From 1 January 2027, no employer in Germany can be exempted any longer: you keep the documents listed in § 8 para. 2 BVV electronically and hand them over on request to the audit service of the German Pension Insurance (DRV). These include, for example, certificates of enrolment, A1 certificates, work permits, and the application for exemption from pension insurance obligation for mini-jobs.
Good to know
Documents are not transmitted through the electronically supported audit (euBP). You only hand them over to the auditor on request, in the way you agree on with them.
You do not need to digitize paper records from before 2022 retroactively. If your company was exempted, this applies to records from before 2027.
If the DRV announces an audit, you or your payroll provider submit the payroll and accounting data (euBP) from audit-proof software, for example DATEV.
How Kenjo supports you with Smart Docs (planned from Dec 2026)
Activate BVV once: An admin turns it on, and Kenjo creates a BVV area and a starter set of tags/labels that only HR can see.
Mark tags as “BVV-relevant”: This also applies to documents you have already uploaded. Add the period for each document, individually or for many at once.
Keep documents of former employees: While BVV is active, documents with a BVV tag stay in Kenjo until the end of the fifth year after the employee leaves, even if you delete the employee.
Review everything in one place: all BVV documents, including those of former employees.
Download for the audit: per employee (from December 2026), then per company and audit period (from January 2027).
File names: You do not need to rename your existing files. On download, Kenjo generates file names according to the DRV’s rules, based on document type, name, and period (for example “immatrikulation-mustermann_max-2026-10_2027-03.pdf”), and adds an overview table with all documents. The tag name becomes the document type, so choose unambiguous tag names.
What you can do now
Deactivate employees who have left instead of deleting them. If you delete an employee today, you also delete their documents.
Use one clearly named tag per BVV document type.
Upload each document as its own file.
Keep the paper originals of signed forms (for example, the exemption application for mini-jobs) if there is no qualified electronic signature.
Ask your payroll provider or tax advisor to confirm that the euBP data is being transmitted.
Questions? Just write to our support via chat. We are happy to help.
This article contains product information, not legal advice. Your tax advisor can confirm how the rules apply to your company.
As part of an electronically supported audit, you can electronically transmit the audit-relevant data from your payroll and accounting software. The aim is to support the audit with this data by machine and to reduce the effort of a conventional audit for everyone involved.
Electronically supported audit (euBP)