# Mandatory digital personnel files: What will apply from 2027?
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> Das Risiko einer Arbeitsunfähigkeit ist ein ständiger Begleiter. Wie steht es aber um die Pflicht zur Entgeltfortzahlung durch den Arbeitgebenden? Trägt der Arbeitgebende das Arbeitsunfähigkeitsrisiko während der Freizeit? Und wo ist die Grenze?
The requirement to maintain certain payroll records electronically has, in principle, been in force since 1 January 2022. From 1 January 2027, employers who have previously been exempt must also maintain the records specified in Section 8(2) of the BVV electronically, as the exemption under Section 8(3) of the BVV expires on 31 December 2026.
Why is 1 January 2027 a cut-off date?
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A common question: if the obligation to keep electronic records has been in force since 2022, why is there so much talk of an obligation coming into effect from 2027? The reason lies in the transitional arrangements.
Since 1 January 2022, employers have been required to keep certain electronic payroll records digitally. They were able to apply for an exemption from the relevant audit department of the German Pension Insurance. However, this exemption is limited until 31 December 2026.
This gives rise to two scenarios:
- Employers without an exemption must keep newly generated mandatory records electronically from 1 January 2022.
- Employers with an approved exemption must keep newly generated mandatory records electronically from 1 January 2027 at the latest.
The underlying Common Principles under Section 9a of the BVV refer to new ‘circumstances and events’. This refers to new transactions or records arising from the respective cut-off date onwards.
Therefore, 2027 does not mark the start of a completely new obligation for all companies. For employers who have previously been exempt, the transition period comes to an end. For these companies specifically, the turn of the year marks the binding deadline for the switch.
**Example:** An employer is exempt from the requirement to maintain remuneration records electronically up to and including 31 December 2026. If a period of employment commences in December 2026, the relevant copy of the record required under Section 2 of the Evidence Act does not have to be digitised retrospectively simply because the deadline has passed.
If a further period of employment begins on 2 January 2027, the relevant record must be included electronically in the payroll records.
Does the requirement to keep electronic records also apply to small and medium-sized enterprises?
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Section 8 of the BVV does not link the obligation to a specific number of employees or to turnover. Consequently, there is no general exemption for SMEs solely on the basis of their size. An exemption granted until the end of 2026 is a temporary transitional arrangement. It is not a permanent special provision for small businesses.
One statutory exemption applies to employees in private households. Section 28f(1), second sentence, of SGB IV expressly exempts these employment relationships from the obligation set out in the first sentence to keep and retain personal remuneration records. This exemption depends on the nature of the employment relationship. It does not apply to standard employment relationships within companies.
Which payroll records must be kept electronically
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Will all documents in personnel files have to be available in digital form from 2027? The scope of the requirement is more narrowly defined and is derived primarily from Section 8(2) of the BVV. The documents concerned include, in particular:
AreaDocuments to be kept electronicallyEmployment of foreign nationalsProof of nationality, residence permit, work permit and postingSocial security statusDocuments relating to exemption from compulsory insurance, exemption from the obligation to take out insurance and determination of statusNewsData submitted by employers and contributions-related notifications from health insurance fundsMinor employmentDeclarations regarding other employment, as well as applications and declarations relating to pension insuranceProof of employmentA copy of the record in accordance with the Evidence Act, or, in the case of maritime enterprises, a copy of the employment contractHealth and CareProof of health insurance cover, proof of parental status, and documents relating to care leave and care allowanceRemunerationStatements regarding the waiver of entitlement to remuneration and decisions on tuition fees paid on behalf of studentsMinimum working conditionsRecords required under the Minimum Wage Act and the Posting of Workers ActOther special casesDocumentation relating to exemption agreements, certain certification data transmitted electronically, and specific supporting evidence for maritime and inland waterway transportIn addition, evidence of the insolvency protection afforded to credit balances must be kept in electronic form. The documents concerned in each individual case should be checked against the current version of Section 8 of the BVV.
**Note from Rexx Systems:** The mandatory list set out in Section 8 of the BVV comprises only the remuneration documents specified therein. A digital personnel file may also contain other personnel documents which a company chooses to manage digitally.
How must electronic payslips be stored?
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The law does not specify any particular personnel records software. However, a scanned file only meets the requirements if it is properly stored, clearly identified and available in a readable format throughout the retention period.
- The Joint Principles under Section 9a of the BVV set out specific requirements:
- Every document requested must be available as a separate file.
