Will the digital personnel file be mandatory from 2027? All questions and answers

Time is of the essence. From January 1, 2027, there will be a clear legal obligation: all employers in Germany must keep certain pay and social security records electronically and in a way that can be analyzed by machine. Although the basic obligation to keep electronic records has been in place since January 1, 2022, the previous exemption option expires at the end of 2026. However, a general obligation to keep fully digital personnel files for all personnel documents will not be introduced. Nevertheless, the new regulation requires companies and organizations to make strategically important decisions. This is because keeping paper and digital files in parallel makes little organizational sense and is associated with an increasing compliance risk. Our guide explains what the new legal regulation for digital personnel files means in concrete terms, which requirements must be met from 2027 and how a software solution can be smoothly integrated into existing HR system landscapes.

Stay up to date on human resources and follow ESCRIBA on LinkedIn

Estimated reading time: 16 minutes

What will change from January 1, 2027 – and what won’t?

First of all, an important clarification: In Germany, there is no general legal obligation to keep a personnel file. For employees in the private sector, no law stipulates that a personnel file must exist, let alone that it must be completely digital. Civil servants are an exception, for whom Section 106 (1) of the Federal Civil Service Act (BBG) explicitly prescribes file management.

However, a new legal situation will apply from January 1, 2027. All employers in Germany will then be obliged to keep and store pay records electronically and in a form that can be analyzed by machine. The legal basis for this is Section 8 (2) of the Contribution Procedure Ordinance (BVV) in conjunction with Section 28p SGB IV. The legal basis for this was created by the Seventh Act to Amend the Fourth Book of the Social Code of June 12, 2020 and promulgated by the Fourth Bureaucracy Relief Act (BEG IV) in the Federal Law Gazette on October 29, 2024. The previously possible exemption from the electronic management obligation in accordance with Section 8 (3) sentence 2 BVV ends on December 31, 2026 without replacement.

The specific background to this is the electronically supported tax audit (euBP). This is because the German Pension Insurance is increasingly checking social security-relevant documents in a system-supported and automated manner. From 2027, employers must be able to provide this data digitally and in an auditable format. Paper-based processes will then no longer meet the legal requirements. Hybrid filing (partly paper, partly digital) is also no longer permitted. All documents must be audit-proof, available at all times and machine-readable. This obligation applies across all industries and regardless of the size of the company.

Digitization obligation applies to the following fee documents

With the abolition of the exemption option on December 31, 2026, the electronic management of the following remuneration documents will become mandatory for all employers in accordance with Section 8 BVV.¹

