Elektronische Entgeltunterlagen: ab 2027 Pflicht für alle Arbeitgeber

The enrolment certificate of your working student in a paper folder, the exemption application of your mini-jobber in a drawer: from 1 January 2027 that is no longer enough. From then on, all employers must keep the supplementary payroll records (Entgeltunterlagen) under § 8 (2) of the Contribution Procedure Ordinance (BVV) in electronic form. The option of being exempted from this ends on 31 December 2026. Here you will find out which documents are affected, which technical requirements apply, what happens to paper originals and how you can manage the switch in the next three months.

What this is about: payroll records and the social security audit

Under § 28f (1) SGB IV, every employer must keep payroll records (Entgeltunterlagen) for each employee and retain them until the end of the calendar year following the last audit. The Contribution Procedure Ordinance sets out which details and documents belong in them. The German pension insurance (Deutsche Rentenversicherung) examines these records at least every four years as part of the employer audit under § 28p SGB IV. The question is whether social security contributions were calculated and paid correctly.

The BVV distinguishes two groups:

• Payroll records in the narrower sense under § 8 (1) BVV: name, address, periods of employment, remuneration, contribution groups and similar details. This data is already held electronically in every payroll program anyway.
• Supplementary documents under § 8 (2) BVV: proofs, certificates and declarations on which the assessment of insurance status is based. This is exactly where the problem lies, because in many businesses these documents still arrive on paper.

What changes on 1 January 2027

Keeping payroll records electronically has been the statutory default since 1 January 2022. However, employers could apply to the competent audit service of the pension insurance for an exemption. That exemption applies until 31 December 2026 at the latest.

From 1 January 2027 this exception no longer exists. The obligation then applies to all employers subject to the pension insurance audit, regardless of size and sector. If you employ even a single mini-jobber or working student, you are affected. A new exemption application is no longer worthwhile, because even an approved exemption would expire at the end of the year.

The law does not require old paper files to be digitised retroactively. The obligation applies to documents that have to be kept from 2027 onwards. But because an audit looks back four years, in 2028 or 2029 the auditor will accept only electronic documents for the years from 2027. At the same time, she will still want to see your paper folders for the years before.

Which documents are affected

§ 8 (2) BVV lists the supplementary documents exhaustively. In the practice of small businesses, these are the ones that come up most:

• Mini-jobs: the application for exemption from compulsory pension insurance for marginal employment, and for short-term employees the declaration about further short-term jobs in the calendar year. You will find more on the basics in our article on hiring a mini-jobber.
• Students: the enrolment certificate as proof for the working student privilege.
• Health insurance: membership certificates from the health insurer as well as notices on compulsory insurance or exemption.
• Long-term care insurance: proof of parenthood and the number of children for the surcharge for childless people and the reductions for parents of several children.
• Foreign connection: documents on nationality and residence permit, as well as the A1 certificate for postings abroad.
• Old-age pensioners: the declaration waiving exemption from pension insurance.

The employment contract, for example, is not covered by the obligation. You may store it electronically, but you do not have to. The obligation also applies only to the social security documents. For payroll tax and bookkeeping, the GoBD (German principles for proper electronic bookkeeping) and the tax retention periods apply in addition.

The technical requirements

What electronic record keeping has to look like in concrete terms follows from the Joint Principles of the social insurance institutions under § 9a BVV. The key points:

1. Permitted formats: PDF as well as image files in TIFF, PNG, JPEG or BMP format.
2. One document, one file: each document must exist as a separate file. A bulk scan of the entire personnel file as a single PDF is not enough.
3. Clear assignment: the file name or filing system must show what type of document it is, which employee it concerns and for what period it applies.
4. Audit-proof storage: the requirements follow the GoBD. Documents must be archived in a tamper-proof way and be readable and analysable at any time for the audit. A loose network folder in which anyone can rename or delete files is not a good foundation for this.
5. Electronic receipt as the goal: the regulator's intention is that employees and authorities should deliver proofs directly in electronic form wherever possible. If you receive paper, you convert it into one of the permitted formats.