- PDFs and image files in the formats JPEG, BMP, PNG and TIFF are permitted.
- All necessary images and fonts must be contained within the file.
- Scripts or content that is loaded from other sources are not permitted.
- The document type, data subject and time period must be identifiable.
- It must be possible to view the file regardless of location or system.
A file system can, in principle, meet these requirements. This requires a standardised filing structure and regulated access rights. Companies must also ensure that the documents remain locatable and immediately readable throughout the entire retention period.
A **[digital personnel file](https://www.rexx-systems.com/digital-employee-file/)** simplifies this task, as the document type, individual and time period can be stored directly within the system. However, its introduction is not a statutory requirement in its own right.
Do I need to digitise old personnel files retrospectively?
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There is no blanket obligation to digitise all legacy files. The decisive factor is the date on which the relevant file was created.
Unless an exemption applies, the obligation to maintain records electronically has applied to new documents since 1 January 2022. Where an exemption has been granted, it applies at the latest to new documents from 1 January 2027. The Joint Principles do not generally require the retrospective electronic management of documents from earlier periods.
Companies may digitise older personnel files on a voluntary basis. This creates a uniform file system and simplifies searches. Voluntary digitisation must be distinguished from the statutory obligation regarding newly created documents.
ction of the original. If documents are submitted in paper form in accordance with Section 8(2) of the BVV, the employer must convert them into an electronic format.
As of September 2026, the current version of Section 9(5) of the BVV applies. If paper documents are converted into an electronic format in accordance with Section 8(2) of the BVV, the original documents must be retained until the tax audit has been definitively concluded.
If another statutory provision stipulates a longer retention period, that longer period shall apply. The option to destroy documents described in the Joint Principles of 2022 does not override this current statutory retention obligation.
Am I allowed to destroy the original paper documents after scanning them?
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Scanning a document does not permit the blanket destruction of the original. If documents are submitted in paper form in accordance with Section 8(2) of the BVV, the employer must convert them into an electronic format.
As of September 2026, the current version of Section 9(5) of the BVV applies. If paper documents are converted into an electronic format in accordance with Section 8(2) of the BVV, the original documents must be retained until the tax audit has been definitively concluded.
If another statutory provision stipulates a longer retention period, that longer period shall apply. The option to destroy documents described in the Joint Principles of 2022 does not override this current statutory retention obligation.
**Our advice:** Do not destroy a paper original until the audit notice has become final and no further statutory retention period applies to the document in question.
How long must payroll records be kept?
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There is no single time limit that applies to how long a complete personnel file must be retained. The applicable retention periods depend on the type of document and its purpose.
With regard to remuneration records for social security purposes, Section 28f of Book IV of the Social Code (SGB IV) stipulates that these must be kept separately for each employee and organised by calendar year. The records must be retained until the end of the calendar year following the last tax audit.
Additional retention requirements under commercial, tax or employment law may apply to individual documents. The legislator does not make a blanket statement such as ‘personnel files must be retained for six or ten years’.
Are electronic payslips and euBP the same thing?
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No. The electronic management of remuneration records relates to the storage and availability of certain supporting documents at the employer’s premises. The electronically supported tax audit, or euBP for short, governs the transmission of data relevant to the audit to the German Pension Insurance Scheme.
Electronic payslipseuBPCertain documents are kept in electronic form.Examination data is submitted electronically.The documents will initially remain with the employer.The data is sent to the German Pension Insurance Scheme.Dokumente werden bei Bedarf angefordert.Documents will be requested as and when required.A digital personnel file can help with filing.The data is transmitted via a system-verified payroll or financial accounting programme.A temporary exemption under the euBP is also coming to an end. Electronic submission will be mandatory for payroll cases from 1 January 2027 onwards. A digital personnel file does not replace the system-certified payroll or financial accounting software required for this purpose.
What should employers have done by the end of 2026?
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Another question that is often asked in connection with the obligation to maintain a digital personnel file is: What, specifically, does my HR team need to prepare if an exemption has been in place until now?
Start by taking stock of your current filing and payroll processes. You can then prepare for the transition in eight specific steps:
1. **Check exemption status:** Clarify whether an exemption applies and until when it is valid.
2. **Identify mandatory documents:** Record which types of documents are generated in your organisation in accordance with Section 8 of the BVV.
3. **Record receipt channels:** Document which documents are received from employees, health insurance funds or public authorities.
