Procedural documentation

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The procedural documentation according to GoBD ("GoBS" until 2015) is used to prove that the requirements of the Commercial Code (HGB) and the Tax Code (AO) for the collection, booking, processing, storage and disposal of data and documents are met. The tax authorities have published principles for the proper management and storage of books, records and documents in electronic form as well as for data access in a BMF letter and makes statements on procedural documentation in Item 151ff of the BMF letter.

Regardless of the requirements of the tax administration, there are also requirements for the creation of procedural documentation for certain industries, e.g. B. for the pharmaceutical industry according to FDA Part 11 and GxP ( GMP , GLP Good Laboratory Practice ). The EN 82079 standard is the basis for creating technical documentation .

Procedure documentation according to the GoBD

According to § 140 AO, the non-tax accounting and recording obligations that are important for taxation must also be fulfilled for tax law. Non-tax bookkeeping and recording obligations arise in particular from the provisions of §§ 238 ff. HGB and from the commercial law principles of proper accounting (GoB) specified there. For individual legal forms, there are accompanying recording obligations, e.g. B. from §§ 91 ff. Stock Corporation Act, §§ 41 ff. GmbH Act or § 33 Genossenschaftsgesetz. Furthermore, there are numerous commercial or industry-specific recording regulations that, according to § 140 AO are of importance for taxation in specific individual cases, such as B. Pharmacy business regulations, calibration regulations, driving instructors act, trade regulations, § 26 Banking Act or § 55 Insurance Supervision Act (TZ 3 GoBD 2014).

The GoBD results in the following requirements for the recording and storage of accounting-relevant documents as well as those documents that are relevant for taxation, both on paper and in electronic form.

  • Traceability and verifiability
  • Principle of truth, clarity and continuous recording (including timeliness)
  • Document management (document function)
  • Recording of business transactions in chronological order and in factual order (land register recording, journal and account function)
  • Internal control system (ICS)
  • Data security
  • Immutability, logging of changes
  • storage
  • Data access
  • Certification and software attestations and
  • Application regulations

The procedural documentation according to GoBD describes the organizational and technical process for the traceability and verifiability of the recording and storage of tax-relevant business transactions and additional information regarding:

  • the emergence (recording)
  • the indexing,
  • processing and storage,
  • the clear finding,
  • the machine evaluability,
  • the protection against loss and falsification and
  • the reproduction of the archived information (Item 152).

The financial administration has specified the requirements for procedural documentation in Item 151ff of the GoBD: Since the correctness relates not only to the electronic books and otherwise required records but also to the related procedures and areas of the data processing (= DV) system, every DV System, a clearly structured procedural documentation must be available

  • the content,
  • the structure,
  • the process and
  • the results of the IT process

are fully and conclusively evident. The design and level of detail of procedural documentation according to GoBD depend on the complexity and diversification of the business activity and the organizational structure as well as the IT system used. The process documentation is qualitatively sufficient and complete if an expert third party can check the correct use of the solution on the basis of the documentation.

The procedure documentation according to GoBD usually consists of one

  • general description,
  • user documentation,
  • technical system documentation and
  • an operational documentation. (Item 153)

Insofar as a missing or inadequate procedural documentation does not impair the traceability and verifiability, there is no formal defect with material weight that could lead to the discarding of the bookkeeping. (Item 155)

Formal deficiencies do not lead to the discarding of the accounting. However, the presumption of factual correctness is refuted if it can be proven that there are grounds for factual objections to the result of the bookkeeping or the records. In order to reject the bookkeeping, the tax authority must also show that the result of the bookkeeping is incorrect. Because even a formally improper bookkeeping can show a correct result. However, if the presumption is destroyed because the tax authorities have proven that the result of the bookkeeping is incorrect, the result on which the taxation is based can also be determined without express evidence - i.e. through an estimate. The taxpayer bears the objective burden of proof for the circumstances favorable to him, ie he has to provide evidence that business expenses can be deducted. If there are formal errors and incomplete records in connection with the yield estimate, this can result in an overall unfavorable determination of the result for the taxpayer by the tax authorities.

In the opinion of the tax authorities, the taxpayer must install an internal control system to ensure compliance with the GoBD regulations. This ICS includes, among other things, access controls, separation of functions, recording and processing controls and other protective measures. The structure and mode of operation of the internal control system must also be documented in a separate procedural documentation (Item 100).

See also


  • Principles for the proper management and storage of books, records and documents in electronic form as well as for data access (GoBD) (PDF file). Letter from the Federal Ministry of Finance to the regional tax authorities of 14 November 2014 - IV A 4 - S 0316/13/1003.
  • Ulrich Kampffmeyer , Jörg Rogalla: Principles of electronic archiving . Code of Practice Volume 1. VOI Association of Organizational and Information Systems e. V., Bonn, 2nd edition 1997, ISBN 3-932898-03-6 .
  • Karl-Georg Henstorf, Ulrich Kampffmeyer, Jan Prochnow: Principles of procedural documentation according to GoBS . Code of Practice Volume 2. VOI Association of Organizational and Information Systems e. V., Bonn, 1999, ISBN 3-932898-04-4 .