Do you have a Verfahrensdokumentation that describes your IT-supported bookkeeping process in full?
Is it reviewed regularly, at least once a year, to confirm it is still current?
Are responsibilities, interfaces and version levels documented?
02
Immutability & audit trail
Are all documents subject to retention requirements filed in a technically immutable way once they arrive?
Is every action on a record logged with timestamp, user and reason for the change?
Can the original state be restored at any time?
03
Retention periods & findability
Are all document types classified and assigned the correct retention period (6, 8 or 10 years; invoices and accounting vouchers since 2025: 8 years)?
Can individual documents be produced within a reasonable time, in hours rather than days?
Is there a documented procedure for destroying documents once the retention period has expired? It has to account for audits still in progress and for cases where the period is suspended.
04
Data access & analyzability (Z1/Z2/Z3)
Can the data be exported in a format the tax authorities can read?
Are all three types of data access supported (Z1 direct, Z2 indirect, Z3 handover of data media)?
Is access still assured after system changes and migrations, for the whole retention period?
Assess your maturity
Count your "yes" answers. The scale is a rough orientation, not a guarantee for any specific Betriebsprüfung.
0–3 yes answers
Critical risk in an audit
4–7 yes answers
Basics in place, gaps in the details
8–11 yes answers
Well positioned, close the last gaps
12 yes answers
Very well prepared
This checklist provides general information on legal requirements and is not a substitute for legal or tax advice in an individual case. As at September 2026.
Next step
Found gaps?
All twelve checkpoints are on this page in full, with no sign-up and no email address. If you are unsure about individual points, an initial call is the place to work out where you stand and what is worth tackling first.