Germany Paperless

It is possible to dispose original paper receipts after digitisation in Germany. Since the latest revision in 2019, mobile scanning, using cloud systems and digital storing is allowed. However, to go fully paperless in Germany, you need to meet quite some requirements. These requirements are set in the German GoBD (Grundsätze zur ordnungsmäßigen Führung und Aufbewahrung von Büchern, Aufzeichnungen und Unterlagen in elektronischer Form sowie zum Datenzugriff). The GoBD is effectively an interpretation of the law by the German tax authorities and published by the German Federal Ministry of Finance.

Principles

The requirements set out in the GoBD relate to a set of principles, summarised below:

• Traceability and verifiability: All individual business transactions and the processing/accounting procedure must be traceable and proven by a receipt.
• Completeness: Business transactions have to be recorded without gaps, all relevant data should be included.
• Accuracy/correctness: Business transactions shall be accurately represented by documents in accordance with the actual circumstances and in compliance with the legal provisions. (BFH judgement of 24 June 1997, BStBl II 1998 p. 51)
• Timely bookings and records: Transactions must be recorded in a timely manner, i.e. as soon as possible after it occurs.
• Order: Business transactions shall be recorded in a systematic, clear, unambiguous and identifiable manner.
• Immutability: Once information has been introduced into the processing procedure, it may no longer be suppressed or overwritten, deleted, altered or falsified without being made identifiable, so that its original content can no longer be determined.

Procedural documentation

Since the GoBD also applies to the (internal) procedures and data processing, companies need to create and keep a clear and complete procedural documentation. This documentation should illustrate how data is processed and how records are kept. What is exactly included in the documentation depends on the complexity of the company’s business activity, organisational structure and systems used.

For the period of the retention period, it must be guaranteed and proven that the procedure described in the documentation fully corresponds to the procedure used in practice.

The procedural documentation must be comprehensible and thus verifiable by an expert third party (e..g auditor) within a reasonable period of time.