Made with love by this nice team. Become part of it
ComplianceDigitalisierung
9 min read

Digital Personnel File & euBP 2027: Obligations for Employers

Digital personnel file from 2027: what the euBP requires of employers, which records are affected – and what you should do now.

Content

Key Takeaways

From 2027, there is no general statutory obligation to maintain a fully digital personnel file. However, certain payroll and social insurance records that employers must manage electronically — or provide digitally as part of the electronically supported company audit, known as the euBP — are becoming mandatory.

The requirements apply in principle to all employers who have employees, process payroll and are subject to audits by the German Pension Insurance (Deutsche Rentenversicherung). Company size is not a deciding factor.

For HR and payroll teams this means: documents must be digitally available, structured, traceable and audit-ready. The digital personnel file is becoming the operational standard for many organisations.

What changes from 2027 with the euBP?

The electronically supported company audit (euBP) is the digital audit procedure of the German Pension Insurance (Deutsche Rentenversicherung, DRV). Employers provide audit-relevant data electronically so that DRV company audits can be carried out more efficiently.

2023
Audit-relevant data from certified payroll systems is transmitted electronically
2025
Also applies to data from financial accounting
until 2026
Transitional exemptions still in place
from 2027 (current)
Transition period ends – records must be kept and provided electronically

From 1 January 2027, the transition period ends. Employers should by then be able to manage relevant payroll and social insurance records electronically and provide audit-relevant data in digital form.

Anyone still managing records on paper, in hybrid systems or in an unstructured way will face significantly greater effort when an audit takes place.

Which companies does the regulation apply to from 2027?

The requirements around the euBP and electronic payroll records apply in principle to all employers who have employees, process payroll and must maintain records relevant to social insurance law. What matters is not the size of the company, but the employer role.

This means that small and medium-sized businesses, larger organisations, companies with multiple locations, and companies with in-house or outsourced payroll should all check whether their document processes are prepared for the digital requirements.

Which records are affected?

The focus is on records relevant to payroll processing, social insurance and company audits.

General internal correspondence or purely organisational documents are treated differently from records with a direct connection to pay, contributions or social insurance assessment.

Organisations should therefore know which records they hold, where they are stored, who is permitted to access them and how they can be provided if an audit takes place.

Why the digital personnel file is becoming increasingly important

The digital personnel file is more than a digital archive. It creates the organisational foundation for managing personnel documents centrally, in a structured and traceable way. Digital audit processes require that relevant information does not first have to be searched for, scanned or pieced together from different systems.

A digital personnel file helps organisations to

  • store documents centrally and in a structured way
  • manage access rights clearly
  • keep sensitive personnel data secure
  • reduce search and administrative effort
  • avoid media breaks between HR and payroll
  • provide audit-relevant records more quickly
  • document processes in a traceable manner

This makes it an important building block for efficient, secure and future-ready HR operations.

Benefits of a digital personnel file for HR and payroll

Central storage instead of scattered documents

A digital personnel file consolidates relevant documents in one defined place with clear filing structures – instead of paper files, network drives and email inboxes.

Faster availability during company audits

Records can be provided more quickly and internal preparation time is reduced. This takes pressure off HR and payroll teams and improves process reliability.

Clear permissions for sensitive personnel data

Who can view, edit or delete which documents? Access can be managed by role and personnel documents can be controlled precisely.

Foundation for modern HR processes

It connects document management, processes, permissions and data structures – the basis for onboarding, contract management, certificate handling and self-services.

What organisations should prepare now

Organisations should use the time until 2027 to systematically review their HR and payroll document processes. A useful starting point is a stocktake:

Stocktake — Key questions
  • 01
    Which personnel and payroll records are currently being maintained?
  • 02
    Which documents are already held digitally?
  • 03
    Which records still exist in paper form?
  • 04
    Where do media breaks occur?
  • 05
    Which systems are involved?
  • 06
    Who is responsible for filing, maintaining and providing documents?
  • 07
    Which permissions are required?
  • 08
    Which documents are relevant for payroll, social insurance and audits?
  • 09
    How can records be managed in a traceable and secure way?

On this basis, it is possible to determine which documents should be prioritised for digitalisation, what filing structure makes sense and how the digital personnel file can be integrated into existing HR and payroll processes.

Why organisations should not wait until the end of 2026

Introducing a digital personnel file is not a pure IT project. It affects processes, responsibilities, permissions, data quality, paper records and the collaboration between HR, payroll, managers and external service providers.

