Germany implements new External Audit Regulation (ApO)

Germany has implemented a new External Audit Regulation (Außenprüfungsordnung, or ApO), which officially came into force on September 10, 2026. This regulation replaces the previous Betriebsprüfungsordnung (BpO 2000) that had been in effect since 2000.

The new framework incorporates legal changes from the DAC7 implementation law and aims to modernize tax controls through increased digitalization and more efficient procedures. Key updates include a stronger focus on risk-oriented auditing, which may limit audit periods to fewer than three taxation periods in certain cases.

Procedural changes include specific notice periods for audits: typically four weeks for large enterprises and two weeks for others. Additionally, the revenue threshold for mandatory group and follow-up audits has increased from 25 million euros to 50 million euros. The ApO also emphasizes improved coordination between state tax audit offices and the Federal Central Tax Office.