Audit-Proof Email Archiving
"Revisionssicher", usually translated as audit-proof, is not defined in any German statute. It sums up what the Commercial Code, the Fiscal Code and GoBD require from an archive: a tax audit must be able to rely on the archive being complete and unchanged.
Legal basis
- § 239 (3) HGB and § 146 (4) AO: records must not be changed in a way that hides the original content.
- § 257 HGB and § 147 AO: business letters, accounting vouchers and tax-relevant documents are kept for 6, 8 or 10 years.
- GoBD: electronic records are kept in their original format, unalterable, complete and machine-readable.
Five criteria
| Criterion | What it means for email |
|---|---|
| Complete | Every email is captured before a user can delete it |
| Unalterable | Content, headers and attachments stay exactly as received |
| Protected from deletion | Deletion only after the retention period |
| Findable | Every email can be found in seconds for the whole period |
| Traceable | Access and settings changes are logged |
Why mailbox, PST file and backup fall short
In a mailbox, users delete emails with one click, and the trash gets emptied. An Outlook PST file can be opened, edited and copied without a trace. A backup only holds what was there when it ran. None of them meets all five criteria.
How EasyMailArchive works
- Capture in the mail flow. A BCC or journal rule on your mail server sends every email to your relay address
[email protected]the moment it is sent or received. - Original storage. The email is stored unchanged, with a SHA-256 checksum per message.
- Encryption. AES-256 with a separate key per customer, stored in Germany, a separate database per customer.
- No deletion. There is no delete function for single emails. When the retention period you set ends, the system deletes automatically. A legal hold (Business and up) stops that too.
- Log. Every action in the archive is logged. Export the log as CSV.
- Export for the auditor. Original EML, or PDF with checksums.
Setup takes a few steps: create an account, add the relay address to a BCC rule, send a test email. See the setup guide for your system.
Your part
Software alone does not make an archive audit-proof. You need procedural documentation that describes how emails are captured, kept and deleted, and you need to make sure the BCC rule stays active.
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This article summarises the law in general terms and is not legal or tax advice.