Documentation and audit trail
For copies of identification documents, Art. 25.2 Ley 10/2010 expressly permits storage on optical, magnetic or electronic media — provided these guarantee integrity, correct readability, tamper protection and proper retrievability. The same principle broadly applies to the rest of the AML documentation, even though Art. 25.2 literally refers only to identification records.
The statute therefore prescribes neither specific software nor a particular file format. What it does prescribe is the standard the archiving system must meet:
Purely digital record-keeping is therefore possible. The decisive question is not paper versus digital, but whether the system can show that a record is authentic, legible and unaltered.
Legal basis: Ley 10/2010, Art. 25.2
Practical tip: A folder on a shared drive does not meet the tamper-protection requirement merely because nobody changes anything. The question is not whether something was altered, but whether an alteration would be detectable.
AI-assisted tools were used in preparing these FAQs; the content was subsequently reviewed and approved by the Doxario editorial team. They reflect the general state of the law as at the review date shown and do not constitute individual legal or tax advice. To assess your own case — particularly where complex structures are involved (offshore companies, trusts, foundations, communities of heirs) or where the new EU rules leave room for doubt — we recommend consulting a lawyer specialising in Spanish anti-money-laundering law and, on tax questions, a tax adviser. Doxario is a deal management and compliance platform for estate agents in Spain, operated by Blue Pepper S.L.; we therefore have an economic interest in the solutions described in these FAQs. Doxario accepts no liability for decisions taken solely on the basis of these FAQs.
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