Each data processing system (DV system) must have a clearly structured procedural documentation according to RN 151 of the GoBD. The GoBD (principles for the proper management and storage of books, records and documents in electronic form as well as data access) has been in force since 1.1.2015 and a procedural documentation must also be available since that date. The procedural documentation must describe all the technical and organizational processes of the data processing operations. This means that the content, structure, process and results of the data processing operation must be completely and conclusively visible. The documentation must be verifiable for an expert third party in a reasonable time.
Procedural documentation is a duty!
The described procedural documentation must be true. There must be no discrepancies between the described and actual processes.
Changes in the process documentation must be historically traceable (for example in versions) with a change history.
The general ledger system and the pre- and subsystems are data processing system according to the GoBD, for example: fixed asset accounting, payroll accounting, cash register systems, payment system,...
Requirements according to the GoBD
GoBD Rn. 152:The procedural documentation describes the organisational and technical intended process, e.g. in the case of electronic documents, of the origin of information on indexing, processing and storage, clear retrieval and machine-exploitability, protection against loss and distortion and reproduction. GoBD Rn. 153: The process documentation usually consists of a general description, a user documentation, a technical system documentation and an operational documentation. Receipts and documents in paper form must be considered in the procedural documentation, such as electronic files. The absence of a paper document must not affect the possibility of traceability and verifiability (GoBD, paragraph 141). |
more information can be found in the GoBD.
Contents of the procedural documentation
The procedural documentation must consist of a general part, user documentation, technical system documentation and operational documentation.
General part of the procedural documentation
This part describes the general organization and structure of the company, suchas:
- Process organization
- Application field of the POS system
- Organizational structure
- Infrastructure
- Organization chart
User documentation
This part of the process documentation provides information about the technical processes, for example the data collection, coordination, audit and output in the company, such as
- Work instructions to staff
- Operating instruction
- User Manuals
- Program descriptions
Technical system documentation
The technical system documentation is intended to provide information concerning which software is used, which hardware, networks, ASP or cloud applications are in use and which data structures and interfaces exist.
- Documentation of machine control
- Documentation of database procedures and other processing rules
- Documentation of the handling of errors in the system
- Contents of the database tables
- Interfaces to other systems
Operational documentation
This part explains and documents the organizational processes in the company and also the proper application of the computer systems, such as
- Data integrity
- Data backup procedures
- Release of new or modified programs and program versions
- Access permissions
Each company must have engaged an internal control system (ICS) as part of the procedural documentation (see GOBDRN 102).
What to do if there is no written documentation?
In the absence of written documentation, this should be prepared as soon as possible. For this purpose, the current processes in the company have to be taken into account. Existing descriptions, such as written work and organizational instructions, can be used as a basis. In addition, notes from employees of operations, as well as computer program descriptions, security guidelines, etc. can also be helpful. The main aim of the procedural documentation is a complete and clearly structured description in which are no conflicting instructions or descriptions.
Consequences of a missing procedural documentation
According to GoBD, if, despite the missing of a procedural documentation or an inadequate procedural documentation, an examination can be carried out without any problems and thus the traceability and verifiability is not affected, there is no formal deficiency with objective weight to reject the accounting.
A sample of a procedural documentation was created by the Arbeitsgemeinschaft für wirtschaftliche Verwaltung.
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