GoBD: Understanding the requirements for proper digital bookkeeping

Victoria Waba

Content Marketing Manager

5/27/20253 min read

At fiskaly, Victoria specializes in the German market, digital receipts, and employer branding. With a deep understanding of the digital landscape, she simplifies fiscalization, enhancing transparency and compliance.

GoBD is a central regulatory framework for digital accounting and the retention of tax-relevant data in Germany. The revised version of the GoBD guidelines stipulates that certain requirements for the archiving of receipts must be met. In combination with the Cash Security Ordinance (Kassensicherungsverordnung), they ensure that digital business processes comply with the requirements of the tax authorities. For companies, this means: They must carefully document, regularly review, and legally structure their IT systems and internal processes—to avoid fines, estimates, or audit risks. Let's take a detailed look at the requirements.

What are the GoBD?

The GoBD (short for “Grundsätze zur ordnungsgemäßen 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 as well as for Data Access) are an administrative regulation and a central component of the tax system in Germany.

The definition of the GoBD emphasizes their role in digital accounting, as well as the documentation requirements to ensure compliance with the tax office. They were introduced by the Federal Ministry of Finance (BMF) and specify the requirements arising from the German Fiscal Code (AO) and other tax regulations.

The GoBD define in detail how companies must capture, store, retain, and provide tax-relevant data to the tax authorities in the event of an audit. The aim is to ensure transparency, traceability, and immutability of digital records.

What are the legal principles of the GoBD?

The GoBD are based on various legal foundations, especially §§ 146 and 147 of the Fiscal Code (AO). These paragraphs regulate the obligation to keep books and the retention of tax-relevant documents. The GoBD principles specify these regulations concerning digital processes and systems and apply to all companies, self-employed persons, and freelancers in Germany—regardless of size or industry.

Key requirements of the GoBD include:

Traceability and verifiability of all entries and records
Immutability of data after its recording
Timely recording of business transactions
Proper retention of digital documents for 10 years
Documentation of the IT systems and processes used
Access rights for the tax authorities
Recording obligations according to the GoBD to ensure unchangeable and audit-proof documentation of receipts and bookings

The current version of the GoBD came into effect on January 1, 2020.

For which documents do the GoBD regulations apply?

The GoBD regulations apply to all tax-relevant documents, regardless of whether they are in electronic or paper form,especially when they are digitally created, received, processed, or archived. The goal is to ensure the properness of accounting and complete traceability for the tax office.

The most important document types covered by the GoBD include:

Records and business transactions (cash reports, individual cash data, outgoing and incoming invoices)
Electronic documents and receipts (e-invoices in structured electronic data format, system logs, TSS logs)
Accounting documents
Commercial and business correspondence
System and process documentation

Is GoBD-compliant archiving mandatory?

Yes, the GoBD is mandatory—however, not in the form of an independent law, but as an administrative regulation from the Federal Ministry of Finance (BMF). Nevertheless, the requirements are binding, as they specify the legal obligations of the Fiscal Code (AO).

The GoBD are based on the following paragraphs of the Fiscal Code:

§ 146 AO – Rules for bookkeeping
§ 147 AO – Retention of documents

This means: Anyone who is legally obliged to keep books or voluntarily keeps books and records (e.g., self-employed persons, traders, freelancers) must comply with the GoBD. Even in purely digital or partially digital accounting, the GoBD requirements apply without restriction.

GoBD and their role in relation to KassenSichV

In addition to the Cash Register Act and the KassenSichV, the GoBD are relevant for cash register operators. The guidelines published by the Federal Ministry of Finance in 2014 regulate the proper handling and retention of electronic data. Entrepreneurs themselves are responsible for compliance with the GoBD, even if they entrust their accounting documents to a tax advisor. Although they are an administrative regulation and not a law, they have legal significance.

The GoBD define key requirements such as the immutability of booking data and the traceability of business transactions—requirements also enshrined in the KassenSichV and mandatory for companies. Together, the KassenSichV and the GoBD ensure that companies not only meet the technical requirements for protection against manipulation but also fulfill general accounting obligations properly. This contributes to legal certainty and enables the tax authorities to efficiently monitor compliance with tax regulations.

Requirements for the retention of cash register data

In Germany, there has so far been no general obligation to use electronic cash registers. Companies can choose between electronic registers and open cash drawers. Electronic cash registers must be equipped with a Technical Security System (TSS). Open cash drawers are exempt from this requirement but require stricter documentation under the GoBD. However, the coalition agreement between CDU, CSU, and SPD provides for the introduction of a cash register obligation for companies with annual sales exceeding 100,000 euros starting January 1, 2027.

Cash register data must generally be retained for ten years. This retention period applies to all tax-relevant documents, including cash register data, in accordance with the legal requirements of the German Commercial Code (HGB) and the Fiscal Code (AO).

They must be stored completely and immutably. Every change to the cash register system and every subsequent change to the data must be logged and also retained.

In addition, the data must always be available, immediately readable, and machine-evaluable. Deficiencies in data retention can lead to significant tax back payments and penalties.