Free template · Excel & PDF
As of 4 October 2026 · German accounting vouchers 8 years
GDPR Deletion Concept Template with Retention Periods
A deletion concept defines which personal data is deleted when – and how you prove it. Download our EU template as an Excel file: deletion classes, triggers, owners, deletion method, a deletion log – and columns for the periods and legal basis under your national law. Plus a version with German periods, a verified retention table for Germany and a calculator for the earliest deletion date.
XLSX · 25 KB · no sign-up · periods to add under your national law
For companies under German law: version with German retention periods (XLSX · 26 KB)- 7 example deletion classes, usable EU-wide
- Sheet for the deletion log
- Second version with German HGB and AO periods
- Dropdowns for period, trigger, method
Retention schedule
Demo Organisation Ltd · Template preview
- DC-01Accounting vouchers8 yearsYear end
- DC-02Annual accounts10 yearsYear end
- DC-03Business letters6 yearsYear end
- DC-05Applications6 monthsRejection
Deletion log
15/01/2026 · DC-01 · vouchers 2017 · destroyed
7 example rows · 150 empty rows with dropdowns
In short
A deletion concept is an overview that sets out, for each type of personal data, how long it is kept, when the period starts, who deletes it and how the deletion is evidenced. It puts storage limitation (Art. 5 GDPR) and the duty to erase (Art. 17 GDPR) into practice. Statutory retention periods – in Germany, for example, 8 years for accounting vouchers – take precedence over deletion.
Basics
What a deletion concept is – and why you need one
The GDPR does not allow personal data to be kept "just in case". Under the principle of storage limitation, data may only be kept in a form that permits identification of data subjects for as long as necessary for the purposes of processing (Art. 5(1)(e) GDPR). Once the data is no longer necessary for the purpose, the controller must erase it without undue delay (Art. 17(1)(a) GDPR) – even if nobody asks.
A deletion concept turns this principle into rules you can apply. It assigns each data type to a deletion class and records what the data is for, which period applies and why, from which event the period runs, who is responsible for deletion, how it is deleted and how this is documented. The term "deletion concept" is not in the GDPR. But without such a document you can hardly demonstrate storage limitation – and under accountability (Art. 5(2) GDPR) you have to.
The deletion concept is closely linked to other obligations. In the records of processing activities you should, where possible, state the envisaged time limits for erasure of the different categories of data (Art. 30(1)(f) GDPR). In privacy notices you must tell data subjects the storage period or the criteria used to determine it (Art. 13(2)(a), Art. 14(2)(a) GDPR). And when someone asks for their data to be erased, you need a quick answer on which data you must keep where and for how long.
Statutory retention obligations take precedence over deletion. Art. 17(3)(b) GDPR exempts processing necessary for compliance with a legal obligation. In Germany the key obligations are in Section 257 HGB (Commercial Code) and Section 147 AO (Fiscal Code): books and annual accounts 10 years, accounting vouchers only 8 years since 1 January 2025, business letters 6 years. During this time the data is not deleted but blocked: taken out of active use and only used for the retention purpose. Other countries have their own periods – the table below covers German law.
A deletion concept is not a one-off document. New systems, new data types and changes in the law – such as the shorter period for accounting vouchers introduced by Germany's Fourth Bureaucracy Relief Act – call for regular review. A fixed annual date on which periods are checked and due deletions carried out and logged works well.
- for accounting vouchers since 1 Jan 2025 (Section 147 AO, Section 257 HGB)
- 8 years
- for accounting vouchers since 1 Jan 2025 (Section 147 AO, Section 257 HGB)
- for books, inventories, annual accounts
- 10 years
- for books, inventories, annual accounts
- for business letters
- 6 years
- for business letters
Retention table
German retention periods 2026: what is 10, 8 and 6 years
The main statutory periods for companies in Germany, checked against the statutory text. The last three rows are not statutory retention obligations but common internal decisions or a minimum period – this is marked in each case.
