Replacement Scanning in Germany: Scan Receipts, Destroy Paper

Binders full of paper receipts take up space, and finding anything in them is hard. The answer is replacement scanning (ersetzendes Scannen): you scan the receipt, archive the scan and destroy the paper. German law allows this, but only under conditions. This guide explains which ones, and how to meet them with little effort.

What is replacement scanning?

With replacement scanning, the scan replaces the paper original. The paper is destroyed after scanning; in a tax audit only the digital copy counts. The alternative is scanning “alongside”, where you keep the paper as well.

The legal basis is section 147(2) of the German Fiscal Code (AO): most records that must be retained may be kept as a reproduction on a data carrier. How exactly is set out in the GoBD (paragraphs 136 ff.).

The requirements

1. Visual match. The scan must match the original when made readable. Everything must be visible: text, stamps, handwritten notes, including the back if there’s something on it.
2. Completeness. Every page is scanned; none gets lost.
3. Immutability. The scan is archived so it can’t be changed or deleted unnoticed.
4. Documented process. Who scans what, when, and how is it checked? That’s in your scanning instructions, part of your procedural documentation.
5. Promptness. Documents are scanned and captured promptly.
6. No original required. The document isn’t one that must be kept as an original.

Originals you must not destroy

• Annual financial statements (balance sheet, profit and loss account)
• The opening balance sheet
• Documents where the original has its own evidential value, such as deeds, notarised contracts or documents you need in the original for customs or courts

When in doubt, ask your tax adviser before destroying paper.

Scanning instructions: what goes in

Scanning instructions are usually one or two pages:

• Who may scan? Names or roles, with deputies.
• When? For example daily after the mail arrives.
• With what? Device, resolution (e.g. 300 dpi), colour or greyscale, file format (PDF or TIFF).
• What? Which document types, and which stay as originals.
• How is it checked? For example a visual check of every page for legibility and completeness.
• Where is it archived? Which system, which cabinet.
• When is paper destroyed? For example after the check and the booking, or after a fixed waiting period.

TR-RESISCAN: mandatory or not?

TR-RESISCAN (BSI TR-03138) is a technical guideline of the German Federal Office for Information Security. It describes a very thorough scanning process and is often mentioned together with replacement scanning. German tax law doesn’t require it. For small companies, a documented, consistent process with quality checks is enough. TR-RESISCAN is still a good reference when you write down your process.

Archiving receipts after scanning

A scan is only worth as much as the archive it’s in. A folder on a network drive usually isn’t enough, because any file there can be overwritten unnoticed. What an archive must do is explained in GoBD-compliant archiving.

With Papermerge it works like this:

1. Scan to PDF or TIFF. Many scanners can email the scan directly to the email address of your cabinet.
2. Choose the category and enter the metadata: supplier, date, amount. Papermerge doesn’t read text from images (no OCR). The metadata still makes the document searchable and machine-evaluable.
3. Check and archive. Once archived, the scan can’t be changed, is protected with a checksum and can’t be deleted before the end of its retention period.
4. Destroy the paper as your scanning instructions say.

Papermerge is not certified under TR-RESISCAN. It takes care of archiving; you describe the scanning process itself in your scanning instructions.