Against a backdrop of the gradual digitalization of corporate accounting systems, tax administrations
are increasingly developing adapted methods to ensure the reliability and traceability of data
submitted by taxpayers during tax audits. In line with this approach, the Cameroonian legislature had
introduced, into the General Tax code, an obligation for taxpayers whose accounts are maintained
using computerised systems to submit, at the commencement of audit proceedings and in an
exploitable dematerialised format, a copy of the File of Accounting Entries (FAE) covering the
audited period. Although this measure reflected a notable step towards modernising audit procedures,
it gradually proved insufficient and, to a certain extent, ineffective, thereby undermining the overall
efficiency of tax audits. With a view to remedying the identified shortcomings and strengthening the
coercive mechanisms of tax control, the Cameroonian fiscal legislature has, through the 2026 Finance
Law, undertaken a restructuring of the sanction’s framework governing non-compliance with
computerised accounting requirements. This was achieved, on one hand, through the rewriting of
Article M 19 of the General Tax Code (GTC), which reinforces the taxpayer’s obligations with
respect to the FAE, and on the other hand, through the introduction of Article M 30 a into the GTC,
which organises the sanctioning of violations occurring after the submission of said file. Such an
innovation undoubtedly reflects a determination to enhance the effectiveness of tax audits. This article
highlights, first, the reinforcement of the requirement for authenticity and accuracy of accounting
entries (I), and second, the extension of ex officio (arbitrary) assessment to violations relating to
computerised accounting (II), as introduced by the 2026 Finance Law.
I. The Reinforcement of the Requirement for Authenticity and Accuracy of Accounting Entries
Through the amendment of Article M 19 of the GTC, the Cameroonian fiscal legislature has placed
particular emphasis on dematerialised accounting within the framework of tax audits, by reinforcing
the requirement for authenticity and accuracy of accounting entries. First, paragraph 2 of the said
article as supplemented by the 2026 Finance Law, clarifies that the failure to submit the file of
accounting entries (FAE) at the commencement of audit proceedings now constitutes a hindrance to a
tax audit. In this perspective, any refusal or omission to submit it to the tax authorities triggers direct
opposition to the audit process. Furthermore, it is apparent from the new wording of paragraph 2 that
taxpayers are henceforth prohibited from modifying their accounts for the period under audit from the
moment the FAE is handed over to the tax controllers. This prohibition plainly intended, inter alia, to
guarantee the integrity of accounting data, to ensure the traceability of accounting entries, to prevent
fraud, and to ensure the reliability of the audit process. Finally, taxpayers are now required to retain,
for a minimum period of ten (10) years, a technical audit journal (logs). This journal must be non-
alterable and must be capable of tracing every creation, modification, or deletion of accounting
entries, complete with timestamps and user identification. It should be noted that in the event of a duly
recorded discrepancy, as established in an official report, between the accounting documents and the
FAE submitted at the outset of on-site proceedings, the tax authority may reject the accounts on
grounds of unreliability. The last sentence of paragraph 2 of Article 19 of the GTC further specifies
that the burden of proving the authenticity and accuracy of the accounting entries rests with the
taxpayer, who must demonstrate that the data submitted is consistent with the actual accounts and has
not been tampered with. This reversal of the burden of proof in audit matters reflects a manifest intent
to deter taxpayers from altering their accounting entries after submission of the FAE; conduct that
could otherwise expose them to ex officio assessment.
II. The Extension of Ex Officio/Arbitrary Assessment to Violations Relating to Computerised
Accounting
Where it is established that a taxpayer has modified their accounts following the submission of the
FAE, or where discrepancies are found to exist between that file and the accounting documents, the
tax administration may reject the accounts and, consequently, proceed with an ex officio assessment.
It should be noted, however, that this sanction applies to two principal types of violation, each subject to a specific adversarial procedure. The first violation consists in the falsification of accounting
entries. According to the 2026 Finance Law Circular, this encompasses any modification, deletion, or
falsification of accounting entries or supporting documents occurring after the submission of the FAE.
Once established, the tax administration draws up an official report of findings specifying the nature,
extent, and period of the modifications identified. This report is notified to the taxpayer, who then has
eight (8) days to submit written observations and supporting justifications. The second category of
breach relates to obstruction of the computerised audit. Under the 2026 Finance Law circular, this is
constituted by the refusal to grant auditing officers access to the accounting entries files or to the data
necessary for the audit and examination of audit trails. In such a case, the administration issues the
taxpayer with a formal notice, by any means capable of establishing the date of receipt, inviting them
to grant the required access within a period of eight (8) days. The refusal is recorded by an official
certificate of non-compliance, drawn up on an adversarial basis or, failing that, endorsed with a note
of the taxpayer’s refusal to sign. Where, upon the expiry of the procedural deadlines referred to above
in relating to falsification of accounting entries and obstruction of computerized audit, the taxpayer
has failed to produce documentary evidence attesting to the integrity and accuracy of the accounting
data, the tax administration is then entitled to definitively reject the accounts and proceed with an ex
officio assessment based on available information, in application of Article M 30 of the GTC.
Conclusively, the reforms introduced by the 2026 Finance Law mark a decisive shift in the
Cameroonian tax legislature approach to computerised accounting, moving from a largely declaratory
framework to a genuinely coercive one. By reinforcing the obligations attached to the File of
Accounting Entries (FAE), reversing the burden of proof in favour of the tax administration, and
extending ex officio taxation to cover falsification of accounts and obstruction of computerised audits,
the legislature has created a robust and structured deterrent against fiscal fraud. Crucially, this
heightened rigour is tempered by a formal adversarial procedure that preserves the fundamental rights
of taxpayers, reflecting the hallmark of a maturing fiscal legal order. These reforms ultimately place
Cameroon in greater alignment with international best practices in tax administration and constitute a
necessary step towards a more transparent and effective system of fiscal control.
Author: Yannick Josué Ndoum, Senior Consultant; Supervisor: Abert Désiré Zang, Managing
Partner