Gazette. Effectively, the Ministerial Decision recognizes electronic accounting records as legally valid. This is seen as follows:
(a) Under Article 1 of the Ministerial Decision, institutions, companies and banks that rely on computers in their accounting systems in Bahrain are exempted from maintaining paper commercial books.
The above exemption underscores the effectiveness and widespread usage of electronic systems by businesses for their accounting framework in an increasingly digital age. Furthermore, it reduces the burden businesses may face as a result of administrative costs or related expenses in maintaining physical accounting records.
(b) Article 2 of the Ministerial Decision adds to the above by recognizing the usage of electronic commercial books as having the same legal evidentiary value as paper commercial books. By placing such electronic records on the same evidentiary standing of their physical counterparts, it eases any issues that businesses may face for the purposes of general legal and regulatory compliance or filings before court, as may be necessary.
However, Article 2 of the Ministerial Decision is not absolute. As a prerequisite, the following procedures and rules are to be applied to safeguard the accuracy and integrity of the data as recorded by computer systems:
- The electronic accounting system needs to incorporate sufficient technical protections to preserve the integrity of the stored data and prevent any modification, deletion or alteration that may occur thereto.
- Furthermore, data must also be entered into the electronic systems on a regular basis and within the legally mandated time frames.
Collectively, Articles 1 and 2 of the Ministerial Decision achieve a middle ground between corporate flexibility and responsibility. While the Ministerial Decision grants greater flexibility to businesses in respect of accounting records, at the same time, such businesses must also ensure adequate technological standards are in place and remain compliant with legal requirements.
In conclusion, the exemption from businesses that rely on electronic based accounting systems, and the legal recognition of such systems represents a progressive and modernized outlook towards company recordkeeping and compliance. As such, the Ministerial Decision enhances ease of doing business under clear safeguards as stated above and strengthens government oversight, which overall generates a more efficient regulatory environment.










