GoBD explained: principles, retention and what they mean for your invoices

What GoBD is and who it applies to

GoBD is not a law. It is a circular from the German Federal Ministry of Finance (BMF) (circular of November 28, 2019, last amended by the circular of July 14, 2025, both German) that spells out how the record-keeping rules of the German Fiscal Code (Abgabenordnung, AO, §§ 145 to 147 AO) apply to electronic records. It describes how books, records and tax-relevant documents must be kept and stored electronically, and how the tax authorities may access this data during an audit.

It applies to every business in Germany that is required to keep books or records, from a sole trader using cash-basis accounting (Einnahmen-Überschuss-Rechnung) to a GmbH (GoBD margin nos. 3 to 5). If you keep electronic books voluntarily, the same rules apply (§ 146(6) AO, GoBD margin no. 28). As soon as invoices, receipts or bookings are created or processed electronically, GoBD is the yardstick a tax audit (Betriebsprüfung) uses to judge your process. If you are a founder in Germany, that includes the invoices your shop, Stripe account or SaaS billing produces.

The core principles

GoBD boils down to a few principles:

Traceability and verifiability. An expert third party, such as a tax auditor, must be able to get an overview of the business transactions within a reasonable time. Every document must be traceable from its origin to the booking, and back again (GoBD margin nos. 30 to 35; § 145(1) AO).

Completeness and correctness. Every business transaction is recorded individually, completely and accurately. No sale is missing, and none is recorded twice (GoBD margin nos. 36 and 44; § 146(1) AO).

Timely recording and order. Documents are recorded promptly and filed in an orderly way, so that they can still be found (GoBD margin nos. 45 and 53).

Immutability. This is the most important principle and the one most often violated in practice: once a booking or document has been recorded, it must not be possible to change it in a way that hides the original content (§ 146(4) AO, GoBD margin no. 58). Changes must either be technically impossible or logged without gaps (margin no. 59). That is why an invoice is never deleted or overwritten. You correct it with an additional document, such as a cancellation invoice (Stornorechnung) or an invoice correction, that keeps the original content recognisable (margin no. 111). How Rechnungskit implements this technically (WORM storage, checksums, locked database tables) is described on the security, hosting and compliance page.

Retention: how long and in what form

Invoices and other accounting vouchers must be kept for 8 years, books of account and annual financial statements for 10 years (§ 147(3) AO; for invoices also § 14b(1) UStG, German). Each period starts at the end of the calendar year in which the document was created (§ 147(4) AO).

The form matters as much as the duration: documents that were created or received electronically must be kept in that form (GoBD margin no. 119). For an e-invoice, that means you keep the structured data part (XML), not just a printout or a PDF view. Under the current GoBD version (BMF circular of July 14, 2025, margin nos. 119 and 131), the human-readable PDF part of a ZUGFeRD hybrid only has to be archived as well if it contains additional or different tax-relevant information (such as booking notes). For outgoing invoices you create yourself, margin no. 76 says no image copy has to be stored if your invoicing program can produce a copy with identical content at any time. The storage itself must be audit-proof: unalterable, protected against loss, available for the whole period, readable and machine-evaluable (§ 147(2) AO, GoBD margin nos. 58 to 60).

Procedure documentation

GoBD expects procedure documentation for every IT system that handles your records (GoBD margin nos. 151 to 155, German): how an invoice is created, which systems are involved, how it is archived, who has access and how the system is protected against changes. This procedure documentation (Verfahrensdokumentation) must be clear enough for an expert third party to check it within a reasonable time (margin no. 151). Our procedure documentation template shows what such a document looks like for an automated invoicing flow.

What it means for invoices in e-commerce

In online retail, documents come from many places: orders in the shop, payments at Stripe, Mollie or PayPal, invoices in an app or tool, credit notes for refunds. The whole chain is only GoBD compliant once all the parts fit together. Every payment has to lead, traceably, to exactly one invoice whose number is only ever used once (§ 14(4) sentence 1 no. 4 UStG, German), corrections have to be additional documents rather than deletions, and the archive has to sit independently of your shop hosting, unalterable and available for the full retention period. According to the tax authorities, the number sequence does not have to be gap-free (section 14.5(10) UStAE, German), but you should be able to explain any gaps.

Rechnungskit is e-invoicing software built for exactly this. Every invoice it creates is archived so it cannot be changed, with a SHA-256 checksum as proof of integrity, versioned object storage and the structured XML archived alongside as the original format. Corrections are only ever created as cancellation invoices, invoice numbers run in sequence without gaps you would have to explain, and the DATEV export delivers the documents to your tax advisor (Steuerberater) in order.