FAIA Luxembourg: the audit file the AED can request
FAIA is never filed spontaneously. The obligation is one of capability, which makes it trickier than a deadline: it only surfaces when it is too late to prepare.
What exactly is FAIA?
FAIA, the AED computerised audit file, is a single XML file holding a financial year's accounting data in a prescribed structure. It lets the administration load an entire set of accounts into its analysis tool and run automated tests on it.
The applicable framework is the AED's FAIA version 2.01 recommendation, based on the FAIA_v_2.01_full.xsd schema, which transposes the OECD SAF-T standard for Luxembourg. The obligation to supply accounting data electronically derives from the law of 19 December 2008.
This is not a free-form export. The structure, tag naming and block hierarchy are fixed by the published schema. A non-compliant export is an invalid file, even where the amounts it contains are accurate.
Who must be able to produce a FAIA?
The AED targets taxable persons required to keep proper accounts and operating a computerised accounting system. The file is supplied on request, a possibility open since the close of the 2011 financial year.
The EUR 112,000 turnover threshold is frequently cited as a trigger. That figure in fact corresponds to the annual VAT return periodicity threshold. It is a useful practical indicator, not an automatic exemption rule. Where in doubt, confirmation should be sought from the AED.
The exposed situations look alike. A company whose software is not localised for Luxembourg, a subsidiary running a foreign group ERP without a FAIA module, and a company that changed software mid-year with data split across two systems.
What does a compliant FAIA contain?
The file is organised in successive blocks. Each carries control points that recur constantly in practice.
| Block | Content | Common defect |
|---|---|---|
| Header | Source software, company, period | Incomplete period or unclosed financial year |
| GeneralLedgerAccounts | Ledger accounts and standard mapping | No mapping to the standard chart of accounts |
| Customers and Suppliers | Counterparty records, addresses, VAT numbers | Missing or malformed VAT number |
| TaxTable | Table of VAT rates and codes | Rate used in entries but absent from the table |
| GeneralLedgerEntries | All entries for the financial year | Unbalanced entries or entries outside the period |
| SourceDocuments | Invoices, movements and payments | Empty block although entries reference it |
Why can a technically valid file still cause problems?
Because schema validation tests form only. It confirms that the file follows the expected grammar, not that the accounts are coherent.
The discrepancies that actually prompt questions are different in nature: turnover that does not reconcile with the VAT returns filed, rates applied in entries but missing from the tax table, counterparty accounts used without a matching record, or unexplained breaks in invoice numbering.
FAIA turns a document-based audit into mass analysis. An anomaly that went unnoticed in a twenty-item sample becomes visible across the entire year.
How to prepare before the request arrives
Covering the risk takes very little. Generate the FAIA for the closed financial year and validate it against the schema: if the software offers no such function, the production capability does not exist. Reconcile the file's turnover with the returns filed, line by line rather than in aggregate. Verify the mapping of accounts to the standard chart, the first point the administration examines and the most frequently defective on foreign software.
These three checks take half a day on an SME financial year. Reconstructing accounts to produce a FAIA after receiving an audit notice takes several weeks.
A question about your situation? Let's talk.
Free first call within 24 hours. Dedicated adviser, NDA from first contact.