Germany updates GoBD for mandatory e‑invoicing and data retention

1. Scope and purpose of the second GoBD amendment

On 14 July 2025, the Federal Ministry of Finance (BMF) published a second amendment to the GoBD (principles for proper management and storage of electronic books, records and documents, and for data access). The update primarily reflects the legal changes arising from the mandatory domestic e‑invoicing regime that took effect on 1 January 2025, and it became effective immediately on the date of publication.​

The amendment text is available here (German): BMF – GoBD second amendment.​

2. Retention rules and formats for e‑invoices

Key clarifications concern how e‑invoices and other electronic documents must be archived:​

• For e‑invoices under Section 14(1) UStG, it is sufficient to archive only the structured data part (typically the XML file), provided all GoBD requirements regarding completeness, integrity and retrievability are met.​
• The PDF or other human‑readable image of an e‑invoice does not need to be stored if it does not contain additional tax‑relevant information.​
• Incoming electronic documents must be retained in the format in which they were received — for example, invoices as XML, bank statements as PDF or image files.​
• For documents received as structured datasets (such as e‑invoices), content conformity is sufficient; there is no requirement for visual conformity between archived data and any rendered image.​
• Format conversion is allowed, but the original structured data must be preserved. If image information is enhanced (e.g., via OCR), the verified and corrected additional data must also be retained; the XML part of an e‑invoice must remain intact.​
• When using invoicing software, no separate graphic copy (for example, a PDF or the PDF part of a hybrid invoice) needs to be stored at creation time, as long as an identical copy of the outgoing invoice can be generated on demand.​

3. Hybrid e‑invoices, payment proofs and business letters

The amendment also clarifies treatment of hybrid formats and other documentation:​

• For hybrid formats such as ZUGFeRD, the human‑readable PDF component only needs to be archived if it contains additional or different tax‑relevant information that is not present in the structured XML data, such as accounting notes or qualified electronic signatures.​

For payment processing proofs (for example, technical logs generated by payment service providers):​

• These generally do not have to be retained unless
  • they are used as accounting documents,
  • they are the only settlement record with the payment processor, or
  • they are the only way to clearly distinguish cash vs. non‑cash transactions in the cash book.​

For business letters and accounting documents received electronically, such as bank statements, the GoBD reiterates that they must be archived in the format in which they were received, typically as PDF or image files.​

4. Audits and electronic data access

The updated GoBD confirms and refines tax authority rights in audits:​

• The tax office may require a machine‑based evaluation of data that is subject to recording and retention obligations, or have such an evaluation performed by an authorised third party.​
• Taxpayers must provide data in a machine‑readable format, for example via export files that the tax administration’s systems can process, or by granting read‑only access.​
• Only evaluations that rely on the capabilities available in the taxpayer’s or the commissioned third party’s IT systems may be demanded; the tax authority cannot require the implementation of additional tools or functions solely for audit purposes.​

These changes align Germany’s data retention and access practices with the new e‑invoicing environment, while giving businesses more flexibility to rely on structured XML data as their primary audit‑ready record, provided it remains unaltered and fully compliant.