Thank you for your reply.

Am Dienstag, 4. Oktober 2016 14:49:20 UTC+2 schrieb Timitos:
>
> > These requirements are: 
> >   * book entries or records must not be changed in such a way that 
> > their original content cannot be retrieved or determined any more, 
> >   * later changes are to be made in such a way, that the original 
> > content as well as the fact that changes were made, are recognizable, 
> >   * when master data is changed, the distinct meaning in the according 
> > transaction data has to be recognizable afterwards. 
> I think that these 2 features should meet the legal requirements but 
> maybe except for the requirement that is defined by 'unchangeable'. All 
> the data is stored in a database and i do not see any proper technical 
> way how to make the content of it 'unchangeable'. For me the GoBD are 
> are quite vague about this term. 
>

According to the GoBD Guidlines [1], pages 28-29, 'unchangeable' (that is 
how I've translated) means:

'The electronic data processing procedure must guarantee, that all 
information (programs and data stock), which has been introduced once into 
the data processing process (receipt, entry, etc.), cannot be 
aborted/suppressed or rewritten without an identification as such, deleted, 
edited or falsified/manipulated, too. Already inserted information into the 
data processing procedure is not allowed to be replaced by new data without 
proper identification.' 

Measures to prevent such manipulation can be on the hardware and on the 
software side.

Software measures listed there are: 'Safeguarding or backup (depends on the 
translation and intention of the guideline itself), blocking, locking up, 
erase marker, automatic logging, versioning, historicizing.'

This is to be regarded as a 'should'-requirement.

The guideline comments on this as follows, p. 32:

By using of additional internal safety measures (checksums, validity check, 
system protocols/logs, technical authorisation, etc.) attempts of 
manipulation of data "bypassing the planned process" can be prevented in 
most cases or at least be detected.'

I have never had the pleasure of a tax audit, so I have no experience at 
all with the tax auditors/inspectors in Germany. Penalties can be very 
considerable if you are a small and medium-sized company.

[1] https://www.psp.eu/media/allgemein/GoBD-Leitfaden_Version_2_0_FINAL.pdf

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