Scroll the table sideways →
| Documents | Period | Legal basis | Start of period | Note |
|---|---|---|---|---|
| Books and records, inventories, opening balance sheet, annual financial statements, management reports, group accounts and the work instructions and organisational documents needed to understand them | 10 years | Section 257(1) no. 1, (4) HGB; Section 147(1) no. 1, (3) AO | End of the calendar year | Unchanged by the Fourth Bureaucracy Relief Act. |
| Documents under Art. 15(1) and Art. 163 of the Union Customs Code | 10 years | Section 147(1) no. 4a, (3) AO | End of the calendar year | Tax law only (AO). |
| Accounting vouchers: invoices, bank statements, receipts, till receipts and other records for bookings | 8 years | Section 257(1) no. 4, (4) sentence 1 HGB; Section 147(1) no. 4, (3) AO | End of the calendar year | Since 1 Jan 2025 (previously 10 years) for all vouchers whose period was still running on 31 Dec 2024 (Art. 97 Section 19a(2) EGAO). |
| Accounting vouchers of credit institutions, insurers and securities institutions | 10 years | Section 257(4) sentence 2 HGB; Art. 97 Section 19a(3) EGAO | End of the calendar year | Exempt from the reduction. |
| Business letters received and copies of letters sent (including business emails) | 6 years | Section 257(1) nos. 2, 3, (4) HGB; Section 147(1) nos. 2, 3, (3) AO | End of the calendar year | If a letter is also an accounting voucher, 8 years apply. |
| Other documents insofar as they are relevant for taxation | 6 years | Section 147(1) no. 5, (3) AO | End of the calendar year | |
| Delivery notes that are not accounting vouchers | until invoice | Section 147(3) sentences 3 and 4 AO | – | Received: until the invoice arrives; sent: until the invoice is sent. |
| Payroll accounts | 6 years | Section 41(1) sentence 9 EStG | End of the year of the last wage payment | Until the end of the 6th calendar year after the last recorded wage payment. |
| Logs of high-risk AI systems kept by the deployer | at least 6 months | Art. 26(6) AI Act | Generation | Minimum, not maximum; for Annex III systems from 2 Dec 2027. Applies EU-wide. |
| Contract data without voucher character after the contract ends (e.g. warranty correspondence) | often 3 years | Based on the regular limitation period, Sections 195, 199 BGB | End of the year the claim arose | No retention obligation – internal decision with a rationale. |
| Applications after rejection | often 6 months | Based on Section 15(4) AGG (2 months) and Section 61b(1) ArbGG (3 months) | Receipt of the rejection | No retention obligation – common practice; talent pool only with consent. |
- Periods under Section 147 AO do not end insofar and as long as the documents are relevant for taxes whose assessment period has not yet expired (Section 147(3) sentence 5 AO). If in doubt, check with your tax adviser before destroying documents.
- The list is not exhaustive. Sector-specific obligations – for example in healthcare, occupational safety or financial services – apply on top. Shorter periods under other laws do not affect the tax periods (Section 147(3) sentence 2 AO).
New since 2025
Accounting vouchers: 8 instead of 10 years – what that means
With the Fourth Bureaucracy Relief Act (Federal Law Gazette 2024 I no. 323), the German legislator reduced the retention period for accounting vouchers in Section 257(4) HGB and Section 147(3) AO from ten to eight years. The new period has applied since 1 January 2025 to all documents whose period under the old law had not expired by 31 December 2024 (Art. 97 Section 19a(2) EGAO).
The periods for books, inventories, opening balance sheets, annual financial statements and management reports (still 10 years) and for business letters (still 6 years) were not reduced. Credit institutions, insurers and securities institutions keep accounting vouchers for ten years (Section 257(4) sentence 2 HGB, Art. 97 Section 19a(3) EGAO).
Many deletion concepts and templates in circulation still say ten years for invoices. Check your deletion classes: keeping vouchers longer than required means storing personal data – for example on invoices to private customers – without a reason.
Example: when may accounting vouchers be destroyed?
- Vouchers from 2016Period ended under the new law on 31 Dec 2024 → may be destroyed since 1 Jan 2025
- Vouchers from 2017Period ended on 31 Dec 2025 → may be destroyed since 1 Jan 2026
- Vouchers from 2018Period ends on 31 Dec 2026 → may be destroyed from 1 Jan 2027
- Vouchers from 2026Period ends on 31 Dec 2034 → may be destroyed from 1 Jan 2035
In each case subject to Section 147(3) sentence 5 AO (open assessment period) and different rules for banks, insurers and securities institutions.
Interactive
Period calculator: when may data be deleted?
Pick a data type and enter the relevant date. The calculator shows the start and end of the period and the earliest deletion date – to copy into your deletion concept. German law. No data is stored or transmitted.