Many of these requirements you already know from document filing for financial accounting. What applies there to invoices, we described in our article on digital archiving under the GoBD.

Caution with signed documents

Some declarations require written form, for example the mini-jobber's exemption application or a full old-age pensioner's waiver of exemption from insurance. The following applies here:

• Electronic with a qualified electronic signature: satisfies the written form requirement. You add the document to the payroll records in this form.
• Paper with a signature, digitised with an advanced employer signature: under the Joint Principles, the paper original may then be destroyed.
• Paper with a signature, simply scanned: you must keep the original until the audit for the period concerned has been finally concluded, and if necessary beyond that if other retention rules apply.

For small businesses without a signature solution, this means in practice: scan the document and file the original anyway. That is double filing, but legally safe.

What happens if you do not switch

If documents are missing or not kept properly, the employer bears the consequences. If the audit service cannot trace why a mini-jobber was exempt from compulsory pension insurance or why a working student was treated as exempt from insurance, you face back payments of contributions for up to four years plus late payment surcharges under § 24 SGB IV. For employers who breach their duty to cooperate, administrative offence proceedings under § 111 SGB IV may come into play.

Also important: if you outsource payroll to a payroll bureau or service provider, responsibility for complete payroll records still stays with you as the employer.

Your checklist until the end of the year

1. Take stock: find out how enrolment certificates, health insurer certificates, proof of parenthood and mini-job applications reach you today and where they end up: paper folder, email inbox, desktop, payroll program.
2. Choose a system: check whether your payroll program or your payroll bureau offers a digital personnel file with audit-proof storage. Often the function is already there and simply not used.
3. Define naming and structure: set a uniform scheme, for example personnel number, document type and validity period, and put it in writing. This makes the procedural documentation easier.
4. Digitise the intake channel: ask employees to send proofs as PDFs in future, and change your personnel questionnaires and onboarding documents accordingly.
5. Clarify written-form documents: decide whether you will keep originals or use a signature solution.
6. Plan for recurring proofs: enrolment certificates have to be provided anew every semester. Set a reminder at the start of each semester so that no period is left without proof.

Our conclusion

Keeping payroll records electronically is not a major project if you start now. For a business with a handful of employees, it comes down to a few document types, a clean filing scheme and a digital intake channel. It only gets expensive when, at the next audit, an exemption application or an enrolment certificate is missing. At Buchführungsheld we work fully digitally anyway: documents and proofs arrive by upload or email, are checked and filed in an audit-proof way. All at a fixed price, with no hourly billing. If you want to know what this could look like for your documents, book a free initial consultation.

Frequently asked questions

From when do payroll records have to be kept electronically?

In principle since 1 January 2022. Until 31 December 2026, employers could apply to be exempted. From 1 January 2027, the obligation under § 8 BVV applies without exception to all employers subject to the pension insurance audit.

Does the obligation also apply if I only employ mini-jobbers?

Yes. Mini-jobbers are also subject to the audit. They are precisely the case where typical supplementary documents arise, such as the application for exemption from compulsory pension insurance or the declaration by short-term employees about further employment.

Do I have to scan old paper files retroactively?

No. Retroactive digitisation is not required. The obligation concerns documents from 2027 onwards. You keep older paper documents as before until the retention period has expired.

Which file formats are permitted?

PDF as well as the image formats TIFF, PNG, JPEG and BMP. Each document must exist as its own file and be clearly assignable to one employee and one period.

May I throw away the paper original after scanning?

For documents that require written form, only if you digitise them with an advanced employer signature. Without a signature, you keep the original until the audit has been finally concluded. For all other proofs, check before destroying them whether other retention rules apply, and if in doubt keep the original.

Am I responsible if my payroll bureau does the payroll?

Yes. The duty to keep payroll records properly stays with the employer, even if payroll is outsourced. So clarify with your service provider who requests, checks and files which proofs.