Germany updates Tax Code decree to align with new GoBD rules
From 1 September 2025, Germany’s AEAO now references the July 2025 GoBD update on electronic records and cash‑register systems, without adding new technical requirements.
Table of Contents
1. What changed in the AEAO and why
On 1 September 2025, the Federal Ministry of Finance (BMF) published a letter amending the Application Decree to the Tax Code (Anwendungserlass zur Abgabenordnung, AEAO). The goal is to bring the AEAO into line with the updated GoBD guidance issued on 14 July 2025 on the proper electronic management and storage of books, records and documents and on data access.
The BMF letter is available here (German): AEAO amendment – 1 September 2025.
2. Key updates – references and TSE handling
The amendment focuses on cross‑references and clarifications, not new technical rules:
- Several AEAO sections dealing with bookkeeping and storage requirements for electronic recording systems with cash‑register functionality now explicitly reference the BMF GoBD letter dated 14 July 2025 (BStBl I p. 1502).
- One AEAO section has been adjusted to point readers to existing AEAO provisions that describe how to handle failures of certified Technical Security Devices (TSEs) in electronic recording systems.
The letter does not introduce new technical requirements; the detailed operational obligations for businesses remain those already defined in the AEAO as amended. The changes are effective immediately, meaning the updated references and cross‑links apply from 1 September 2025 onwards