Result
Accounting voucher (invoice, bank statement)
Pick a data type and enter a date – the start, end and earliest deletion date will appear here.
Guidance only, not legal advice. Periods under German law, as of 4 October 2026.
Structure
The 8 building blocks of a deletion concept
These building blocks are the columns of our template. The structure follows practice and the standards on the topic (DIN 66398, ISO/IEC 27555); no specific format is required by law.
Data types
Which personal data you process – ideally derived from the records of processing and specific enough for every department to recognise its data.
Deletion classes
Data types with the same period and trigger are grouped into one class. That keeps it to ten to twenty rules instead of hundreds of individual cases.
Purpose
What the data was collected for. Once the purpose no longer applies and no retention obligation stands in the way, the duty to delete begins.
Period and legal basis
How long the data stays and why: law, contract or documented internal decision. Label recommendations as such.
Start and trigger
When the period starts: end of the calendar year, end of contract, rejection, withdrawal. Without a trigger no period can be calculated.
Responsibility
Who initiates and follows up the deletion – one role per deletion class, not "IT" for everything.
Deletion method
Automatically in the system, manually, anonymisation, shredding or deletion by the processor – matching the storage location.
Deletion log
Proof that deletion took place: date, deletion class, scope, system, who. Without creating new, unnecessary personal data.
The template
What is in the Excel template
The template has four sheets. The main sheet has one row per deletion class with these twelve columns, seven example rows and 150 empty rows with dropdowns. In the EU version the examples leave period and legal basis open for your national law; the version for German law fills them in.
Scroll the table sideways →
| Column | What goes in | Example |
|---|---|---|
| Deletion class | ID of the class | DC-01 |
| Data type | Which data exactly | Accounting vouchers: invoices, bank statements |
| System / location | Where the data is | Accounting software, DMS |
| Purpose | What the data is processed for | Retention under commercial and tax law |
| Period | Retention or deletion period (dropdown) | 8 years (German-law version) |
| Legal basis of the period | Law, contract or internal decision | Section 257(4) HGB; Section 147(3) AO (German-law version) |
| Start / trigger | Event from which the period runs (dropdown) | End of the calendar year of creation |
| Owner | Role that deletes and follows up | Head of accounting |
| Deletion method | How data is deleted (dropdown) | Manual deletion in the system |
| Evidence / log | How the deletion is evidenced | Deletion log, annual run in January |
| Status | Draft, approved, implemented (dropdown) | Approved |
| Notes | Exceptions, restriction notes, links | Banks: 10 years |
The four sheets
Retention schedule
One row per deletion class, header frozen, filter on, an explanation as a comment on every column.
Deletion log
Date, deletion class, scope, system, method, carried out and checked by – 300 prepared rows.
Guide
All columns explained with references, notes on blocking and the start of periods, status and sources.
Lists
The dropdown values for period, trigger, method and status – free to extend.
Delete, block, anonymise
Three ways to handle data at the end of a period
"Period expired" does not always mean "delete now". These three options appear in a deletion concept:
Delete
The data is removed so that it cannot be restored – in the system, in backups according to their rotation cycle and at the processor. Paper is shredded.
Purpose no longer applies, no retention obligation (Art. 17(1) GDPR).
Block (restriction)
The data stays stored but is marked and taken out of active use. It may only be used for the retention purpose, for example a tax audit.
A statutory retention obligation still applies (Art. 17(3)(b), Art. 4(3), Art. 18 GDPR; in Germany Section 35 BDSG).
Anonymise
The personal reference is removed permanently so that nobody can be identified any more. Truly anonymous data no longer falls under the GDPR. Pseudonymisation is not enough.
Data is to be kept for statistics or analysis (Recital 26 GDPR).
Guide
Creating a deletion concept in 7 steps
How to get from an empty template to a deletion concept that is actually lived. The order and rhythm are a recommendation from practice.
- 1Record data typesUse the records of processing as a basis and list the data types per processing activity. Add where the data is – including file shares, mailboxes and processors.
- 2Determine purpose and periodFor each data type, clarify what it is needed for and whether a statutory retention obligation applies. Where none applies, set a period and give a short rationale.
- 3Form deletion classesGroup data types with the same period and trigger. Ten to twenty classes are enough for most companies.
- 4Define triggers and ownersFor each class, set the event from which the period runs and the role that initiates deletion.
