GoBD: meaning, invoices and archiving
The GoBD are the tax authorities' rules on how you keep and store books, records and receipts electronically. They apply to practically every business with tax record-keeping obligations, from freelancers to large corporations. For e-invoices, this has meant one thing above all since 2025: the structured XML file is the original and must be kept unchanged and machine-readable for eight years.
What does GoBD mean?
GoBD stands for "Grundsätze zur ordnungsmäßigen Führung und Aufbewahrung von Büchern, Aufzeichnungen und Unterlagen in elektronischer Form sowie zum Datenzugriff" (principles for the proper keeping and retention of books, records and documents in electronic form and for data access). It is a circular from the Bundesministerium der Finanzen (BMF, Federal Ministry of Finance), published on 28 November 2019 and amended twice since then: on 11 March 2024 and on 14 July 2025.
The GoBD are not a law. They describe how the tax authorities interpret the statutory obligations under the Abgabenordnung (AO, German Fiscal Code), above all §§ 146 and 147 AO, and under commercial law. In a tax audit, this interpretation is exactly the yardstick that applies.
Who do the GoBD apply to?
The GoBD apply to all taxpayers who are required to keep books or records under tax or commercial law. This covers companies that prepare balance sheets as well as businesses using cash-basis accounting (Einnahmen-Überschuss-Rechnung), freelancers, small businesses under the small business scheme, and people who are self-employed on the side. There is no exemption for small businesses. The requirements apply to all systems in which tax-relevant data is generated: invoicing software, accounting, cash register, inventory management or archive.
The principles of the GoBD
The GoBD summarise the requirements for proper bookkeeping in a few principles:
- Traceability and verifiability: An expert third party must be able to trace business transactions from the receipt to the booking entry and back within a reasonable time.
- Completeness: All business transactions are recorded without gaps.
- Accuracy: The records reflect the business transactions correctly.
- Timely recording: Business transactions are recorded promptly. For non-cash transactions, recording within ten days is considered unobjectionable.
- Order: Documents are filed systematically and can be found.
- Immutability: Once recorded, data must not be changed in such a way that the original content can no longer be determined. Changes must be logged.
In addition, there is the procedural documentation. It describes how receipts are created, recorded, processed and archived in your business. If it is missing or incomplete, this can raise doubts about the propriety of your bookkeeping during an audit.
GoBD-compliant invoices: what matters
A GoBD-compliant invoice is not a separate type of invoice. The term refers to an invoice that is created correctly, stored in an unalterable form and can be found at any time. Three points are decisive:
- Content: The invoice contains all mandatory information under § 14(4) UStG (German VAT Act). You can find an overview in the article Mandatory information on an invoice.
- Creation: Invoices created with freely editable programs such as Word or Excel and simply saved as files are problematic. They can be overwritten at any time without the change being visible. An invoicing program with fixed invoice numbers and a change log meets the immutability requirement far more easily.
- Retention: The invoice document remains legible, unchanged and machine-readable for the entire retention period.
For outgoing invoices, the GoBD make it clear: if you use an invoicing program, you do not need to store a pictorial copy of every outgoing invoice from the time it is created, provided you can generate a copy with identical content at any time. This explicitly also applies to the PDF part of a hybrid format.
What has applied to e-invoices since 2025?
With the e-invoicing mandate between domestic businesses, the BMF adapted the GoBD in a circular dated 14 July 2025. The changes apply immediately. The most important points:
- The XML file is the original. For e-invoices within the meaning of § 14(1) UStG, it is sufficient to keep the structured part. Incoming e-invoices must be stored in the format in which they were received.
- Hybrid formats such as ZUGFeRD: The structured data part is what counts. You only need to keep the PDF part as well if it contains tax-relevant information that is missing from or differs from the XML data, for example booking notes.
- No format conversion that deletes data: The XML file must not be lost through a conversion, for example into an image format such as TIFF.
- Matching content rather than matching appearance: For structured data records received, matching content is sufficient; a pictorial reproduction is not required.
So if you only print out e-invoices or file the visual representation as a PDF and delete the XML file, you are not keeping the original. The article Receiving, displaying and processing XRechnungen explains how to make received XRechnungen legible.
Retention periods under § 147 AO
Since 1 January 2025, the Vierte Bürokratieentlastungsgesetz (Fourth Bureaucracy Relief Act) has introduced shorter periods for accounting vouchers:
| Documents | Period |
|---|---|
| Books, records, annual financial statements, inventories | 10 years |
| Accounting vouchers, including incoming and outgoing invoices | 8 years |
| Commercial and business letters received and sent | 6 years |
§ 14b UStG also provides for invoices to be kept for eight years. The period begins at the end of the calendar year in which the invoice was issued or the receipt was created. An invoice from 2026 must therefore be kept until the end of 2034. If audits or proceedings are still ongoing, the period may be extended.
Archiving in compliance with GoBD: how to proceed
The following practice has proven effective for archiving your invoices in compliance with the GoBD:
- Keep the original format: E-invoices as XML, PDF invoices as PDF, paper receipts in the original or following a documented scanning procedure.
- Handle emails correctly: If the email merely serves as a means of transport for an attached invoice, keeping the attachment is sufficient. If the invoice is in the body of the email, keep the email itself.
- Do not print and delete: Receipts received electronically must be kept electronically. A printout does not replace the file.
- Keep changes traceable: Use a system that logs changes instead of storing files in freely writable folders.
- Ensure data access: During an audit, the tax authorities can request direct access to your data, an evaluation according to their specifications, or a data carrier. The data must therefore be machine-readable.
- Maintain procedural documentation: Record how invoices reach you and how they are checked, booked and archived.
How faktoora supports archiving
In faktoora, outgoing and incoming invoices are archived, and sending and filing remain logged and traceable. The invoices can be exported in structured form, including for DATEV, and handed over to your accounting department or tax adviser. The guide to the archiving function shows how to archive invoices in the system. You can read more about receiving and checking incoming documents on the page on incoming invoices.
Whether your bookkeeping as a whole complies with the GoBD never depends on software alone, but also on your processes and your procedural documentation.
Note: This article is for general information purposes and does not replace tax advice.
Frequently asked questions
What does GoBD mean?
GoBD stands for the principles for the proper keeping and retention of books, records and documents in electronic form and for data access. It is a BMF circular that specifies the bookkeeping obligations of the Abgabenordnung for electronic systems.
How long do invoices have to be kept?
Since 2025, eight years, counted from the end of the calendar year in which the invoice was issued. Books and annual financial statements must still be kept for ten years.
Do I have to keep the PDF of a ZUGFeRD invoice?
The XML part is what counts. You only need to keep the PDF as well if it contains tax-relevant information that is missing from the XML, for example booking notes.
Is it enough to print out e-invoices?
No. Invoices received electronically must be kept electronically in the format in which they were received. For e-invoices, that is the XML file.
Do the GoBD also apply to small businesses?
Yes. Small businesses under the small business scheme and freelancers using cash-basis accounting also have record-keeping and retention obligations and must comply with the GoBD.