The Betriebsprüfung 2026 is becoming increasingly digital. Auditors arrive with a laptop and concrete questions about your processes. Anyone who first has to "dig out" documents signals disorder.
What auditors look at today
Data access is a given. Under § 147 (6) AO the tax authorities may demand data access up to and including the handover of data: auditors ask for structured data exports (CSV, XML) instead of stacks of paper files.
Verfahrensdokumentation as the opening question. One of the first questions is often: "Show me your Verfahrensdokumentation." Anyone who hesitates here loses trust.
Samples instead of a full review. Auditors draw random samples and check completeness, audit trail and consistency.
Document 1: Verfahrensdokumentation
Often the first thing requested. Core contents (derived from the GoBD, margin no. 151 ff.): scope, organisational framework, technical architecture, processes, permission model, archiving, backup, procedural controls. Lever: keep it current (rule of thumb: review annually), with traceable versioning.
Document 2: Invoice register
Lists every invoice received in chronological order. Proven columns: date of receipt, intake channel, supplier, invoice number, amount, status, reference to the archived document. Lever: completeness is mandatory. A gap is a typical trigger for an estimated assessment (Hinzuschätzung).
Document 3: audit trail
Records who did what in the DMS, and when. Typical fields: date and time, user, action, record affected, and where applicable the before and after value. Lever: audit trail data has to stay available for the entire retention period of the documents.
Document 4: retention schedule
| Document class | Retention period | Legal basis |
|---|---|---|
| Invoices, accounting vouchers | 8 years (since 2025, previously 10) | AO § 147, HGB § 257, UStG § 14b |
| Books, annual financial statements | 10 years | AO § 147, HGB § 257 |
| Business letters | 6 years | HGB § 257 |
| Personnel files | 3 years after termination | rule of thumb (limitation periods, BGB §§ 195, 199) |
| Payroll accounts | 6 years | EStG § 41 |
| Social security payroll records | until the end of the year following the last social security audit | SGB IV § 28f |
Lever: the periods have to be stored in the DMS per document class, not "on paper in a drawer".
Document 5: deletion policy
Documents which data is deleted and when, who is responsible, how the deletion is logged, and how you make sure that ongoing legal proceedings are not overlooked. Lever: auditors typically ask: "When did you last delete in production?"
Preparing data access
Under § 147 (6) AO the tax authorities can inspect the system themselves, demand automated evaluations to their specifications, or have the data handed over in a machine-readable format. With a DMS, preparation therefore no longer means putting folders together, but:
- 1Set up read access for the auditor: a separate user with a restricted role.
- 2Open the Verfahrensdokumentation and check the as-of date.
- 3Have the retention schedule and the deletion policy ready, i.e. the answers to documents 4 and 5.
- 4If the auditor wants to evaluate the data on their own computer: create an export for the audit period, for example from the result list.
Printing, copying files together and a folder on the auditor's laptop are no longer needed. The auditor sees the documents where they are archived.
FAQ
How is a Betriebsprüfung announced? The audit order arrives in writing with reasonable notice, for small and mid-sized businesses usually at least two weeks in advance.
What if the Verfahrensdokumentation is out of date? Communicate openly and commit to a correction within 2 weeks. Out-of-date documentation is better than none.
How long does a typical Betriebsprüfung take? That depends on size and complexity, from a few days to several weeks.
Conclusion
The Betriebsprüfung 2026 audits digitally. If you have five documents to hand and give the auditor read access, you start without stress. The rest is sample discipline, and that starts in everyday work, not on the audit day. As of September 2026
This article provides general information on legal requirements and is no substitute for legal or tax advice in an individual case.
Further reading
Ready for your next Betriebsprüfung?
The GoBD audit checklist sums up twelve checkpoints for a self-audit, in plain language.