Who may do your bookkeeping from 1 September 2026? The 9. StBÄG and what it changes for Odoo users

On 1 September 2026 a boundary shifts that, in most Mittelstand companies, nobody has ever determined precisely: the boundary between what self-employed bookkeeping professionals are allowed to do for you, and what remains reserved to a Steuerberater, the regulated German tax advisor, alone. The legal basis is the Neuntes Gesetz zur Änderung von Vorschriften im Steuerberatungsrecht sowie im Steuerrecht (Ninth Act amending provisions of tax advisory law and of tax law) — 9. StBÄG for short — signed on 29 June 2026 and promulgated on 2 July 2026 in the Bundesgesetzblatt, the Federal Law Gazette (BGBl. 2026 I Nr. 197).

For a Geschäftsführung — the managing directors of a German company — considering a change of finance software, this is not an academic question. It is a very concrete one: who will be allowed to take on which part of my bookkeeping, and what does that mean for the choice of my ERP system? At doo.FINANCE we answer this question regularly for companies moving from long-established DATEV structures to Odoo. The article below sets out the new legal position — without simplifying it.

The 9. StBÄG: what was promulgated, and from when it applies

The Act is extensive. It replaces §§ 4 to 7 of the Steuerberatungsgesetz (StBerG), Germany's Tax Advisory Act, in their entirety, reorganises the provisions on Lohnsteuerhilfevereine — the associations authorised to assist employees with their income tax returns — and amends the Umsatzsteuergesetz (UStG), the Abgabenordnung (the German Fiscal Code) and the Finanzgerichtsordnung (the Code of Procedure for Fiscal Courts). Two points matter above all for companies: the recast exemption provision in § 6 StBerG and the new designation provision in § 55g StBerG.

Entry into force is staggered. Artikel 13 Absatz 1 provides, verbatim:

"This Act shall enter into force on 1 September 2026, subject to subsections 2 to 4."

The exceptions concern essentially technical consequential amendments:

• Artikel 1 Nummer 8 enters into force only on 1 January 2027.
• Artikel 1 Nummern 12, 13, 17 and 19 Buchstabe b, together with Artikel 3 Nummer 3 and Artikel 8 to 11, already entered into force on the day after promulgation — that is, on 3 July 2026.
• Artikel 7 applies retroactively from 1 January 2026.

Both of the provisions that are decisive for you — the recast §§ 4 to 7 StBerG (Artikel 1 Nummer 4) and the new § 55g StBerG (Artikel 1 Nummer 14) — fall under the general rule. They apply from 1 September 2026.

The new boundary: what bookkeeping professionals are expressly allowed to do from 1 September 2026

The StBerG works through a prohibition and a list of exceptions. § 5 Absatz 1 StBerG prohibits any commercial assistance in tax matters (geschäftsmäßige Hilfeleistung in Steuersachen) by persons not expressly authorised to provide it. The new § 6 StBerG carries the heading "Exceptions to the prohibition of unauthorised assistance in tax matters" — and from September this list is broader than before.

§ 6 Absatz 1 Nummer 1 StBerG: the four permitted activities

In its new version the provision reads — the prohibition does not apply to:

"the setting up of charts of accounts [das Anlegen von Kontenplänen], the recording of current business transactions, ongoing payroll accounting and the preparation of the Lohnsteuer-Anmeldung [the payroll tax return], in so far as the performance of these activities lies within the responsibility of persons who, after passing the final examination in a commercial training occupation or after acquiring equivalent prior training, have worked in practice in the field of bookkeeping for at least three years at a volume of at least 16 hours per week".

The setting up of charts of accounts is thereby named expressly in the statutory text for the first time. For a company running its own ERP system this is the practically most important sentence in the entire Act: whoever builds and maintains your Kontenrahmen — the chart-of-accounts framework, whether SKR 03, SKR 04 or a company-specific derivative — inside your system does not have to be a Steuerberater in order to do so.

Note at the same time the qualification condition that the legislature wrote in expressly. Responsibility for these activities must lie with a person who

1. has passed a final examination in a commercial training occupation or acquired equivalent prior training,
2. has subsequently worked in practice in the field of bookkeeping for at least three years, and
3. has done so at a volume of at least 16 hours per week.

This is not a formality. Under § 7 Absatz 1 StBerG the competent Finanzamt — the local tax office responsible for your business — may prohibit further assistance for a maximum of five years where substantiated facts suggest persistently improper activity.

In addition, the new § 2 Absatz 3 StBerG makes clear that *assigning account codes to documents* (Kontieren von Belegen) and *issuing posting instructions* (Erteilen von Buchungsanweisungen) specifically do not count as merely mechanical operations. These activities are assistance in tax matters — they are simply exempted from the prohibition through § 6 Absatz 1 where the qualification requirements are met. The distinction matters considerably in law: the permission attaches to the person, not to the type of activity.

What remains a Vorbehaltsaufgabe, an activity reserved by law — first and foremost the Umsatzsteuer-Voranmeldung

The list in § 6 Absatz 1 StBerG is exhaustive. What is not in it remains caught by the prohibition in § 5 Absatz 1 StBerG. And what stands there expressly is only the Lohnsteuer-Anmeldung.

