Optical and Digital Media for Accounting Records: Current IGJ Regulations and How They Can Benefit Your Company

Are You Still Keeping Legally Certified Paper Books? There Is a Fully Valid Legal Alternative

Many companies continue to operate with legally certified physical accounting books as if they were the only available option. They are not. The Argentine Office of Legal Entities (Inspección General de Justicia, or IGJ) allows companies to replace these books with records maintained through mechanical, magnetic, optical, or other systems. The applicable framework—General Resolution 15/2024, in force since November 1, 2024—substantially updated the rules established by its predecessor, General Resolution 7/2015.

If your company has not made the required periodic filings, or if the volume of transactions has made physical books a genuine operational obstacle, this article explains the current legal framework, the most significant changes compared with the previous regime, and the practical steps you should take to bring your company into compliance or transition to a digital system.

Medios ópticos y digitales

Current Regulatory Framework

The Legal Basis: Article 329 of the Argentine Civil and Commercial Code

The starting point is not the IGJ itself, but the Argentine Civil and Commercial Code. Article 329 establishes that any legal entity may request authorization to replace its mandatory books with records maintained through mechanical, magnetic, or other means, provided that the information is preserved in an unalterable form and can be reproduced legibly.

The IGJ implements this provision through General Resolution 15/2024, Articles 242 and following. Effective November 1, 2024, this resolution entirely replaced General Resolution 7/2015 as the agency’s general regulatory framework.

The Most Significant Changes Compared With the Previous Regime

General Resolution 15/2024 introduced substantial changes in three main areas.

  1. Hash-Based File Preservation
    The most significant technological change is the recognition of files identified by a hash code as a valid means of preserving accounting documentation (Articles 250 and 251).

    The regulation expressly acknowledges two practical problems with traditional optical media, such as CDs and DVDs: they are now difficult to obtain on the market, and current equipment often lacks the drives needed to read them.

    Digital records are identified through cryptographic hashes generated using the tool available on the IGJ website. Each monthly hash must be recorded in the Inventory and Balance Sheet Ledger or in another duly certified ledger authorized for this purpose.

  2. Elimination of the Biennial Filing
    Under General Resolution 7/2015, companies were required to submit a technical update report every two years. General Resolution 15/2024, Article 252, eliminates this biennial filing requirement and retains only the annual filing, reducing the administrative
    burden without eliminating substantive oversight.

  3. Clarification of Document Retention at the Company’s Registered Office
    The regulation expressly clarifies that the obligation to retain documentation at the company’s registered office under Article 325 of the Civil and Commercial Code refers to the physical medium on which the information is stored, such as USB drives or other storage devices, rather than the servers used to process it (Article 244).

This clarification resolves uncertainties for companies operating with cloud-based infrastructure.

Comparison: IGJ General Resolution 7/2015 vs. General Resolution 15/2024

Aspect IGJ General Resolution 7/2015 RG IGJ 15/2024

Legal basis
Article 61 of Law No. 19,550
Article 329 of the Civil and Commercial Code

Initial filing
Public deed, CPA report, flowchart, and chart of accounts
Similar documentation, without the flowchart or chart of accounts (Article 244).

Permitted media
CDs, DVDs, microfilm, and magnetic media.
CDs, DVDs, and digital hashes; microfilm eliminated

CPA report
Report without a prescribed format
Compliance report under FACPCE Technical Resolution 37 (Article 252).

Periodic filing
Annual and biennial
Annual only; biennial filing eliminated (Article 252).

Digital book archiving
Not expressly provided for
Specific framework under Article 251: hash, PDF/ZIP files, and duplicate copies

Retention at registered office
Ambiguous
Expressly refers to the physical storage medium, not the server (Article 244)

Retention at the registered office
Permitted
Eliminated (Article 250, Section 4)

Who Should Consider Migrating to Optical or Digital Media—or Bringing Their Existing Arrangements Into Compliance?

Companies With Overdue Periodic Filings

If your company obtained authorization to use optical media under General Resolution 7/2015—or continues operating under an authorization governed by General Resolution 15/2024—but failed to submit the annual reports prepared by its certified public accountant within 120 days after the fiscal year-end, it is in a noncompliant situation.

The consequences are significant: the company, its directors, and its statutory auditor may be subject to the maximum fines established under Laws No. 19,550 and 22,315.

The regulations provide a mechanism for correcting noncompliance. Once a violation is identified, the company has 90 days from the issuance of the agency’s notice to remedy the situation (Articles 252 and 253).

 


Companies With High Transaction Volumes

Companies recording thousands of transactions each month face practical difficulties with physical books, including the volume of pages, mandatory binding in sections of up to 500 pages, storage requirements, and immediate access for audits.

Migrating to digital media using hash-based identification eliminates these operational obstacles and enables more efficient traceability.

 


Companies That Have Changed Their Name or Registered Office

If your company was authorized to maintain records using optical media and subsequently changed its corporate name or registered address without updating its authorization with the IGJ, it is technically out of compliance.

Article 245, item 6, of General Resolution 15/2024 provides a specific procedure for this situation. The process is simpler than applying for a new authorization and includes updated templates and a professional report.

 


Companies Transferring From Other Jurisdictions to Buenos Aires City

Companies that come under the IGJ’s supervision with authorizations previously issued by provincial regulatory authorities must bring those authorizations into compliance with the IGJ framework.

Article 245, item 5, of General Resolution 15/2024 expressly governs this situation.

What Documentation Is Required for the Initial Authorization Application?