4. **Define filing rules:** Set out file formats, naming conventions and responsibilities in a binding manner.
5. **Protect originals:** Ensure that paper originals subject to retention requirements are preserved.
6. **Clarify the euBP procedure:** Check with your payroll department or service provider to determine which system-verified programme transmits the data.
7. **Test retrieval:** Carry out a test to check whether a document can be found based on the person, document type and time period.
8. **Document responsibilities:** Record who receives, checks and makes documents available for review.
If a new solution is required for this, it is helpful to compare providers of digital personnel files. When integrating HR and payroll systems, a **[DATEV interface](https://www.rexx-systems.com/datev-interface/)** can also help to minimise data discontinuities. Such an interface should be assessed separately from the euBP transmission procedure.
How do I keep track of digital personnel records?
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At Rexx Systems, our experience in developing **[HR software](https://www.rexx-systems.com/software-hr-en/)** has taught us that a digital personnel file must do more than simply store files. In day-to-day operations, it must:
- unambiguously assign documents to a specific employee and a document type,
- make documents quickly retrievable via a search function,
- control access via role-based permissions,
- map recurring tasks and deadlines in traceable workflows.
The Rexx Suite’s digital personnel file brings together documents and personnel data in a single environment for this purpose. The personnel file software’s scan manager also assists with the digitisation of paper documents.
**Note:** With a configuration tailored to business processes, the digital personnel file helps companies to reliably comply with legal requirements. Rexx Systems provides information on ISO 27001 certification and security measures in the [**Trust Centre**](https://www.rexx-systems.com/trustcenter/).
Bring some structure to your HR documents
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From 1 January 2027, employers who were previously exempt will also be required to maintain the remuneration records specified in Section 8(2) of the BVV in electronic form. With the digital personnel file from Rexx Systems, you can organise these mandatory records alongside other HR documents in a centralised environment.
**The benefits of the Rexx Suite:**
- You can quickly locate relevant records because documents are unambiguously assigned to the respective employee.
- You protect sensitive personnel data with role-based permissions that precisely control access and editing.
- You can convert paper documents into a central digital structure using the Scan Manager whilst continuing to comply with existing retention obligations.
- You keep track of recurring tasks and deadlines, as document-related processes can be mapped out via workflows.
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Mandatory Digital Personnel Files – Frequently Asked Questions
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### Do euBP data have to be submitted on a monthly basis?
No. There is no requirement to submit a monthly or other regular report. The data is provided for the purposes of a tax audit. The specific deadline is set out in the audit notice issued by the German Pension Insurance Scheme.
### What should you bear in mind when changing your invoicing software?
From 1 January 2025, employers must submit the euBP data for the next tax audit when changing their payroll software or service provider. The previous software or client should only be deleted once the DSRV has confirmed that the data has been successfully processed.
### Which companies are affected?
The Pay Transparency Directive applies to all employers in the EU. It is particularly relevant for companies with 100 or more employees, as they will in future be required to report regularly on gender pay gaps.
### What happens to the euBP data after the tax audit?
The DSRV automatically deletes the data submitted as soon as the audit decision becomes final. The sender receives an electronic notification to this effect.
### How are scanned documents assigned to the correct personnel file in Rexx Systems?
[**Rexx Systems**](https://www.rexx-systems.com/en/)’ ScanManager digitises paper documents in batches and assigns them to the digital personnel files of the relevant employees. Upon import, the scans are indexed and tagged with search criteria. This enables the documents to be retrieved specifically via Rexx Systems’ digital personnel file.
### What are the potential consequences of missing pay records?
Anyone who intentionally or recklessly breaches the obligation to keep or retain records of payments may be guilty of an administrative offence. Section 111 of Book IV of the Social Code (SGB IV) provides for a fine of up to 50,000 euros for the offence specified therein. The maximum amount is not automatically imposed for every record-keeping error.
### Can notices of termination be signed exclusively in digital form?
No. Under Section 623 of the German Civil Code (BGB), notices of termination and mutual termination agreements must be in writing. Electronic form is not permitted. A digital copy filed for record-keeping purposes does not alter this requirement for validity. For documents without such formal requirements, a digital signature may be acceptable.
**Disclaimer:** The legal content provided in this glossary is for general information purposes only and does not constitute legal advice. Despite careful research and verification, we accept no liability for the accuracy, completeness or timeliness of the content. Use of this information is at your own risk.
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