Expert knowledge for digital decisions
What does a company audit check regarding digital documents?
Short answer
The three audit points
Completeness and Unaltered Status. Every document must be present and provable as unchanged. Subsequent changes must be documented.
Process Documentation. The process must be described – see our own contribution on this topic.
Data Access. The tax authorities may require access to the tax-relevant data in a readable format.
What is noticeable in practice
- Only prints available. In an e-invoice, the structured data part is the original.
- Email inbox as an archive. Meets neither unalterability nor readability.
- No process documentation.
- Documents in a system that no longer exists. After a system change, the old stock must remain readable.
The last point becomes relevant with every software change and is regularly overlooked.
What you should prepare
- A description of where which documents are stored
- Proof that the storage is unaltered
- The possibility to provide data in a readable format
- An up-to-date process documentation
During system changes
Clarify before shutting down the old system, how the old documents will remain readable for the remaining retention period. Exporting to an open format is usually the most practical way.
This text does not replace tax advice.
Key facts
- Three Audit Points
- Completeness, Documentation, Readability
- Most Common Shortcoming
- Inbox as an Archive, Only Prints
- During System Changes
- Ensure Readability of Old Documents
Sources
All external claims are backed by traceable sources.-
01
§ 147 AO – Ordnungsvorschriften für die Aufbewahrung von Unterlagen Bundesministerium der Justiz
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02
Fragen und Antworten zur obligatorischen E-Rechnung ab 1. Januar 2025 Bundesministerium der Finanzen