The Accounting Data Interfaces Regulation (DSFinVBV): Useful or superfluous?

The proposed Accounting Data Interface Regulation (DSFinVBV) is intended to further standardise digital tax audits. But does a new, uniform interface standard really deliver the expected added value for the tax authorities and businesses, or does it primarily create additional work? The Federal Chamber of Tax Advisers has a clear view on this matter. The Chamber published its detailed critique of the draft regulation on LinkedIn. Tax adviser Torsten Stockem, a TCMS expert and partner at the law firm Energiesozietät, broadly shares this critique.

He explained to Paul Liese in our live programme „hsp live at 11“ why he takes a critical view of the Ministry of Finance’s draft regulation and which aspects he takes issue with. Paul sparked a lively discussion by adopting the position of the Ministry of Finance and the tax authorities. In this article, we have summarised the key arguments for you. You can also read about the practical problems posed by the regulation and specific recommendations for action for businesses and tax advisers.

Section 147b of the German Fiscal Code (AO) established the legal basis for a standardised accounting data interface. The aim is for all businesses to provide their data in a standardised format so that the authorities’ audit software can automatically detect all types of anomalies. Critics point out that there are already plenty of sets of rules and regulations in place, such as the GDPdU and GoBD, and that the e-balance sheet also provides structured data. Another regulation would only cause even more chaos, rather than promoting the enforcement of existing rules.

Tax adviser and TCMS expert Torsten Stockem is familiar with the perspective from his experience in consultancy practice. As an experienced adviser to a wide variety of companies, he wonders why the tax authorities do not first enforce the existing rules. New regulations would simply drive up costs and create further barriers. hsp managing director Paul Liese takes the side of the tax authorities in the live broadcast. Accordingly, he challenges the criticism levelled by Torsten Stockem and the Federal Chamber of Tax Advisers.

Torsten Stockem shares the Federal Chamber of Tax Advisers’ criticism of the draft DSFinVBV. In his view, many audit processes are already functioning in practice today: auditors and accountancy professionals import accounting data, map accounts and carry out analyses. In the case of companies that are audited regularly, this even leads to economies of scale. At the same time, he warns that additional regulatory requirements could lead to greater administrative burdens for companies and tax firms, the costs of which would ultimately be borne by taxpayers.

He also points out that existing tools such as the e-balance sheet, with its taxonomies, have so far scarcely been used for comprehensive sector comparisons or automated audit analyses. Added to this is the fact that legislation, detailed regulations and technical implementation often take several years – at a time when technologies such as AI are developing at a rapid pace. Finally, Torsten points to the great heterogeneity of sectors and charts of accounts: a standardised chart of accounts is simply not practicable for many companies.

Paul Liese, speaking on behalf of the authorities, notes that without standards, the workload involved would be impossible to manage. In the case of till systems, for example, the structured export format (DSFinV-K) has ensured clarity. There are around 120 to 130 different point-of-sale software providers. Without a standard, auditing would be utter chaos – and therefore an impossibility for the audit software. Furthermore, technical security features (TSE) also demonstrate how regulation can make manipulation more difficult.

The major areas for improvement that are often overlooked:

• Document management and emails: Many companies archive business-related emails in a decentralised manner (Outlook inbox, etc.) rather than in a document management system (DMS). This makes it more difficult to meet audit requirements relating to business correspondence or documentation obligations.
• Ancillary systems: Merchandise management or sector-specific systems generate tax-relevant documents, but often do not meet the GoBD requirements. These „streamlined“ systems are frequently susceptible to manipulation and are therefore a key focus of audits.
• Lack of procedural documentation: Not all companies have up-to-date system and archiving documentation that provides auditors with quick answers.

Despite all the criticism, Paul asks Torsten whether there might also be advantages to greater standardisation. As a TCMS expert, Torsten assumes the existence of a functioning Tax Compliance Management System, ideally with a documented internal control structure. This would allow audits to be carried out more quickly and result in less stress for the audited companies.

Whether the Ministry of Finance reconsiders its position or implements the draft as it stands, we recommend that you take the following steps straight away:

1. Creating or updating procedural documentation: Describe processes, systems and responsibilities, particularly with regard to email archiving and document management systems (DMS).
2. Implementing a DMS and archiving policies: Define which emails and documents should be stored in the DMS and how staff should classify them.
3. Check auxiliary systems: Ensure that your stock management, industry-specific software and invoicing systems comply with GoBD. Where necessary, have audits carried out by a third party.
4. Documenting chart of accounts mapping: Once you have created a mapping for the test software, you will save a lot of time on subsequent tests.
5. Setting up TCMS/IKS: An effective compliance system can simplify audits and, where appropriate, lead to simplified procedures or faster financial statement preparation processes.
6. Stay pragmatic: Make better use of existing data (e.g. E-Bilanz) before embarking on new, large-scale implementations.
7. Communicating with software providers: Clarify at an early stage how interfaces will be implemented technically and whether any updates are planned.

The idea of a standardised accounting data interface undoubtedly has advantages, particularly in the case of standardised systems that are susceptible to manipulation, such as till systems, or when seeking to automate audit processes. From a consultancy perspective, however, many questions remain unanswered: Will the additional effort justify the expected revenue? Are existing data streams (e-balance sheets, accounting data) not already sufficiently usable? And is now the right time to commit to new requirements on a large scale, whilst AI models and audit software are developing at a rapid pace?

Critics understandably point out that, before new, comprehensive rules are introduced across the board, businesses and the tax authorities should first make better use of existing data sources and documentation requirements and get their affairs in order. At the same time, it is worth companies tackling this work now. Document management systems (DMS), procedural documentation and GoBD compliance of ancillary systems are tangible steps that can already significantly simplify audits today.

Find out more now about the Tax Compliance Management System (TCMS) with Opti.Tax: