In an audit the Verfahrensdokumentation is often the document requested first. If yours is up to date and complete, you start the audit day with trust already on your side.
What a Verfahrensdokumentation achieves
Under the GoBD (margin no. 151 ff.) it is mandatory for every company that processes documents electronically. It answers two questions:
- How does the process work? From invoice intake through to the archive.
- How is it ensured that the process is carried out correctly? Controls, permissions, retention.
The 8 parts in practice
1. Scope
Which accounting processes the documentation covers, which document types are affected, which organisational units are included. Plus the as-at date and the version number. Practical lever: A typical audit finding is an outdated scope. Review it actively once a year.
2. Organisational framework
Roles and responsibilities: who receives documents, who checks them, who approves, who posts, who archives. Plus stand-in rules. Practical lever: The stand-in rule is a typical gap. Document it as a short table.
3. Technical architecture
Which systems are involved in the procedure (DMS, ERP, mail system, scanning, cloud hosting). Interfaces. Hosting location. Operator. Practical lever: Data processing agreements (DPA) with cloud providers should be linked. A simple block diagram helps the auditor.
4. Intake, processing and outgoing processes
How documents reach the system (PEPPOL, email, upload, mobile, scan, EDI) and how they are checked and processed. Practical lever: One workflow block of its own per document type.
5. Permissions and roles
Which roles have which permissions. Which transactions require the four-eyes principle. Practical lever: A role matrix as a table. Per role: which case files are visible, which critical actions need four-eyes approval.
6. Archiving and retention periods
How long which documents are kept (HGB § 257, AO § 147). How immutability is ensured. Practical lever: Retention periods per document class as a table. The deletion policy linked as a separate section.
7. Data backup and recovery
Backup strategy, recovery times (RTO, RPO), responsibilities, test routines. Practical lever: When was the last restore tested? Auditors ask for this. Minimum frequency: once a year, documented.
8. Procedural controls
Internal controls with which the procedure is reviewed regularly. Frequency, form, who reviews. Practical lever: A quarterly sample of 20 documents, an annual completeness check.
Three typical mistakes
Mistake 1: an outdated as-at date. If the documentation is 3 years old and processes have changed in the meantime, it is worthless.
Mistake 2: a missing stand-in rule. “What happens when the head of accounting is on holiday?” has no answer.
Mistake 3: no link between the documentation and the real process. Auditors ask: “Show me the real case and compare it with the documentation.”
FAQ
Do we really need a Verfahrensdokumentation? Yes, as soon as documents are processed electronically. The GoBD obligation applies regardless of company size.
Is such a Verfahrensdokumentation “GoBD-compliant” or aligned with GoBD? It is aligned with GoBD and covers the requirements named in the GoBD (circular from the Federal Ministry of Finance 2019, last amended in 2025). Whether a procedure as a whole satisfies the GoBD only becomes clear in a Betriebsprüfung.
What happens if the Verfahrensdokumentation is missing? That depends: under GoBD margin no. 155 a missing Verfahrensdokumentation alone is not a reason to reject the accounting records, as long as traceability is not impaired. If traceability does suffer, formal objections up to an estimated assessment of additional income (Hinzuschätzung) can follow.
Is a Word document enough? Yes. The documentation has to be legible, complete and up to date. The format is secondary.
Conclusion
A Verfahrensdokumentation is not a bureaucratic evil you are forced into, it is a tool. If you fill in the eight parts pragmatically and keep the documentation alive, you start every audit day with trust already on your side. As at 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.