Glossary GoBD

Definition: The GoBD (Principles for the proper management and retention of books, records and documents in electronic form as well as for data access) are rules issued by the Federal Ministry of Finance (BMF) that specify how tax-relevant electronic data and documents must be captured, retained and made accessible to the tax office. They concretise requirements of the Fiscal Code (Abgabenordnung, AO) and apply to all companies and freelancers in Germany that use electronic accounting or documentation systems.

Legal basis and scope

The GoBD are based on the provisions of the Fiscal Code (in particular §147 AO on retention obligations) as well as tax and commercial law requirements (e.g. VAT Act (UStG), Commercial Code (HGB)). They apply to electronic books, records and the retention of electronic documents as well as to partly automated and manual processes, provided the data are tax-relevant.

Important: The GoBD are not an independent legal norm but administrative principles of the BMF. In tax audits, the tax office examines compliance with these principles and may adjust tax assessments or make estimated additions in case of violations.

Core requirements of the GoBD

The GoBD set out several key requirements that must be implemented in practice:

• Traceability and verifiability: Entries and documents must be recorded so that a knowledgeable third party can follow and verify the facts.
• Completeness and accuracy: All tax-relevant business transactions must be recorded completely, correctly and in a timely manner.
• Immutability and logging: Once recorded, data must not be altered unnoticed. Changes must be logged.
• Retention and availability: Data must be kept available for the legally required retention periods and provided in a readable form on request.

Practical implementation in accounting

Freelancers and small businesses need technical and organisational measures to comply with the GoBD. The most important steps:

Procedural documentation

Create a procedural documentation that describes the system used, responsibilities, workflows, interfaces, backup and recovery procedures as well as changes to the system. Without this documentation the properness of the accounting is quickly questioned.

Software and interfaces

Use GoBD-compliant bookkeeping and invoicing software. Ensure that exports in a machine-readable format are possible (e.g. CSV, XML) and that logs and audit trails are available.

Backups and access

Regular backups, audit-proof archiving (e.g. PDF/A) and a documented deletion policy are required. Make sure that in a tax audit data access is possible in one of the prescribed forms (e.g. export function).

Concrete examples, checklist and retention periods

Practical use cases help with implementation:

• Freelancer using cloud invoicing: Document how invoices are created, signed, stored and how corrections are made. Activate audit trails and regular exports.
• Small trading company with a cash register: Use a TSE-compliant POS solution under the KassenSichV, record shift closings and keep cash journals in an immutable form.
• Accounting service providers: Define who has access, how client data are separated and how documents are archived in an audit-proof manner.

Short checklist for practice:

1. Create and keep the procedural documentation up to date.
2. Choose and configure GoBD-compliant software.
3. Ensure audit trails and change logs.
4. Perform regular backups and recovery tests.
5. Observe retention periods and enable exports.

Conclusion: The GoBD require freelancers and small businesses to implement both technical measures and clear organisational processes. A proper procedural documentation, the choice of suitable software and regular backup and testing procedures reduce audit risk and provide legal certainty vis-à-vis the tax office.