In Germany, procedural documentation has been mandatory since 2015 for all companies that process and store relevant tax documents digitally. In order to avoid legal consequences, companies should ensure that their own procedural documentation always complies with the applicable legal provisions. It is subject to various basic requirements that are intended to guarantee that the procedural documentation provides a clear insight into a company's tax-relevant IT-supported business processes. It is of central importance that it transparently shows how all receipts, especially electronic ones, are recorded, processed and stored in the company.
The documentation must always provide precise answers to various questions, including:
- How are receipts and documents recorded, processed and stored in the company?
- Which IT systems are used in the company?
- How is it ensured that receipts and data are protected against falsification or loss?
- Who has access to the receipts and data?
- What internal controls ensure compliance with the procedures defined in the company?
It is also essential that the processes described in the procedural documentation actually correspond to reality. Any changes to the system or working methods must be fully documented and the procedural documentation itself must be versioned, with all versions being retained. Basically, this means that the procedural documentation should not only exist on paper, but must be actively implemented in the company's operations for the entire retention period.
What is procedural documentation according to GoBD?
The procedural documentation in accordance with the GoBD is a documented representation of the business processes, in particular the electronic accounting systems used in a company. In Germany, the GoBD are decisive for proper accounting and data processing and apply to all companies.
Here are some key elements that should be included in the GoBD procedural documentation:
- General information
- Name and address of the company
- Description of the object of the company - Organization and responsibilities
- Organizational chart of the company
- Responsibilities for accounting and data processing - Description of the IT systems
- Description of the hardware and software used, including versions
- Details of the network structure - Data security and access control
- Measures for securing and monitoring IT systems
- Access authorizations and protocols - Data access and availability
- Measures to ensure the availability of data
- Processes for data recovery in an emergency - Logging of business transactions
- Logging of changes to accounting data
- Time stamp and traceability of business transactions - Document management
- Guidelines for document management and administration
- Procedures for electronic invoicing and archiving - Audit security and audit obligations
- Measures for audit security of accounting data
- Regulations for audits and reviews - Documentation of interfaces
- Description of interfaces to other systems or external service providers
- Regulations on data transmission and processing
The GoBD procedural documentation should ensure that accounting and data processing are transparent, traceable and audit-proof. Companies are obliged to regularly review their procedural documentation and adapt it in the event of changes in order to maintain compliance with the GoBD. A solid understanding of GoBD and the correct implementation of procedural documentation are crucial in order to meet legal requirements and avoid problems in the event of an audit.
GoBD process documentation and the legal basis
The legal basis for procedural documentation is derived from various laws and regulations. Here are some relevant aspects:
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GoBD (principles of proper accounting and data access): The GoBD contain requirements for the proper keeping and storage of books, records and documents in electronic form. They require companies to document their IT systems and the associated processes in a comprehensible manner.
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AO (German Fiscal Code): The Fiscal Code regulates taxation in Germany. It sets out various principles for the obligation to record and document business transactions.
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Section 146 AO (recording obligation): According to Section 146 AO, companies are obliged to record their business transactions in accordance with the principles of proper accounting. The procedural documentation can help to fulfill these requirements.
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Section 147 AO (retention of documents): The AO stipulates that books, records, and other documents must be kept for six or ten years. Clear and comprehensible procedural documentation can support the retention obligation.
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Tax audits: During tax audits by the tax office or other authorities, companies may be asked to submit their procedural documentation to prove proper accounting and data security.
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Section 238 HGB (German Commercial Code) (generally accepted accounting principles): Similar to the GoBD, the HGB also sets out the principles of proper accounting in Section 238. This includes the proper documentation and storage of books, records and receipts. Here, procedural documentation can serve to document the implementation of these principles.
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Section 257 HGB (content of the balance sheet): Section 257 HGB specifies which information must be included in the balance sheet and income statement. Clear procedural documentation can help to ensure that the bookkeeping is designed in such a way that all the necessary information for the preparation of these reports is available.
