New Requirements for German R&D Tax Credits Documentation

The Federal Ministry of Finance in Germany has issued new administrative instructions concerning R&D tax credits, tightening the documentation requirements. This update, effective as of late October 2026, emphasizes that general time tracking is insufficient for justifying eligible personnel costs. The ruling explicitly necessitates project-specific documentation to verify personnel expenses and applies to prior fiscal years still open for assessment.

innoscripta SE had preemptively adjusted to these changes by promoting employee self-reporting through its Clusterix platform, which links activity records with specific R&D projects. This strategy aims to provide transparent, reliable data that can withstand tax audits.

Industry experts, like Matthias Helke, assert the critical nature of precise documentation matching work hours to eligible R&D projects. Michael Hohenester, CEO of innoscripta, highlights the importance of detailed reporting for proper compliance.