Organisations that only start shortly before 2027 often end up digitalising under time pressure. Starting early instead allows for a structured approach:

  1. Analyse the existing document inventory
  2. Identify relevant payroll and social insurance records
  3. Define the filing structure
  4. Create a permissions concept
  5. Prioritise and digitalise paper records
  6. Integrate HR and payroll processes
  7. Involve employees and those responsible

This creates not just a preparation for 2027, but a long-term foundation for digital HR operations.

Checklist: What organisations should prepare now

This checklist is deliberately written as an implementation roadmap. It does not repeat the benefits — instead, it turns the compliance topic into a plannable project, with eight work packages across four phases, each with a verifiable deliverable, an owner and a due date.

Checklist 2027 — 4-Phase Implementation Roadmap

PDF · 2 pages · Free
8
work packages
4
project phases
1
shared target picture
Jan 1
2027 deadline
  • 1
    Set up the project Define the project team, responsibilities, budget and milestones through go-live.
  • 2
    Clarify the current state Inventory documents and define the target structure and filing plan, including retention and deletion logic.
  • 3
    Implement the solution Select the system, clarify data protection and permissions, and migrate legacy files.
  • 4
    Secure operations Test workflows and euBP audit-readiness, train the rollout, and establish controls for stable operations.

Turn the 2027 obligation into a project plan.

All 8 work packages with deliverables, ownership and due dates, plus the 2027 readiness check — as a PDF to check off with your project team.

The role of HR software in the digital personnel file

A digital personnel file should not be viewed in isolation. Its full value only emerges when it is seamlessly integrated into a modern HR system landscape and connects HR processes in a meaningful way.

Helix eAkte by Perbility

Managing personnel documents centrally, structurally and securely

The Helix eAkte turns the digital personnel file into an active part of daily HR operations: with clear responsibilities, traceable workflows, secure permissions concepts and tight integration with adjacent HR and payroll processes.
Discover Helix eAkte Book a demo

Conclusion: Preparing strategically for the digital personnel file from 2027

From 2027, requirements for digital, audit-ready payroll and social insurance records are increasing. For employers, structured digital document management is therefore becoming significantly more important in practice.

What matters is not company size but the employer role. Anyone who has employees, processes payroll and must maintain social insurance-relevant records should review their own processes now. The digital personnel file reduces manual effort, avoids media breaks and creates greater reliability in HR and payroll processes.

Last updated: July 2026

FAQ: Digital personnel file & euBP from 2027

euBP stands for electronically supported company audit (elektronisch unterstützte Betriebsprüfung). Audit-relevant data for company audits by the German Pension Insurance is provided and processed electronically.
The requirements apply in principle to all employers who have employees, process payroll and must maintain records relevant to social insurance law. Company size is not the deciding factor.
Smaller employers should also check which payroll and social insurance records they are required to maintain and how these can be made available electronically from 2027. What matters is the employer role.
Section 7 BVV is a key legal reference point for payroll records. It helps to place the discussion about a digital personnel file in 2027 in its legal context: the focus is not on every HR document, but primarily on payroll and social insurance-relevant records that must be maintained in an auditable form and made available when required.
Records that should be available digitally are in particular those relevant to payroll processing, social insurance and company audits. These can include payroll records, proof of insurance obligations, notification data, certificates and other payroll-relevant documents.
Key requirements include purpose limitation, data minimisation, role and permissions concepts, logging, secure storage, clear deletion processes and a documented retention policy. Sensitive personnel data must not be stored indefinitely simply because it is digitally available.
There is no single retention period for the personnel file as a whole. Depending on the document type, six-year or ten-year tax and commercial law periods as well as special social insurance retention rules may apply. Organisations should therefore create a retention matrix by document category.
The absence of a fully digital personnel file does not automatically result in a penalty. However, problems arise if audit-relevant payroll or social insurance records cannot be provided completely, traceably or on time during an audit. This can lead to additional audit effort, queries, rework and — depending on the individual case — legal or financial consequences. Data protection breaches may also give rise to GDPR-related risks.
A digital personnel file creates a central and structured foundation for personnel documents. It makes audit-relevant records easier to provide, reduces search effort, improves permissions concepts and supports efficient HR and payroll processes.
Organisations should not wait until the end of 2026. The transition affects not only technology but also processes, permissions, existing paper records, retention periods, data protection and responsibilities. Starting early reduces time pressure and the need for rework.

Disclaimer: This article does not claim to be complete and does not constitute legal advice. For the specific implementation of the new requirements within your organisation, legal advice should be obtained where necessary.

More interesting articles