• Documents from which the information required under paragraph 1 sentence 1 no. 3, 9 and 17 is evident
• the work permit issued by the Federal Employment Agency in accordance with Section 15d of the Employment Ordinance or the residence permit issued in accordance with Section 19c (1) of the Residence Act in conjunction with Section 15d of the Employment Ordinance
• the data of the reports submitted
• the data of the notifications transmitted by the health insurance funds that have an impact on the employer’s contribution calculation
• the declaration by the marginally employed person to the employer that exemption from pension insurance is waived
• the application for exemption from compulsory insurance pursuant to Section 6 (1b) of the Sixth Book of the German Social Code, documenting the date of receipt by the employer
• a copy of the minutes in accordance with § 2 of the Verification Act and, for shipping companies, a copy of the employment contract in accordance with § 28 of the Maritime Labor Act
• the declaration of the short-term marginal employee on further short-term employment in the calendar year or the declaration of the marginally paid employee on further employment and, in both cases, confirmation that the employer must be notified of the commencement of further employment
• proof of health insurance cover in accordance with Section 28a (9a) of the Fourth Book of the German Social Code
• a copy of the application pursuant to Section 7a (1) of the Fourth Book of the German Social Code with the documents required by the German Pension Insurance Fund for its decision, its decision pursuant to Section 7a (2) of the Fourth Book of the German Social Code, expert opinions pursuant to Section 7a (4b) of the Fourth Book of the German Social Code and documentation as to which contractors it has provided with a copy of the expert opinion pursuant to Section 7a (4b) sentence 4 of the Fourth Book of the German Social Code
• the decision of the competent collection agency on the determination of the insurance obligation pursuant to § 28h para. 2 of the Fourth Book of the Social Code
• the decision of the tax authorities that the tuition fees paid or assumed by the employer for an employee’s studies do not constitute wages under tax law
• proof of parental status and proof of the number of children to be taken into account in accordance with Section 55 (3) of the Eleventh Book of the German Social Code
• a copy of the declaration on the waiver of payment of entitlements to remuneration,
• the records pursuant to Section 19 (1) of the Posted Workers Act and Section 17 (1) of the Minimum Wage Act
• the certificate pursuant to Section 44a (5) of the Eleventh Book of the German Social Code if employment is interrupted due to receipt of care support allowance
• a copy of the employee’s declaration on taking care leave within the meaning of Section 3 of the Care Leave Act
• for maritime shipping companies, the crew lists and sea logs in accordance with § 22 of the Maritime Labor Act, for inland waterway vessels, the ship’s certificates and for Rhine navigation vessels, a copy of the Rhine navigation affiliation certificate
• the data of the certificates transmitted in accordance with Sections 106 to 106c of the Fourth Book of the German Social Code
• in the case of an application for the conclusion of an exemption agreement, a declaration in which the employee confirms that the conclusion of an exemption agreement for the application of German legislation in accordance with Article 16 of Regulation (EC) No. 883/2004 of the European Parliament and of the Council of April 29, 2004 is in his or her interest
• the declaration of waiver of exemption from insurance pursuant to Section 5 (4) sentence 2 or Section 230 (9) sentence 2 of the Sixth Book of the German Social Code, documenting the date of receipt by the employer
• the employee’s consent at the time of commencement of compulsory insurance due to employment pursuant to Section 127 (1) sentence 1 no. 2 and sentence 2 of the Fourth Book of the German Social Code

Important: The documents must be structured, audit-proof and automatically retrievable at any time.

Why the digital personnel file is practically mandatory

Even if the legal obligation technically only covers remuneration documents, there is a de facto obligation to fully digitize personnel files. The parallel management of paper and digital files creates a double effort: documents have to be filed, maintained and synchronized twice if necessary. This process ties up personnel and creates sources of error. This is not only inefficient, but also entails growing compliance risks.

The digital personnel file is also changing the way HR departments work. Instead of poring through folders, employees can find documents in seconds using a full-text search. Processes such as onboarding, contract changes or certificate creation can be mapped completely digitally. In other words, from automatic document creation to digital approval and audit-proof filing. This significantly reduces throughput times and relieves the burden on both HR teams and managers.

The aspect of data security also speaks clearly in favor of the digital solution: access rights can be controlled on a role-based and granular basis, and every inspection is logged seamlessly. Physical files offer no comparable protection. They can be lost, damaged or viewed without authorization. With a professional ePA solution, companies not only meet the GDPR requirements more reliably, but are also able to provide information at any time during audits by Deutsche Rentenversicherung.

For HR and IT decision-makers, the deadline of 1 January 2027 is therefore not just a compliance event, but the right occasion to strategically tackle the digitization of the entire personnel file – and thus lay the foundation for a more efficient, secure and future-proof HR organization.

Advantages of the digital personnel file at a glance

• Higher employee satisfaction: self-service access to own documents strengthens the employee experience
• Efficiency gains: document access in seconds instead of time-consuming file searches
• Process automation: digital workflows from document creation to filing without media disruptions
• Error reduction: No risk due to duplicate data maintenance in paper and digital formats
• Audit-proof: unchangeable storage with a complete audit trail possible
• GDPR compliance: Automated deletion periods, access logging and data minimization
• Data security: Role-based authorizations protect against unauthorized access
• Tax audit security: documents for euBP that can be analyzed automatically at any time
• Scalability: Flexible file structure grows with the company
• Sustainability: reduction of paper consumption and physical storage costs

What is a digital personnel file and what belongs in it?

