must I keep my evidence documents digitally or can it be on paper

Paper is allowed, digital is more convenient

The regulation does not prescribe a fixed format: keeping documents on paper is permitted, just as a digital version is permitted. What matters is that the documents exist, are complete and can be shown on request — not in what format this happens. Anyone who prefers to work with folders rather than a digital archive will not immediately run into a problem.

In practice, a digital archive is considerably more workable, and this has little to do with the legal text and much to do with everything that must be kept. This includes geodata of parcels, supply contracts, origin declarations and communication with suppliers about the DDS number that belongs to each batch. Such documents must remain traceable and linkable to a specific product stream for a certain period, and this is considerably more difficult to organize with a paper folder per supplier or per country than with a digital file in which everything is searchable. In an inspection, what matters most is whether someone can quickly and completely show what is being requested; a bulging file that is not in order will not help, even if paper is permitted in itself.

What this is based on

Regulation (EU) 2023/1115 sets requirements for what information an operator must keep and for how long, but contains no provision that mandates digital storage or excludes paper storage; which documents exactly these are is described on the page about the documents that must be collected and retained, and the retention period that applies is explained on the page about the five-year retention obligation.