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Section 261 HGB (retention of documents): Similar to the corresponding provisions in the German Fiscal Code, Section 261 HGB obliges companies to retain trading books, inventories, opening balance sheets, annual financial statements and management reports for a certain period of time.
These aforementioned provisions refer to the general requirements for bookkeeping and record retention. The exact structure of the procedural documentation can vary depending on the industry, company size and individual circumstances. It is therefore advisable to
seek legal advice from a tax consultant, lawyer or service provider specializing in procedural documentation in case of doubt. The procedural documentation can be seen as an instrument that serves to fulfill the requirements of the HGB, particularly with regard to proper accounting, the transparency of business processes and the documentation of procedures. In practice, it is common for companies to design their procedural documentation in such a way that it meets the requirements of both the GoBD and the HGB.
Practical tip: With our
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What is the aim of procedural documentation?
The purpose of procedural documentation is to ensure that accounting and the management of receipts in companies are traceable and verifiable. This means that the documentation must provide a knowledgeable third party, be it a tax auditor or an auditor, with a clear insight into the relevant processes within a reasonable period of time. Carefully prepared procedural documentation therefore plays a central role in ensuring the legality of a company's financial processes.
What components does GoBD process documentation contain?
As the backbone of a company's organizational processes and data processing, comprehensive and precise GoBD process documentation not only enables the efficient design of processes, but also compliance with legal regulations and the provision of transparency for external auditors. In this context, the essential components of GoBD process documentation become an indispensable tool for companies of all sizes. The key components are considered in detail below:
General description
Thegeneral description includes basic information about the company, its structure and its business purpose. This creates the organizational basis that serves as the framework for the GoBD procedure documentation. In addition, all tax-relevant processes are named in order to create a comprehensive and precise basis for the procedural documentation.
User documentation
Theuser documentation focuses on the operational level and describes in detail how employees implement the processes defined in the procedural documentation, such as document management, contract management, incoming invoice processing and digital mail delivery. It plays a crucial role in training new employees and ensuring consistent workflows.
Technicalsystem documentation
Thiscomponent focuses on the technical aspects of GoBD procedural documentation, including the hardware and software used. It provides insights into the IT infrastructure and enables a clear presentation of electronic data processing.
Operational documentation
Theoperational documentation describes the organizational measures to ensure smooth IT operations and, in this context, IT security. This includes data backup, change management, but also records of maintenance work, emergency plans and other operational measures that ensure the continuity of processes.
Internalcontrol system
Theinternal control system defines mechanisms that ensure that the processes described in the procedural documentation comply with internal guidelines, compliance specifications and legal requirements. This component serves to ensure compliance and traceability.
Is procedural documentation mandatory?
In principle, all companies that are required to keep accounts under German tax law must prepare procedural documentation in accordance with GoBD. In particular, this includes corporations, partnerships and sole proprietorships that carry out commercial or freelance activities and exceed certain turnover and profit limits. It is important to note that the obligation to create procedural documentation exists regardless of the size of the company. Both small and large companies must guarantee that their bookkeeping complies with the GoBD and be able to provide corresponding procedural documentation. Nowadays, modern companies and their immediate environment use a variety of data processing systems. Therefore, every IT-supported business process that is important from a tax perspective requires the creation of procedural documentation in accordance with paragraph 151 of the GoBD.
What types of procedural documentation are there?
Companies are confronted with a wide variety of business processes and requirements in their day-to-day operations. Process documentation plays a key role in ensuring a clear structure, legal compliance and efficient workflows. Here we take a closer look at three specific types of procedural documentation.
Procedural documentation for replacement scanning
This type of procedural documentation deals with the digital replacement of paper-based documents. It specifies how the replacement scanning of documents takes place, what technical requirements are placed on the scanners and how the integrity of the scanned data is guaranteed. It also covers aspects such as the storage of original receipts and protection against unauthorized access.
Process documentation for document storage
This documentation focuses on the storage and retention of physical and digital receipts. It describes how receipts are organized, secured and stored in order to comply with legal requirements. It also deals with issues relating to access authorizations, archiving duration and audit security.