The digital personnel file, also known as the electronic personnel file (ePA) or e-file, replaces the traditional paper file with a structured, electronic filing system for all employee-related documents. This includes the following:

• Employment contracts and contract amendments
• Charging documents
• Certificates and proof of qualifications
• Vacation requests
• Working time documents
• Employment law letters and assessments

It is important to note that not every document may be included in the ePA. The GDPR stipulates a strict purpose limitation. As a rule, health data such as medical reports or diagnoses do not belong in the digital personnel file. Private notes or information without a clear connection to the employment relationship are also not permitted.

A powerful ePA solution ensures that documents are stored in a structured manner, provided with metadata and can be found using a full-text search. Role-based access rights guarantee that only authorized persons can access certain content. This is logged in a traceable manner using a complete audit trail.

Legal requirements: GDPR, retention periods and works council

The legal framework for the digital personnel file is complex. Three areas are particularly relevant for companies:

GDPR compliance requires that personal data is only processed for specified purposes, is limited to what is necessary and is automatically deleted as soon as statutory retention periods expire. Data subjects have the right to information, rectification and erasure at any time. A professional ePA solution maps these requirements technically, for example through configurable deletion periods, access logging and data minimization. Depending on the document type, a statutory retention period of at least eight years applies to payroll documents.

Audit-proof archiving means that documents must not be able to be changed at a later date. On the software side, this is achieved via special archive structures or audit trails that document every access and every change without gaps. From 2027, this requirement will no longer be optional for all relevant remuneration documents, but will be a legal requirement.

Works council co-determination: The introduction of a digital personnel file is subject to the works council’s co-determination obligation in accordance with Section 87 (1) No. 6 BetrVG, as the system can potentially be used to monitor performance and conduct. A works agreement negotiated at an early stage that clearly regulates access rights, logging and permitted document types is not a bureaucratic obstacle, but a decisive success factor for a smooth introduction.

Choosing the right digital personnel file: What HR and IT decision-makers should look out for

The market for digital personnel files is broadly diversified. An independent market analysis by the management consultancy “Stephan Boehnke HR Consulting & Training” systematically evaluated a total of 16 providers in 2026 and came to the key conclusion that there is no single best solution for every company. The decision depends less on the scope of functions than on the existing IT architecture, the organizational structure in the HR area and the long-term digitalization strategy.

When selecting software, it is advisable to answer the following questions in advance:

• Which HCM or ERP systems are in use and are they up to date?
• Should the ePA be operated as a stand-alone module or deeply integrated into an existing core system?
• Does data from several source systems have to be processed in parallel, for example in the case of international company structures or after acquisitions?
• Should the HR department be able to make configurations independently in the future without any programming effort?

Once you have answered these questions, you can significantly reduce the requirements profile and evaluate in a more targeted manner.

Find out more in this ESCRIBA article: The best digital personnel file with document storage 2026

Integration of the digital personnel file into existing HCM systems

Technical integration is often the most critical factor when introducing a digital personnel file. Existing HCM systems such as SAP SuccessFactors, Workday or Dayforce act as leading data systems – the ePA must connect seamlessly without creating data redundancies or manual transfer steps.

Depending on requirements, different approaches are available for SAP SuccessFactors environments: natively integrated solutions that remain completely in the SAP stack or specialized ePA modules that are connected via certified interfaces and also cover document creation, process automation and ticketing. The advantage of ePA modules, such as those offered by ESCRIBA with ECAP eFile, lies in their expandability, individual adaptability and compatibility with other HR systems such as Workday, Dayforce and Oracle.

In Workday and Dayforce environments, the selection of suitable providers is smaller. Only a few solutions have native integrations with these platforms. REST APIs and OData interfaces that enable bidirectional data communication are crucial here. Equally important is the ability to transfer authorization models from the leading HCM system.

Companies with multi-system landscapes – i.e. parallel ERP or HCM environments – require ePA solutions that can merge data from different sources without the need for individual programming projects. This is another area where ESCRIBA ECAP eFile comes into its own.

ECAP eFile from ESCRIBA: The digital personnel file for complex system landscapes

With the ECAP eFile, ESCRIBA offers a stand-alone ePA solution based on the company’s own no- and low-code platform and developed for use in demanding, heterogeneous IT environments. The SAP-certified solution has native integrations in SAP SuccessFactors, Workday and Dayforce.

