Electronic archiving and document management systems (DMS)

Alongside the retention of original documents, section 257 (3) HGB and section 147 (2) AO also permit the electronic archiving of invoice-relevant data and documents (vouchers, invoices, delivery notes etc.) on an image carrier or other data-storage medium if it is ensured that the reproduction or the data

• corresponds to the trading or business letters received and the vouchers in terms of the image supplied, and in content terms with other documents when they are rendered readable,
• is available at all times for the duration of the retention period and can be rendered readable and automatically processable at any time.

The process used for this must comply with the Generally Accepted Accounting Principles (GoB) irrespective of the technology and archiving procedure used.

These requirements have been further specified both by the Institute of Public Accountants in Germany (IDW) in its opinion on billing "Generally Accepted Accounting Principles for the Use of Electronic Archiving Processes (IDW RS FAIT 3)" and the German Federal Ministry of Finance in the "Generally Accepted Principles of IT-based Accounting Systems (GoBS)" (Downloadlink). To ensure automatic processability of the data during external audits, the "Principles of Data Access and Auditability of Digital Documents (GDPdU)" (Downloadlink) must be heeded.

Also, when processes are outsourced as part of the electronic archiving process – such as the external scanning of physical vouchers – statutory representatives or accounting officers must ensure that the requirements regarding electronic archiving are also complied with by the service company.

In order to satisfy the statutory requirements regarding fitness for purpose, IT AUDIT offers the following support services:

• Project-supporting or ex-post audit on the introduction of electronic archiving and document management systems incl. certification of the fitness for purpose of the process deployed, as well as compliance with the GDPdU
• Assessment of the test planning and test executions as well as support of the commissioning and program approval
• Inspection of the process and procedural documentation, the technical and interface concepts as well as migration, commissioning, authorization, and archiving concepts