Tax & Law
GoBD (Principles for the Proper Keeping and Storage of Books, Records and Documents in Electronic Form)
Definition
The GoBD are administrative guidelines issued by the German Federal Ministry of Finance for audit-compliant archiving and retention of tax-relevant documents in electronic form. They set requirements for immutability, completeness, orderliness, traceability, and machine readability. Electronic invoices must be retained in compliance with GoBD requirements — i.e., in their original electronic format, not as printouts.
Background & context
The GoBD are not a law but an administrative directive of the German Federal Ministry of Finance (a BMF letter) that specifies how tax-relevant documents must be kept and retained electronically in a proper manner. They give concrete form to the requirements of the Fiscal Code (§§ 145–147 AO) and the Commercial Code. Central principles are: traceability and verifiability, completeness, accuracy, timely posting, orderliness and, in particular, immutability. For electronic invoices this concretely means: a received e-invoice (XRechnung XML or ZUGFeRD PDF) must be archived in its original electronic format — a mere printout is not sufficient. The archive must store the file immutably (e.g. via audit-proof systems or WORM storage) and keep it machine-analysable throughout the retention period. During a tax audit, the tax office can demand data access to these documents. A breach of the GoBD can jeopardise the input VAT deduction and the evidential value of the bookkeeping.
In practice — a worked example
A company receives an XRechnung as an XML file. Instead of merely printing it or placing it in a normal file folder, it imports the original file into an audit-proof document management system that logs every change and prevents deletions during the retention period. An accompanying view PDF may also be stored, but does not replace the XML original. This way the company can demonstrate both the file and its immutability in a later tax audit.
Common mistakes
- •Keeping an e-invoice only as a printout is not enough — the electronic original (XML) must be archived.
- •Storage in a normal, writable folder violates immutability; an audit-proof procedure is required.
- •Mind the retention period: invoices must in principle be kept machine-analysable for 10 years (§ 147 AO).
Frequently asked questions
Is it enough to print an e-invoice?
No. The GoBD require retention in the original electronic format. A printout is only an additional view copy and does not replace the digital original.
How long must I retain e-invoices?
In principle 10 years under § 147 AO. During this period the files must be available immutably and in a machine-analysable form.
Are the GoBD a law?
No, they are an administrative directive (a BMF letter) that gives concrete form to the legal requirements of the Fiscal Code and the Commercial Code. In practice they are nonetheless decisive for tax audits.