- 5Clarify the deletion method per systemCan the system delete automatically? If not: who deletes manually, when, and how are backups and paper handled? Bind processors contractually.
- 6Approve and communicateHave management approve the deletion concept and inform the responsible roles. Transfer the periods into the records of processing and the privacy notices.
- 7Delete, log, reviewCarry out due deletions on fixed dates – every January for year-end periods, for example – and record them in the deletion log. Once a year, review the concept for new systems and changes in the law.
AI and deletion
What AI systems mean for your deletion concept
AI tools create new data types that many deletion concepts lack. Add these points (recommendation):
Prompts and histories
Chat histories with AI assistants often contain personal data. Set a period and use the tool's retention settings. Check in the DPA how long the vendor stores histories.
Logs of high-risk AI
Deployers of high-risk AI must keep automatically generated logs for at least six months, to the extent they are under their control (Art. 26(6) AI Act). That is a minimum – the maximum belongs in the deletion concept.
Training and test data
If you train or fine-tune your own models, you need rules on when training data is deleted or anonymised – and what that means for models already trained.
Files at the vendor
Uploaded documents often also sit with the AI vendor. Add the vendor as a storage location to the deletion class and refer to the deletion clause in the DPA.
Standards
DIN 66398 and ISO/IEC 27555
There are two well-known standards for building deletion concepts: the German DIN 66398, a guideline for developing a deletion concept and deriving deletion periods for personal data, and the international ISO/IEC 27555:2021 with guidelines on the deletion of personally identifiable information, which builds on DIN 66398.
Both standards are voluntary. Among other things they describe how to form deletion classes, define deletion rules and assign roles. Our template takes up this basic idea – grouping data types into deletion classes and setting a period and trigger per class – but does not reproduce any text from the standards.
Common mistakes
Where deletion concepts fail in practice
Still 10 years for invoices
Many templates were written before 2025. In Germany, accounting vouchers usually only need to be kept for 8 years – storing them two years longer means two years without a reason.
Forgetting when the period starts
German commercial and tax periods start at the end of the calendar year, not on the voucher date. An invoice from March 2026 may only be destroyed from 1 January 2035.
Only the main system
Copies in mailboxes, exports, network drives and at processors are often left behind. Add every storage location to the deletion class.
A concept without a date
A deletion concept that nobody carries out is just a document. A fixed annual deletion date and a responsible role make the difference.
A log with too much data
The deletion log should prove that deletion happened – not preserve the deleted data. Names of individual data subjects usually do not belong in it.
Backups ignored
Data in backups is usually not deleted individually but overwritten with the rotation cycle. Record this cycle in the deletion concept and make sure deleted data is not used again after a restore.
With SimpleAct
Retention periods and records of processing in one place
In SimpleAct's GDPR module (from Professional) you record retention periods and deletion triggers per data category, linked to the records of processing. The Excel template on this page is the starting point – once several people work on it and review dates need tracking, the software takes over.
- Periods per data category
- Linked to the records of processing
- Reminders for review dates
- Traceable change history
FAQ
Frequently asked questions about deletion concepts
More questions? We're happy to help. Send email · Try 7 days (credit card required)
Sources and status
Last checked on · SimpleAct editorial team
- Section 147 AO (German Fiscal Code) – retention of documents
- Section 257 HGB (German Commercial Code) – retention periods
- Art. 97 Section 19a EGAO – transitional rule on retention periods
- Section 41 EStG – wage tax records
- Section 195 BGB – regular limitation period
- Section 15 AGG – compensation and damages
- Section 35 BDSG – right to erasure
- Art. 17 GDPR – right to erasure (German text)
- Regulation (EU) 2016/679 (GDPR), EUR-Lex
- Regulation (EU) 2024/1689 (AI Act), EUR-Lex
- Haufe: Bureaucracy Relief Act shortens retention obligations (German)
This page, the template and the calculator are for orientation only and do not constitute legal or tax advice. The statutory text is authoritative. Periods without a statutory basis, the approach and the review rhythm are recommendations.
Changes to this page
- 4 October 2026 – Rebuilt: free Excel template with deletion log, verified retention table (10/8/6 years), period calculator, guide, AI section.
- 26 September 2026 – PDF template added (German).
- 14 June 2026 – First version.
Retention periods that are not forgotten
SimpleAct connects retention periods, records of processing and review dates – so your deletion concept does not exist on paper only.