Häufig gestellte Fragen
Is GoBD procedure documentation mandatory for every company?
The obligation applies in principle to every business that records, processes or archives tax-relevant data using a data-processing system, and it derives from the BMF (German Federal Ministry of Finance) circular on the GoBD of 28 November 2019 (margin number 151 et seq.). It applies regardless of size or industry, meaning it also covers small businesses and sole proprietorships as soon as they use accounting software, digital receipts or electronic archives. The required scope, however, scales with size and complexity: a small craft business needs much leaner documentation than a corporate group with a distributed IT landscape. There is no blanket minimum page count; what matters is a comprehensible description of the procedure as it is actually practised.
What happens without procedure documentation in a tax audit?
In the worst case, the tax authorities can reject the accounting as formally non-compliant and estimate the tax bases; in addition, there is a risk of the input VAT deduction being disallowed. However, the GoBD explicitly qualify this in margin number 155: missing or inadequate documentation is only a formal deficiency of material weight if it actually impairs the traceability and verifiability of the accounting. In practice, missing documentation therefore often serves auditors as a gateway for deeper enquiries and increases the risk of additional estimated assessments. The exact impact depends heavily on the industry, company size and degree of customization of the specific ERP setup.
Who writes the procedure documentation within the company?
There is no fixed statutory responsibility, so a clear internal assignment of responsibility is recommended, with the tax or finance department frequently taking the lead and IT and the business departments contributing. Ideally, a person or team with a simultaneous understanding of the tax requirements and the systems in use should be in charge. External support from tax advisors or specialised GoBD consultants is common but does not replace the company's own description of the processes as they are actually practised. Templates from chambers and associations provide a proven structure but must be adapted to the actual workflows.
What content must GoBD procedure documentation include?
In practice, a structure of four parts has become established along the GoBD requirements: a general description of the company, its processes and system landscape, user documentation covering operation, input screens and approval steps, technical system documentation covering software, interfaces and databases, and operational documentation covering data backup, access protection and contingency planning. The aim is that a knowledgeable third party can trace the path of a business transaction from the source document to the posting and audit-proof archiving within a reasonable time. Individual adaptations such as customizing, in-house developments and automated posting logic require particularly thorough documentation because they change the audited procedure. The specific level of detail depends on the complexity of the respective business.
How often must the procedure documentation be updated and how long must it be retained?
The GoBD require the documentation to always reflect the currently valid state of the procedure, which is why it is not a one-off document but must be updated with every relevant process or system change. Triggers include system migrations, updates involving process changes or new interfaces, and changes must remain traceable via versioned filing with date and responsible person. A file created once and then forgotten does not meet the requirement. The procedure documentation is also generally subject to the ten-year retention period under Section 147 AO (German Fiscal Code), so earlier, since superseded versions should also be retainable for the relevant period; it keeps its ten-year period even though a shortened eight-year period has applied to pure accounting records since 2025.
What role does the ERP system play in the procedure documentation?
The ERP system is usually the central system in which tax-relevant data originates and converges, making it a core component of the procedure documentation. Among the things to be described are the document flow from capture to posting, the interfaces to upstream and downstream systems and audit-proof filing, for example via a connected DMS archive. While a technical audit trail automatically logs individual changes, the procedure documentation organisationally contextualises and explains the overall procedure. The most common gap arises when an ERP system is adapted over the years but the associated documentation is not maintained along with it.