To request authorization from the IGJ to use mechanical, magnetic, or other alternative recording media under Article 244 of General Resolution 15/2024, the company must submit the following documentation.

Corporate Documentation

  • A certified copy of a public deed or a private instrument meeting the requirements of Article 34 of General Resolution 15/2024, containing the resolution adopted by the company’s management body authorizing the application.
    The resolution must specify the legally certified books to be replaced, the recording system to be used, and—if CDs or other optical discs are involved—the company’s commitment to maintaining the ability to read the media throughout the legally required retention period.

Technical and Professional Documentation (Article 244, Item 2)

  • A comprehensive and precise description of the accounting recording system to be used, identifying the records that will be maintained and the books they will replace.
  • A technical report addressing the integrity and unalterability of accounting records, including software, hardware, password policies, and remote connections.
  • A description of the methodology used to generate CDs, DVDs, or hashes and to archive supporting documentation. Storage media must be kept in fire-resistant storage.
  • Blank templates in duplicate, together with one illustrative example showing the company’s legal name, the name of the record or listing, its registered legal address, and the date and page number left undetermined.
  • A statement indicating whether the company’s books are up to date.
  • Precise details of the physical location of the server used.

CPA’s Pre-Filing Report (Article 244, Item 3)

The report must comply with FACPCE Technical Resolution 37, as adopted by the Buenos Aires City Professional Council of Economic Sciences (CPCECABA). It must include verification of the company’s status under Articles 94 and 299 of Law No. 19,550 and compliance with Articles 242, 249, 250, and 252 of General Resolution 15/2024.

The application is deemed approved automatically if the IGJ does not issue a notice identifying objections within 30 business days of submission. This is the tacit approval mechanism established under Article 247 of General Resolution 15/2024.

Mandatory Annual Filing: What the CPA's Report Must Include

Once authorization has been obtained, a filing must be submitted to the IGJ within 120 days after the end of each fiscal year, in accordance with Article 252.

Compliance Report Under FACPCE Technical Resolution 37

The report must include:

  • An exact description of the system used during the fiscal year, identifying any updates implemented and specifying both the original and current versions.
  • A reasoned professional opinion on whether the system authorized by the IGJ corresponds to the system actually in use and whether the authorized system has become obsolete. Any discrepancies must be described, including the date on which each took effect. If the system is obsolete, a technical update proposal must be submitted.
  • The page number in the Inventory and Balance Sheet Ledger where the authorizations and cancellations issued by the agency are recorded.
  • Details of all media used during the period, including listings and records, their names, the period covered, the starting and ending numbers for each medium, and the archiving methodology.
  • Confirmation that any outsourced archiving agreement remains in effect, where applicable.

A written statement from the company’s legal representative must also be submitted, confirming the documentation provided. The representative’s signature and official capacity must be notarized.

If no objections are raised, the IGJ issues a certification that must be recorded in the Inventory and Balance Sheet Ledger.

If noncompliance is identified, the company has 90 days to remedy it. Failure to do so may expose the company, its directors, and its statutory auditor to the maximum fines established under Laws No. 19,550 and 22,315.

Has Your Company Received an IGJ Notice or Request for Information?

During the authorization process or as part of the annual filings, the IGJ may issue notices identifying objections or requesting additional information. In Argentina, these notices are commonly referred to as vistas. They are issued before the agency reaches a decision on the application.

Although the regulation provides for tacit approval after 30 business days under Article 247, the agency may, in practice, raise objections requiring a reasoned technical response within the specified deadline.

An IGJ notice is not a rejection, but it does require immediate attention and a well-supported professional response. The response should address compliance with the regulatory requirements under Articles 242 through 253 of General Resolution 15/2024, the suitability of the described recording system, and any additional documentation needed to resolve the agency’s concerns.

At Fidem Partners, we assist companies in preparing and submitting responses to IGJ notices and formal demands concerning optical and digital media. We coordinate with the reporting CPA to develop the response strategy and assemble the supporting documentation required to obtain authorization or bring the company’s situation into compliance within the applicable deadlines.

Why Working With a Specialized Team Is Essential

The authorization process for alternative accounting media is not simply a matter of completing a form. It involves technical decisions regarding the accounting recording system, the professional responsibility of the CPA issuing the report, and compliance with current accounting standards, particularly FACPCE Technical Resolution 37.

Errors in the system description, submitted templates, or the status of the company’s books may lead to objections that delay approval—or, worse, penalties if the system was already being used without authorization.

At Fidem Partners, we support companies throughout the entire process, including:

  • An initial review of the company’s status with the IGJ.
  • Preparation of the required documentation.
  • Coordination with the reporting CPA.
  • Management of the authorization application.
  • Preparation and submission of annual reports.
  • Responses to IGJ notices and requests for information, when necessary.

In Summary

IGJ General Resolution 15/2024, in force since November 2024, establishes the applicable regulatory framework for accounting records maintained through alternatives to legally certified paper books.

Its most significant changes include recognition of hash-based identification as a valid preservation method, elimination of the biennial filing requirement, simplification of the initial documentation requirements, and clarification of the rules governing document retention at the company’s registered office.

If your company holds an existing authorization but has overdue annual reports, has received an IGJ notice, or is considering replacing legally certified paper books with a digital recording system, now is the time to review and organize its compliance.

At Fidem, we support businesses with growth, financial planning, and strategic structuring.

En Fidem trabajamos acompañando empresas en procesos de crecimiento, planificación financiera y estructuración estratégica.

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