BVV requirements for 2027

An important transitional rule under social security law ends on 1 January 2027

Employers have generally been required to keep certain remuneration records electronically since 2022. Until now, they have been able to apply for an exemption from this requirement. This option ends on 31 December 2026. From 1 January 2027, employers who were previously exempt must also keep the records concerned electronically.

Employers need to take action now

This is not simply a matter of scanning paper records or storing documents electronically. The relevant remuneration records must be kept electronically, be complete and traceable, and be clearly assigned to the employees concerned. They must also be available for a company audit.

What does this mean in practice?

In particular, employers should ensure that the relevant remuneration records:

  • are available electronically,
  • are complete and legible,
  • can be clearly assigned to the employees concerned,
  • are stored in accordance with the applicable statutory and procedural requirements, and
  • can be made available electronically for a company audit.

The deadline of 1 January 2027 does not, by itself, require employers to digitise all older paper records retrospectively.

Who is affected?

The requirements generally do not depend on the size of the company. They may therefore apply to both large and small employers. Special rules apply to employees in private households.

Don’t confuse electronic remuneration records with euBP

Keeping remuneration records electronically and the electronically assisted company audit (euBP) are separate requirements. Electronic remuneration records concern the proper maintenance and retention of specific records, while euBP concerns the electronic provision of data for a company audit. Having a functioning euBP process therefore does not automatically mean that the requirements for keeping remuneration records electronically have also been met.

We’re here to help

Get your assessment now

If you can’t answer “Yes” with confidence to every question, we recommend reviewing your current processes before the end of the year.

Your answers will help us identify in good time whether any organisational or technical action may be needed before year-end.

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Michael Schäfer
Michael Schäfer
Partner

What solutions are available?

The right solution depends largely on your existing HR and payroll systems.
DATEV Personal Personio as an example of an integrated HCM system Existing human capital management (HCM) systems

A lean solution for DATEV clients

  • Digital document exchange and a structured digital personnel file.
  • Audit-proof archiving via the DATEV Cloud.
  • Digitisation without a major system overhaul.
  • Particularly well suited to a simple, cost-effective implementation.

Digitise HR processes end to end

  • Centralised management of employee data and personnel documents.
  • Digital HR processes, such as absences, working hours and workflows.
  • A structured link between HR processes and your existing payroll system.
  • Ideal for companies that want to further digitise their HR operations while meeting BVV requirements.
  • Grant Thornton can support the implementation of Personio and its integration with your existing HR and payroll processes.

Make targeted use of the solutions you already have

  • No system change is required.
  • Review existing HR, payroll and document management systems for BVV compliance.
  • Make any necessary adjustments where needed.
  • Grant Thornton can support the review and implementation.

Our experts

Michael Schäfer

Partner
Duesseldorf  Office
View full profile

Sophie Römer

Payroll Manager
Leipzig  Office
View full profile

    Frequently asked questions about the BVV requirements for 2027

    The requirement to keep certain remuneration records electronically has been in place since 2022. However, the option to obtain an exemption ends on 31 December 2026.

    From 2027, there will be no further extensions: employers must have the necessary processes in place to provide the required records electronically.

    The requirement applies regardless of company size, industry or number of employees. Small businesses must also meet all the requirements. Employees in private households are excluded.

    A wide range of documents are affected, including evidence of social security coverage or exemption, declarations relating to mini-jobs, certificates of posting and other documents relevant to social security.

    Employers should check early which documents are affected and where they are currently stored.

    Simply scanning the documents is not enough. They must be complete, legible, clearly assigned and available at all times. There are also specific requirements for file formats, document storage and retention.

    Companies therefore need a reliable digital process—from capturing documents to making them available for audits.

    Records must be complete, traceable and clearly assigned to the employees concerned. Throughout the statutory retention periods, they must be available at all times and readable without delay.

    Disorganised filing systems and missing records can cause significant problems during audits.