The Umsatzsteuer-Voranmeldung, the preliminary VAT return, is not named. It therefore remains reserved to the persons with unrestricted authority to provide assistance in tax matters — Steuerberater, Steuerbevollmächtigte (tax agents), Rechtsanwälte (lawyers), Wirtschaftsprüfer (statutory auditors) and vereidigte Buchprüfer (sworn book auditors) under § 3 StBerG. The 9. StBÄG changes nothing about this.

Likewise absent from the list, and therefore still a Vorbehaltsaufgabe:

• preparation of the Jahresabschluss, the annual financial statements, and of the Steuerbilanz, the tax balance sheet,
• all Steuererklärungen, that is tax returns (Umsatzsteuer, Körperschaftsteuer, Gewerbesteuer),
• tax advice in the individual case, including representation before the Finanzamt.

In summary, then, the new boundary reads: the chart of accounts may sit with the Buchhalter, the bookkeeper. The Umsatzsteuer-Voranmeldung may not. It is precisely this cut that explains the cost structure of many German companies — more on that shortly.

External ownership and name protection: who may call themselves a "Steuerberatungsgesellschaft"

In parallel with the opening on one side, the Act tightens on the other. The new § 55g StBerG reads in full:

"Only Berufsausübungsgesellschaften [professional practice entities] in which Steuerberater and Steuerbevollmächtigte hold the majority of the voting rights and in which the majority of the members of the management body are Steuerberater or Steuerbevollmächtigte may use the designation 'Steuerberatungsgesellschaft'."

Two cumulative conditions, then, not one: a majority of voting rights and a majority in the management body. A company that meets only one of the two may no longer use the designation. Alongside this, Artikel 1 Nummer 13 tightens the capital-lock provision of § 55a StBerG for indirect shareholdings — that amendment has already applied since 3 July 2026.

For you as the client, this is a criterion you can check. From September 2026, a provider that uses the designation "Steuerberatungsgesellschaft" is saying something dependable about its ownership and management structure — and therefore about whether it can itself perform the Vorbehaltsaufgaben with Rechtssicherheit, legal certainty.

Why exactly this boundary explains why you pay twice

That brings us to the question behind this article. Many Mittelstand companies experience their bookkeeping costs as opaque because they receive two invoices for one process: one for the software, one for the Kanzlei, the tax advisory practice.

The reason is not pricing but structure. DATEV puts it unambiguously on its own product pages: use of DATEV products is "tied to cooperation with a DATEV member (e.g. a Steuerberater)". A company cannot acquire DATEV on its own. The licence presupposes the relationship with a Kanzlei.

That is understandable in economic terms — and explicable in legal ones. As long as the Vorbehaltsaufgabe, first and foremost the Umsatzsteuer-Voranmeldung, and the tool in which the postings are created are bundled with the same actor, you pay separately for access to the tool and for the performance of the reserved act. The remuneration of the Kanzlei's work follows the Steuerberatervergütungsverordnung (StBVV), the German scale of fees for tax advisors, which provides a separate table for Buchführung, double-entry bookkeeping.

The 9. StBÄG does not remove this bundling. But it makes visible that the bundling is not compulsory. If the legislature places the setting up of charts of accounts expressly outside the reserved scope, then the place where your chart of accounts lives need not be the same as the place where your Voranmeldung is produced. If you want to take that route in practice, the technical steps are set out in our guide to moving from DATEV to Odoo.

What this means in practice for your Odoo environment

Four concrete checks can be derived from the new legal position, and you should work through them before 1 September 2026.

1. Establish who is responsible for your chart of accounts. In an Odoo system the Kontenrahmen sits in the accounting module and is part of your own database. § 6 Absatz 1 Nummer 1 StBerG expressly permits this work to lie within the responsibility of an appropriately qualified specialist. Document who that person is, and that they meet the three-year and 16-hour conditions.

2. Separate ongoing data capture from the Vorbehaltsaufgabe. Recording current business transactions and payroll accounting may take place in the system. Preparing and submitting the Umsatzsteuer-Voranmeldung must lie within the responsibility of someone with unrestricted authority. Set that separation of roles down in your access rights, not only in an understanding between the parties.

3. Check the legal form of your provider. If it uses the designation "Steuerberatungsgesellschaft", from September it must meet the double majority condition of § 55g StBerG. That is a question you are entitled to ask.

4. Check whether your tool is tied to your provider. If changing Kanzlei would mean losing access to the system, your control over your own data is coupled to a contract you do not control.

How these four points are brought together in a live environment is described in our Odoo accounting services; the sequence of a system change is set out under Odoo migration services.

Frequently asked questions

This article reflects the position of Bundesgesetzblatt 2026 Teil I Nr. 197 of 2 July 2026 and is provided for general information. It does not replace legal or tax advice in the individual case. For an assessment of your specific situation, please consult a Berufsträger, a licensed professional.