What distinguishes ECAP eFile from generic document management systems is its connection to HR processes. The file is not an isolated filing system, but part of an integrated HR service manager. Document creation, workflow automation and HR ticketing work together without media discontinuity. For example, a contract amendment process can be mapped completely digitally: from the automatically created document to approval via e-signature to audit-proof filing in the ePA, which is triggered by a ticket in the HR ticketing system.

The file structure is fully configurable. Thanks to no/low-code technology, HR managers can independently adapt file types, authorizations, metadata and deletion periods without any programming effort or dependency on the IT department. This applies to standard personnel files as well as specific file types, such as onboarding, secondment or recruiting files.

The compatibility of ECAP eFile in multi-system landscapes is particularly noteworthy: it can process data from several HCM or ERP sources in parallel and merge them into a standardized file structure – a decisive advantage for corporate groups or companies following company takeovers.

The integrated AI functionality supports text analysis and document classification. Retention periods and deletion rules are automated based on rules and in compliance with the GDPR. Access rights can be assigned based on time, document type or any other properties and thus also meet the stricter requirements for the electronic management of remuneration documents from 2027 in accordance with Section 8 BVV.

How to migrate without breaking the system

The introduction of the digital personnel file is a project that requires structured planning in order to be successful. The following steps have proven successful in practice:

• As-is analysis of the IT landscape: Which systems are in use? – Which interfaces already exist? Are the release statuses up-to-date enough for integration? – Which remuneration documents are still in paper form and must be transferred digitally by January 1, 2027?

• Involve the works council at an early stage: A jointly developed works agreement speeds up the introduction considerably and creates acceptance on both sides.

• Step-by-step migration instead of big bang: first, new employment relationships are managed completely digitally. Existing files are then prioritized for digitization – with duplicate checks, indexing by personnel number and document type, and consistent compliance with retention periods. Priority will be given to the legally required remuneration documents from 2027.

• Training and change management: The introduction will only be successful if HR employees, managers and, where planned, self-service employees can handle the new system with confidence.

• Technical security: Access rights must be clearly defined and regularly checked. Backups and emergency concepts are just as necessary as two-factor authentication for system access. For the payroll documents that will be legally required from 2027, it must also be ensured that the filing system can be analyzed automatically and that it can be retrieved at any time for audits by the German Pension Insurance.

Conclusion: Partial legal obligation, overall strategic opportunity

January 1, 2027 marks a clear regulatory change, but one that is often misunderstood. There is no general legal obligation to keep fully digital personnel files in Germany. However, from 2027, the electronic, machine-readable management of remuneration documents will be mandatory in accordance with Section 8 BVV in conjunction with Section 28p SGB IV. This applies across all sectors and without exception.

However, anyone looking at this obligation in isolation is falling short. The organizational reality in HR departments hardly allows for a clean separation between mandatory digital remuneration documents and other personnel documents that are still kept on paper. This creates considerable additional work and a growing potential for errors. The deadline is therefore less a narrowly defined compliance event than a sensible reason to systematically tackle the digitization of the entire personnel file.

For HR and IT decision-makers, this means that the question is not whether, but with which solution and at what speed the changeover will take place. Choosing the right software is not a purely functional decision. The architecture, the depth of integration and the ability to integrate into existing HCM system landscapes such as SAP SuccessFactors, Workday or Dayforce are crucial. The same applies to the flexibility to adapt the digital personnel file to company-specific requirements without any programming effort. Solutions such as the ECAP eFile from ESCRIBA are designed precisely for this requirement. They also work in complex, heterogeneous system landscapes.

Companies that act now and select the right digital personnel file not only meet the legal requirements that will apply from 2027, but also lay the foundation for a permanently more efficient, transparent and future-proof HR organization. This does not require a legal obligation to have a digital personnel file.

More on this topic

• Digital personnel files in companies – comprehensive guide with all the important information and tips
• Rethinking the digital personnel file with ESCRIBA NLC technology
• The personnel file as an ideal introduction to digital HR processes
• E-file
• The best digital personnel file with document storage 2026