GoBD Procedure Documentation (Verfahrensdokumentation)

A GoBD procedure documentation, in German Verfahrensdokumentation, is the written description of how an organisation captures, processes, transmits, stores and secures its tax-relevant data and documents. It exists to make the bookkeeping process transparent and verifiable so that a knowledgeable third party, typically a tax auditor, can understand how data flows from a source document into the books and how it is retained. Required as part of GoBD compliance, it is not a single file but a structured set of documents that describes the interplay of people, processes and the underlying ERP and archiving systems.

Purpose

The procedure documentation answers a simple question that auditors ask: how can we trust that the records in this system are complete, correct and unaltered? It does so by describing the controls and processes around the data rather than the data itself. Because the GoBD require that bookkeeping be traceable and verifiable, the documentation provides the map an auditor follows. In practice it also serves the organisation internally, capturing institutional knowledge so that processes survive staff changes and system migrations. Where documentation is missing or out of date, an auditor may question the formal correctness of the bookkeeping as a whole, even if the figures themselves are accurate.

Typical structure

A common structure divides the documentation into several parts:

• A general description that summarises the organisation, its processes and the systems in scope.
• A user documentation explaining how staff operate the relevant applications.
• A technical system documentation covering the software, interfaces and data structures.
• An operating documentation describing access control, backups, archiving and how data integrity is maintained.
• An internal control system describing who checks what, and how errors are detected and corrected.

The goal is that someone unfamiliar with the business could reconstruct the path of any transaction from the description alone.

What it must cover

The documentation should trace the full lifecycle of tax-relevant data: how a document enters the organisation, whether on paper or electronically, how it is captured, indexed and posted, and how it is finally archived. It should explain the role concept and access rights, the use of an audit trail, and the document archiving approach that keeps records unalterable for the retention period. Where scanned documents replace paper originals, the scanning process and its controls must be described so that the digital copy is accepted. Changes to systems and processes should be reflected through versioning, so the documentation always matches the state actually in use during each audited period.

Boundaries and good practice

A procedure documentation is descriptive, not a configuration of the system itself; writing it does not make a non-compliant process compliant, but it does expose gaps. It is specific to German bookkeeping obligations and differs from a software functional specification, which describes what a system should do, or from validation evidence in regulated industries. Good practice is to keep it living: updated when processes change, version-controlled, and retained alongside the records it describes for the full statutory period, so that each historical period can be explained by the documentation that was valid at the time.

Related Topics

• GoBD
• DMS archiving
• Audit trail