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Document archiving explained legally

We guide you through the legal jungle, uncover marketing half-knowledge, and explain why PaperOffice is your perfect document base for all legal requirements.

Procedure documentation

You need this: Procedure documentation according to GoBD

Sample procedural documentation for replacement scanning, issued by the Federal Chamber of Tax Advisors (BStBK) in cooperation with the German Tax Advisors Association e.V. (DStV)


Proof obligation

What does a procedural documentation say?

That everything runs smoothly for you.

Using the procedural documentation, companies can prove that their IT-supported accounting as well as the storage of data and documents conform to the principles of regularity defined in GoBD.

That you can provide any document on request

The goal is to make accounting and archived documents in the company understandable and verifiable in a reasonable time for an expert, for example as part of an audit.

For this purpose, it is described in detail how receipts and documents are captured, received, digitized, processed, output, and stored. The taxable user of the IT solution used, or the entrepreneur themselves, is responsible for creating a procedural documentation.

Process documentation

What should a process documentation consider?

For every IT system, a clearly structured procedural documentation should be available. Content, structure, and results of the IT process should be fully and convincingly apparent.
To verify traceability, a comprehensive and up-to-date procedure documentation is required, which documents all system and technological changes in terms of content and time without gaps.

The procedural documentation should also demonstrate how electronic documents are captured, processed, issued, and stored.
A description of the data backup process integrated into PaperOffice for local database application is also an important part of procedural documentation.

A procedural documentation describes the intended organizational and technical process. From the generation of the information through indexing, processing and storage to the unique retrieval.


on the safe side

The solution: PaperOffice compliant with GOBD for document storage

PaperOffice complies with all software requirements according to GOBD through certification and verification, by adhering to all required standards.

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PRINCIPLE OF TRACEABILITY AND VERIFIABILITY (GOBD CHAPTER 3.1)

According to the GoBD, the taxpayer is obligated to secure the IT system against loss (e.g. unavailability) and protect it against unauthorized inputs and alterations.


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PRINCIPLES OF TRUTH, CLARITY AND CONTINUOUS RECORD KEEPING WITH INDIVIDUAL TOPICS (GOBD CHAPTER 3.2)

The DMS server components are generally subject to the same security requirements as other IT components. Relevant topics are monitoring and data security.

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COMPLETENESS (GOBD- CHAPTER 3.2.1)

Each document subject to retention must be recorded separately and with all its components (completeness and continuity).


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ACCURACY (GOBD-CHAPTER 3.2.2)

Following the principle of accuracy, the DMS must ensure that the documents and data to be archived have the required degree of compliance with the original (in terms of appearance or content).

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ORDER (GOBD CHAPTER 3.2.4)

The principles of proper accounting are considered to be consistently fulfilled when the compliance with the criteria of regularity can be ensured throughout the entire retention period when using a DMS.


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IMMUTABILITY (GOBD CHAPTER 3.2.5)

The GoBD stipulates that the data processing procedure used must be designed in such a way that all information that has been input into the processing process may not be suppressed, overwritten, deleted, changed or falsified without being marked (GoBD Chapter 3.1; Paragraph 58-60).

Frequently Asked Questions
Who helps with process documentation?

Who has absolute confidence in their own processes will probably not need a tax advisor. However, we recommend getting help from a tax advisor in advance or at least when creating the procedural documentation. From our own experience, it is always advisable and helpful to speak openly with the examining authority, as ultimately the examiner himself decides despite all regulations and standards.

Who approves the process documentation?

Beware of marketing half-knowledge: Financial authorities do not accept certificates of any kind from any issuer! In case of need, only the submission of the procedural documentation according to GoBD counts and whether everything is really correct is decided by the reviewing authority, for example your tax auditors or tax office.

Why is PaperOffice not enough?

Briefly explained: If you have, for example, an invoice securely archived in PaperOffice, even though the invoice may have been manipulated or altered BEFORE scanning, you are saving it revision-proof, but the overall process itself is not revision-proof and therefore does not comply with GoBD.

Can I throw away original documents?

Documents with legal relevance, such as contracts, still need to be kept in their original form. To put it simply: The tax office accepts electronic receipts, but in case of a dispute, the court only accepts originals. This is because only on original documents can a signature be verified for authenticity. We recommend never disposing of originals.

Why can I delete PaperOffice documents?

There is also process documentation available for this. Because it is technically not possible to completely exclude deletion as long as the data is stored with you. Ultimately, you can delete the data record directly from the database yourself. Or remove the hard drive. Or dispose of the server. Or blow up the building.

How do I find technical DMS recommendations?

Bitkom has developed a checklist according to the latest version of GOBD from 28.11.2019 regarding document management systems, which you can find here.

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