Digital personnel files are increasingly becoming the focus of management and HR managers. Not least due to new legal framework conditions, digital audit procedures and increasing demands for transparency and efficiency, many companies are asking themselves how long paper-based or isolated HR systems will continue to make sense.
This article classifies the legal situation surrounding the digital personnel file from 2026 and shows why the link with digital time tracking in particular is a decisive strategic lever for companies.
Legal situation in 2026: clear development
In 2026, there is still no general legal obligation to manage all personnel files completely digitally. Companies may continue to manage personnel documents in paper form or in hybrid models.
At the same time, a clear trend is discernible:
- Audits by social insurance institutions and authorities are increasingly digital and data-based.
- Legal requirements for documentation and traceability are constantly increasing.
- Exemptions from electronic procedures can only be applied for until the end of 2026.
For managing directors, this means that although there is still room for maneuver legally, this is becoming increasingly limited in operational and strategic terms.
Why the digital personnel file will be de facto indispensable from 2027
From January 1, 2027, documents relevant to remuneration and social security must be available electronically.
This includes payroll data, contribution statements and other remuneration documents relevant to the audit. The central basis is the electronically supported tax audit (euBP), which is carried out by Deutsche Rentenversicherung.
In accordance with Section 28p of the Fourth Book of the German Social Code (SGB IV), employers are obliged to provide audit-relevant pay and employment data electronically for company audits. The German Pension Insurance expressly describes the euBP as a digital procedure in which the required documents and data must be transmitted electronically.
The specific obligation to keep digital records of documents relevant to remuneration also arises from the Contribution Procedure Ordinance (BVV).
According to Section 8 BVV, employers are obliged to keep all documents relevant to social security complete, correct, timely and organized. These documents form the basis for digital verification procedures and must be available electronically from January 1, 2027.
➡️ Against this background, it is clear that a digital personnel file in conjunction with digital time tracking and audit-proof archiving not only makes sense from an organizational perspective, but is also increasingly required by law in order to support audits efficiently and in compliance. Paper files or isolated systems lead to media disruptions, manual coordination efforts and an increased audit and liability risk. An integrated digital solution creates the necessary transparency and traceability.
Four tips you can look out for in the digital personnel file:
1️⃣ Digital time tracking as the basis for audit-proof HR documentation
Digital time tracking forms the basis for numerous personnel and pay-related processes. Recorded working hours, overtime, bonuses and absences have a direct impact on payroll accounting, proof for auditing authorities and documentation obligations under labor law.
If this time data is linked directly to the digital personnel file, a consistent database is created in which all relevant information is available centrally, up-to-date and audit-proof.
2️⃣ Interface to payroll accounting
Ideally, a modern digital personnel file has an interface to payroll accounting. Working time data from digital time tracking flows automatically into payroll accounting, payslips are then stored digitally in the personnel file and made securely available to employees.
This reduces manual intervention, avoids transmission errors and ensures that documents relevant to remuneration are documented completely and comprehensibly at all times. ✅
3️⃣ Keep an eye on deadlines, qualifications and proof of working hours
In addition to traditional documents, a digital personnel file should also be able to manage deadlines and qualifications. In combination with digital time tracking, working time-relevant authorizations and deployment requirements can be systematically monitored.
This includes, for example, expiration dates for first aider qualifications, forklift driver’s licenses or occupational health examinations. Automatic reminder functions support companies in complying with legal requirements and ensuring the proper deployment of personnel.
4️⃣ GoBD-compliant archiving in conjunction with time and remuneration data
Working time records and remuneration documents are regularly relevant for tax purposes. All documents with significance for taxation are subject to the requirements of the GoBD and must be archived completely, unalterably and comprehensibly.
➡️ A digital personnel file in conjunction with GoBD-compliant archiving ensures that both time sheets and payroll-related documents are stored in an audit-proof manner. This makes tax audits, social security audits and internal audits considerably easier.
The digital personnel file, especially in combination with digital time tracking, thus becomes the central foundation of legally compliant, efficient and future-proof HR processes.
Find out more about our solution for the digital personnel file:
