E36 means built from 1990 -1998.
Si it should be a similar system like on E34 and E32.
Easy to do with a PC for an expert and no chance to see it, unless you also get the service reports etc, which also can be falsified.
Sometimes the service record bools are sold as blank books on some auction houses.
Best is to ask the former owner, or ask the seller for the BMW dealer which made the service on that car the years before. Then contact the dealer. Here in Japan BMW always notoes down the miles/km the car comes into their shop and what has been done.