GDPdU: Principles of Data Access and Auditability of Digital Documents
When companies discuss electronic archiving and email archiving, they inevitably encounter GDPdU. The abbreviation stands for the German principles governing data access and the auditability of digital records.
As soon as a tax audit is announced, one key question appears: Which rules apply to retaining digital records?
These requirements are defined by guidance from the German Federal Ministry of Finance and by GoBD. GoBD refers to the principles for proper bookkeeping and retention of records in electronic form, including data access.
Taxpayer duty to cooperate in data access
A core requirement is the taxpayer's duty to cooperate during auditor data access. This means that relevant data must always be accessible during an audit. Auditors must be able to read and evaluate the data, or readability must be ensured through data handover on an accepted storage medium.
GDPdU format: Which formats are required?
If you want to implement GDPdU correctly, you must clarify which file formats are accepted by tax authorities. During data handover, companies need to follow the required transfer description standards.
The key requirement is that tax authority audit software can read the data reliably. Accepted file formats currently include:
- Access
- ASCII delimited
- ASCII fixed length
- ASCII print files
- dBase
- EBCDIC data
- Excel
- Lotus 123
- SAP/AIS files
- AS/400 data descriptions convertible to RDE descriptions
All other formats must be converted into readable formats before an audit.
GDPdU and POS systems: Which cash register systems are allowed?
Tax authorities define requirements for POS and cash register systems. While paper receipts and invoices were once sufficient, since 2002 the same data must also be stored electronically and comply with GDPdU requirements.
Because these requirements are defined by the Federal Ministry of Finance, they should be implemented before the next tax audit. Today, it is standard for modern POS systems to be labeled as "GoBD/GDPdU compliant."
GDPdU archiving: How to ensure legally compliant electronic archiving
Does everything have to be archived digitally? Not necessarily. Important paper documents do not always need to be digitized. A fully digital archive is not suitable for every organization.
What matters is that all relevant data can be provided during an audit. Most accounting and business systems store this data and provide export options.
GDPdU and the Federal Ministry of Finance
The Federal Ministry of Finance defines how data access is regulated in tax and audit scenarios. GDPdU outlines principles that apply when tax offices need access to company data during digital audits.
It also defines requirements for enterprise data processing systems. Auditors must be able to access and evaluate data and request copies on storage media if needed.