Security guide
Audit trail: why every change must be traceable
Updated: · Leutrim Miftaraj, FLIORE · Editorial standards · Other languages: Deutsch · Français · Español
Short answer
An audit trail records who created, changed, approved or deleted which data and when – unalterably and with a time stamp. In a family office it shows that due diligence obligations were met, payments were properly approved and valuations were not embellished after the fact. Anti-money laundering, commercial and tax law require traceable and unalterable records; a complete audit trail is the simplest way to get there.
What an audit trail records
- Who: the acting person, uniquely identified.
- What: the type of action and the object concerned, such as a mandate, person, document or payment.
- When: date and time, set by the system.
- Before and after: the old and the new value for changes.
- Context: approvals, comments, reasons.
Legal requirements
The Swiss AMLA requires records from which qualified third parties can form a reliable judgement. The Ordinance on the Keeping and Retention of Accounting Records requires integrity, traceability and unalterability for books kept electronically; accounting books and vouchers must be retained for ten years. In Germany, the Federal Ministry of Finance's GoBD specify the unalterability of electronic records; since 2025 the retention period for accounting vouchers has been eight years, and for books and financial statements ten years. In Austria, section 132 of the Federal Fiscal Code (BAO) generally provides for a period of seven years.
What the audit trail protects against
It protects the family against unnoticed manipulation and mistakes, such as a changed bank account just before a large payment. It protects the team, because it shows that decisions were taken properly. And it makes audits considerably easier: instead of laboriously gathering evidence, every question can be answered with an extract.
Requirements for a good log
- Generated automatically, not switchable off by users.
- Unalterable: entries cannot be edited or deleted.
- Complete: read access to particularly sensitive data is logged as well.
- Analysable: filterable and exportable by person, object and period.
- Available for the entire retention period, including after a system change.
Data protection within the log
An audit trail itself contains personal data. Only a few roles should have access to it, such as management and compliance. Retention follows the purpose: as long as the underlying records must be retained.
In FLIORE
FLIORE automatically logs changes to mandates, persons, documents and settings with the person and time. Renamed documents, approvals and exports appear in the audit trail; the activity of each mandate can be viewed directly on the mandate.
At a glance
| Core content | Who, what, when, before/after, context |
|---|---|
| Switzerland | AMLA, accounting records ordinance, 10-year retention |
| Germany | GoBD; accounting vouchers 8 years, books 10 years |
| Austria | Section 132 BAO, generally 7 years |
Terms on this page
- Forms A, K, S and T
- Standardised forms used by Swiss banks to establish the beneficial owner: A in general, K for controlling persons, S for foundations and T for trusts.
- Audit trail
- An unalterable log that records who created, changed, approved or deleted which data and when.
Frequently asked questions
Is the version history of office documents enough?
Partly, for individual documents – but not as the family office's audit trail. It can be altered, does not cover database changes and cannot be analysed centrally.
Must read access be logged too?
The law rarely requires it expressly, but for particularly sensitive data it is good practice. It makes it possible to establish who viewed confidential information.
How long is the audit trail kept?
At least as long as the records it relates to. For anti-money laundering records in Switzerland, that means at least ten years after the end of the business relationship.
What happens to the audit trail when software changes?
It must be exported and kept in a readable form. When selecting software, it should be clarified in which format the log can be exported.
Sources
- Swiss Ordinance on the Keeping and Retention of Accounting Records (GeBüV, SR 221.431) – Fedlex
- German Federal Ministry of Finance – GoBD
- German Fiscal Code (AO), section 147 – rules on retention
- Austrian Federal Fiscal Code (BAO) – Legal Information System (RIS)
This page provides orientation and does not replace legal or tax advice. The cited legal sources in their applicable version are authoritative.
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