What does Process Documentation GoBD Mean?

Many entrepreneurs are familiar with the basic principles of proper bookkeeping, but have to match the GoBD procedure documentation at the latest. But ignorance does not protect against punishment! At the latest when the auditor asks about the procedural documentation, things get tight!

In order to ensure the verifiability and traceability of the company’s entire bookkeeping, the procedural documentation must map all technical and organizational processes. This includes the processes of creation but also the indexing, the electronic storage of all accounting documents, the clear allocation and retrieval of the documents, as well as the protection against data loss and / or data corruption of all stored information.

What should the procedural documentation look like?

With the help of the procedural documentation, you as the company owner describe exactly which route a receipt takes through your company. For this you have to take different perspectives. The classic procedural documentation is divided into four areas. It always begins with a general description before detailed user documentation follows. Of course, operational and technical system documentation must not be missing in process documentation.

The most important aspect of the process documentation is the actual process of document entry and processing. You have to document which

  • IT systems are used.
  • Measures have been taken to protect the recorded documents from loss or falsification.
  • Measures were taken to document all access to the receipts.
  • There are internal company controls to ensure that all GoBD requirements have been complied with.

Important : As soon as the procedure for entering and processing the documents changes and / or there are changes to the IT system, you must record this in the procedure documentation. Every change to the process documentation must be traceable!

Special case “paperless bookkeeping”: You have to pay attention to this!

If your company still works with receipts in paper form, the original documents can only be disposed of in the trash once the scanning process has been recorded in detail in the procedural documentation in writing. How are the paper receipts recorded electronically? How are they then issued? Who checks the quality of the scans? Is there a log of errors and what does it look like?

Is it mandatory to create procedural documentation according to the GoBD?

In a nutshell, yes it is! At the moment, a non-existent or insufficient procedural documentation is not considered a direct formal defect with objective weight. Therefore, there are currently no “serious” consequences, provided that the accounting and all documents are traceable. If the auditor is of the opinion that there are gross deficiencies, he can completely discard and estimate the bookkeeping. Usually an estimate is always to the disadvantage of the entrepreneur.

Seminars can help

According to HOWSMB.COM, there are various organizers who offer seminars on GoBD-compliant procedural documentation. The Technical Academy Wuppertal eV explains, among other things, the legal framework, the components of procedural documentation and the use of various documents. In seminars by IBS Schreiber GmbH, the participants get to know the requirements of the GoBD, receive an excursion into the storage of tax-relevant documents and learn practical application in case studies.


Make sure that you can substantiate every business transaction. This means that you also have to keep documents that are relevant to the individual business transaction. The recording of cashless business transactions must take place within ten days and cash business transactions on a daily basis. Tax auditors consider it questionable if it takes longer than ten days to record the documents.

Worth knowing: What does the GoBD understand by the recording of receipts?

The manual review and an orderly filing of all documents (backup / land register recording) are part of the recording of documents relevant to the bookkeeping.

The correct form of the land registry

  • Digital receipts must also be stored digitally, for example using archiving software . Just printing is not enough!
  • Documents of public belief and / or evidential value (e.g. notarial contracts, etc.) must always be kept in the original.

GoBD: This is what the documentation should look like

All receipts must be recorded digitally in the period specified above. An orderly, clear and continuous document filing must be guaranteed. The entrepreneur is responsible to the tax office to ensure the completeness of all documents.

Process documentation: the immutability of the data

Regardless of whether you enter receipts in paper form or digitally, you have to mark them individually with the date of entry. If changes are necessary, these must be made in such a way that the original content is retained. Certain forms of storage and / or formats are not GoBD-compliant. Example, the creation of invoices in Word or Excel. In this case, the unchangeability of the data is not guaranteed, nor is it possible to archive the data in an audit-proof manner.

Does the duty also apply to small businesses?

Yes, small businesses are also obliged to document the procedures. According to a study by the DIHK , not only the additional financial and administrative burden is a problem, but above all that many do not even know what such procedural documentation should look like. There are some templates on the web, but these are tailored to the special needs of large companies. Of course, the tax auditor is also a certain uncertainty factor.

Freelancers and sole proprietorships are not obliged to create detailed procedural documentation. However, only under the condition that they can explain all processes to the auditor in an uncomplicated manner in the event of a tax audit.

As an entrepreneur with a handful of employees, you should seek advice from your tax advisor. Before consulting, make a note of all the relevant systems that you use for bookkeeping. Of course, the protocols and operating instructions used should not be missing. All information helps the auditor to better understand all processes within your company.

What do I have to consider when managing the cash register?

The documentation of cash transactions must always be done on a daily basis. Again, no booking without receipts applies! You can replace lost or damaged receipts with your own receipts, but very special guidelines apply here. Furthermore, the tax office has a very strict eye on that there is no cheating. A simple GoBD process documentation checklist can also be used for (register) cash registers, provided that only one cash register is in use. However, if entire POS systems are used, external support is required. In this case, model process documentation will not help either.

Process Documentation GoBD