The decision this page covers is which rows deserve a place in the new system. An expense spreadsheet mixes company card charges, money owed to employees, recurring suppliers, and notes nobody can explain anymore. Treating all of it as data to load is how a new platform starts life with guessed owners and phantom balances.

Sort every record into one of three lists

Import. Active employees with entity, department, and manager. Recurring suppliers that have a named owner today. The ledger dimensions finance actually posts to. Every open amount owed to or by an employee: unpaid claims, outstanding advances, and repayments due, each with an approved figure. Refunds you still expect to receive.

Quarantine. Rows with no owner, a business purpose someone would have to guess, an unknown payment status, a duplicate supplier spelling, or a link to a departed employee. Each quarantined row gets a person responsible and a decision date. It stays out of the new system until resolved, and it stays visible in the archived spreadsheet in the meantime.

Close in the old process. Shared-card numbers, merchant profiles stored with a shared card, unused checks, and approval threads living in email. Cancel or replace the shared card and give each spender a named or virtual card in the new platform; never enter a shared card into the new system as if it belonged to one person. Closed historical transactions also stay where they are, in a read-only archive with a retention date.

The employee list deserves the most care. Personal money is the item most easily lost in a migration that celebrates the card feed. Send each employee a statement of what the company owes them and where that claim now lives before anyone switches off the old workflow.

Keep the original evidence

The receipts and spreadsheet behind past reimbursements are the record, not the imported copy. If you reimburse under an accountable plan, IRS Publication 463 describes the substantiation those claims rely on; a migrated row does not recreate that evidence, so retain the originals for as long as your retention policy requires. Moving data cannot settle the tax treatment of any past payment.

Retiring shared credentials is the cheapest control in the project, and it is ordinary security practice: once each spender has a named card, nobody needs the old number, so cancel it and record the date. The FTC Safeguards Rule is narrower than that. It requires covered financial institutions to run an information-security program and oversee their service providers, so it matters here only if your company is covered and the migration moves customer information into the new platform; in that case, the new vendor belongs in that program's oversight.

Rehearse the import on an awkward sample

Pull a small extract that includes a shared-card charge, an unpaid personal claim, a missing receipt, two spellings of one supplier, a pending refund, and an expense from someone who has left. Apply the sorting rules, load the import list into a test environment, and check that every quarantined row is accounted for. If a reviewer outside the team cannot trace an opening balance back to its source without asking how it was transformed, fix the rule and run the extract again. Spend Management Guide has not run a buyer migration; this sample has to come from your own records.

When and how to switch over, including transactions that arrive during the change, belongs to the rollout decision in the implementation plan.

When to migrate differently, or not yet

A full history import earns its cost when an auditor or lender expects multi-year detail in the new system, when a chargeback or supplier dispute needs its trail there, or when budget owners must compare prior years inside the new reports. Even then, import history as closed, read-only records, separate from the opening set.

A company where only the founders spend, each on their own card, with no employee reimbursements, should keep the spreadsheet and the accounting software's expense features. Revisit when the first non-founder starts spending company money or the first shared card appears.

Verdict

Open the new system with records you can defend: named people, owned suppliers, current dimensions, and every employee balance. Quarantine what is ambiguous, retire shared credentials, and archive the rest. A smaller opening set that finance trusts is worth more than a complete one nobody can explain at the first close.

Traceable evidence

Sources for this decision

2 sources
  1. regulatorPublication 463, Travel, Gift, and Car ExpensesInternal Revenue Service · checked Aug 5, 2026 · supports: Federal substantiation, accountable-plan, travel, gift and vehicle-expense rules within Publication 463; it does not determine deductibility or reimbursement treatment for specific facts.
    Open source ↗
  2. regulatorSafeguards RuleFederal Trade Commission · checked Aug 5, 2026 · supports: FTC Safeguards Rule scope and information-security program requirements for covered financial institutions; it does not certify a spend platform or buyer configuration.
    Open source ↗