Procedural documentation for proper cash management
This focuses on the proper management of cash registers. This procedural documentation is particularly important for companies with cash transactions. It describes how income and expenses are correctly recorded and documented in order to meet tax requirements. This includes the logging of cash movements, protection against manipulation and regular cash audits.
How do you create procedural documentation?
The creation of procedural documentation requires a systematic approach and the consideration of various aspects. It should also be noted that procedural documentation is not a fixed document that is drawn up once. In the context of digital change, processes are continuously modified in order to be able to react flexibly to market changes. As soon as processes in the company change, it is necessary to revise the procedural documentation accordingly. Here are some steps and important considerations to bear in mind when creating GoBD procedural documentation:
Here is an overview of all the important documents for the electronic personnel file:
- Identify the relevant processes: Determine the business-critical processes that need to be mapped in the procedural documentation. These can be financial accounting, HR management, IT processes or specific projects, for example.
- Process description: Describe each identified process in detail. Define clear steps, responsibilities, competencies and interfaces. Take both manual and electronic components into account.
- Select documentation format: Decide on a suitable format for the procedural documentation. This can be a written document, a manual, a digital wiki or a combination of both. The procedural documentation should be user-friendly and easily accessible.
- Use clear language: Use clear and understandable language. The documentation should also be comprehensible to people outside the specific specialist area. This is particularly important if the documentation is reviewed by external auditors or authorities.
- Involvement of employees: Involve your employees who are directly involved in the mapped processes. Their experience and knowledge are crucial for practical and effective process documentation.
- Consider technological aspects: If electronic systems are involved, document the technical details, such as the software used, database structures, interfaces and security measures.
- Versioning and updating: Implement a system for versioning and updating the process documentation. Changes to processes or systems must be fully documented and all versions should be archived.
- Training and awareness-raising: Ensure that the relevant employees are aware of the existence and content of the procedural documentation. Training can help to promote understanding of the importance and implementation.
- Meet legal requirements: Make sure that the procedural documentation complies with current legal requirements. This can vary depending on the industry, region and company size.
- External audit: Consider the possibility of external audits, whether by tax authorities, auditors or other external bodies. The procedural documentation should be designed in such a way that it can withstand an audit.
Practical tip: Creating procedural documentation often takes a lot of time. This is where service providers who specialize in procedural documentation can help. With our partner
f1-verfahrensdokumentation, you have a lean, intuitive partner that is tailored to your fileee DMS and supports you in creating legally compliant procedural documentation.
The DMS as the basis for procedural documentation
The creation of procedural documentation based on a document management system (DMS) offers a modern and efficient solution for companies aiming for a paperless office [FK2]. A DMS enables the structured capture, management and archiving of documents, which simplifies the creation of procedural documentation.here are some of the advantages of this approach:
- Digital structure
With a GoBD-compliant DMS such as fileee, you have already fulfilled the first building block of the GoBD - legally compliant archiving - if used correctly. - Central storage
All relevant documents and information can be stored centrally in the DMS, which improves organization and availability. - Audit-proof archiving
AGoBD-compliant DMS offers audit-proof archiving, which complies with legal requirements and enables complete traceability. - Versioning
Theversioning of documents in the DMS enables a transparent history of process documentation and the tracking of changes. - Access rights and data protection
By assigning access rights in the DMS, sensitive information can be protected and data protection guaranteed. - Search functions
Intelligentsearch functions in the DMS make it easier to find relevant documents and information quickly. - Integration with other systems
ADMS can often be seamlessly integrated into other company systems, which enables holistic data management. - Increased efficiency
The use of a DMS helps to increase efficiency by reducing manual processes and improving collaboration within the team. - Scalability
A DMS is generally scalable and can adapt to the growing requirements of a company.
The combination of procedural documentation and DMS therefore not only offers compliance with legal requirements, but also a modern, flexible and efficient solution for the documentation and organization of business processes.
