GoBD for online retailers – procedural documentation: mandatory program with added value

In the first part of our blog series, we presented the basics of the GoBD, while the second part dealt with accounting, document storage and archiving. In this third part, we take a look at a topic that many retailers would prefer to ignore: procedural documentation. It sounds bureaucratic and dry – but it’s essential. And: those who set it up pragmatically will even benefit from it in everyday life.

Why procedural documentation is mandatory

The GoBD stipulates that your accounting must be traceable, unchangeable and auditable. This is exactly what a tax auditor examines – and for this he needs a kind of operating manual for your systems and processes. This user manual is the procedural documentation.

It describes how tax-relevant data is created, processed, stored and retained in your company. It must also clearly state who has access and which controls prevent manipulation. Without procedural documentation, an auditor simply cannot assess whether your accounting is correct. As a result, they can reject it and estimate turnover – almost always to your disadvantage.

Important: The obligation applies to all taxable companies, including small retailers, freelancers and one-person stores. Anyone who uses digital processes – be it sending invoices via PDF or an ERP system – must keep procedural documentation.

What happens if it is missing?

The consequences of non-existent or inadequate procedural documentation are serious:

• Formal deficiencies: Your accounting is considered improper.
• Additional estimates: The tax office estimates your sales or profits – and rarely interprets them to your advantage.
• Tax arrears & interest: Even small gaps can result in high additional claims.
• Fines or criminal proceedings: In serious cases, there is even the threat of criminal proceedings under tax law.
• More work in the audit: Without documentation, a tax audit takes longer, additional documents are requested and unnecessary stress arises.

In short: If you don’t have procedural documentation, you go into an audit unprepared – and risk serious disadvantages.

More than just a duty - real advantages

Even if it sounds like a rather annoying obligation, good procedural documentation has advantages in everyday life:

• Structure & clarity: You can see in black and white how your processes are running – and where things are going wrong.
• Easier onboarding: New employees find their way in more quickly.
• Security in an emergency: In the event of a dispute with the tax office, you have documented your processes and can prove how you work at any time.
• Less chaos: By describing the processes, you are automatically forced to organize processes and avoid duplication.

What belongs in the procedural documentation

The GoBD does not specify a fixed structure, but certain chapters have been established that every auditor expects. These are particularly relevant for online retailers:

1. General company and system description
   Briefly introduce your company: Name, legal form, contact person. Add an overview of the organization (departments, responsibilities) and describe your system landscape: store system, ERP (e.g. JTL-Wawi), marketplaces, payment provider, DMS/archiving system, accounting software.
2. User documentation
   Describes how work is done on a day-to-day basis:
   
   – How is an A/P invoice released?
   – Who is allowed to archive or delete documents?
   – Which work steps are automated, which are manual?
   
   The aim here is that an external third party must understand how your processes work without having to ask questions.
3. Technical system documentation
   This covers hardware and software, versions, interfaces and storage locations. Backups, recovery routines and archive formats are also included. Particularly important: How do you ensure that data cannot be changed?
4. Controls & authorizations
   Explain your access concepts: Who can do what? Is there a dual control principle for certain processes? Are changes logged?
5. Tax-relevant data processes
   Shows the complete document flow: from the order in the store to the invoice to the return. This also includes tax-related emails, cash register or bank data and the replacement scanning of paper documents.
6. Changes & versioning
   The documentation is a living document. Every change (e.g. system change, new processes) must be noted with date, reason and person responsible. Old versions must be retained.
7. Responsibilities & external service providers
   Who is responsible for maintenance? Which external partners (cloud providers, tax consultants) are involved? Are there contingency plans in case of system failures or data loss?

How to start pragmatically

Many retailers hesitate because they think that procedural documentation is a thick folder full of paragraphs. In reality, it’s enough if your documentation is clear and up-to-date. That’s enough to start with:

1. A list of all systems that generate tax-relevant data.
2. A chart of the document flow (order → invoice → returns).
3. An overview of roles and rights in the company.
4. A change log in which you document adjustments.

You already fulfill the most important requirements. You can gradually refine the documentation later.

Checklist for your procedural documentation

• Company profile & system landscape recorded
• Processes and document flows described
• Roles & authorizations documented
• Archiving & immutability explained
• Changes & versions recorded in a traceable manner
• Responsibilities named and external partners listed

Conclusion

The procedural documentation is not an end in itself. It is the basis for ensuring that your accounting is auditable, traceable and legally compliant. If you ignore it, you risk back taxes, fines and sleepless nights. If, on the other hand, you set them up pragmatically, you benefit twice over: less risk – and more order in your own company.