7. Immutability
What does this mean? Once archived, documents and postings must not be subsequently altered or deleted. Corrections are only permissible through new postings (reversal + new posting) that keep the original content identifiable.
Practical implementation: Use an archive system that protects documents against changes after storage, using hash values, write protection, and versioning. Ensure that even administrators cannot delete documents.
Common mistake: Documents are stored on a file server where any user with write permissions can modify or delete files.
8. Machine Readability
What does this mean? Archived data must be machine-searchable, filterable, and evaluable. The tax authority must be able to perform its own evaluations during a tax audit.
Practical implementation: Perform OCR text recognition on all documents. Provide structured export options (CSV, XML, IDEA). Ensure that metadata such as date, amount, and business partner are captured electronically.
Common mistake: Scanned documents are archived as pure image files without OCR. Or: the system offers no export function for the auditor.
9. Data Backup
What does this mean? Archived data must be protected against loss. This includes regular backups, protection against physical damage (fire, water), and protection against cyber attacks.
Practical implementation: Implement a 3-2-1 backup strategy: 3 copies of the data, on 2 different media types, with 1 at an off-site location. Regularly test the recoverability of backups. Document backup procedures.
Common mistake: Backups are created but never tested for recoverability. Or: all data copies are located at the same physical site.