GoBD from 2025: What changes and who needs to act now

What the gobd mean for companies in practice

The gobd (Principles for the proper keeping and storage of books, records and documents in electronic form and data access) are an administrative instruction from the Federal Ministry of Finance that regulates the handling of digital documents. They specify the requirements from the Fiscal Code and the Commercial Code. It is not a formal law, but a BMF letter that is binding for tax offices and auditors. Since 2015, the directive has combined the previous GDPdU and GoBS requirements. Anyone processing documents digitally or scanning paper documents must adhere to six core principles: traceability, completeness, correctness, timeliness, order, and immutability. In practice, this means a business transaction must be documented seamlessly from creation to completion. Timeliness requires prompt recording. Immutability ensures an invoice cannot be altered or deleted without a trace after posting. Every correction must be logged.

Who must strictly implement the requirements

Every taxpayer keeping electronic books and records is subject to these rules. The most common misconception is that the requirements only apply to large, balance-sheet-producing companies. This is false. Even a small business owner or freelancer keeping a digital net income method (EÜR) or creating invoices with software must meet the requirements. The obligations exist entirely independently of company size, legal form, or the method of profit determination. This error historically stems from the pre-digital era: the former GoB primarily applied to businesses required to keep books. With the switch to the digital version, the scope expanded to everyone processing tax-relevant data electronically. So, anyone writing outgoing invoices in a word processor and saving them as a PDF is already within the scope and must ensure the immutability of these documents.

Which deadlines and changes apply since 2025

The retention period for accounting documents dropped from ten to eight years due to the Fourth Bureaucracy Relief Act (BEG IV). This rule applies since January 1, 2025, for all documents whose period had not expired by this date. This particularly affects invoices. Furthermore, the Federal Ministry of Finance reacted to the new e-invoicing obligation with a letter dated July 14, 2025. A human-readable part of an electronic invoice, such as a PDF, only needs to be retained if it contains tax-relevant additional information. During an audit, the tax authority now also has the choice between data evaluation and pure read-only access. Already in March 2024, there was an adjustment to implement the DAC 7 directive. This change primarily specified the digital interfaces, the description standard for data transfer, and the supported file formats for the tax offices' IDEA audit software.

Why procedural documentation is not optional

If procedural documentation is missing during a tax audit, the bookkeeping is considered formally defective. This gives the tax office the right to estimate profits, which usually turns out to the company's disadvantage. The documentation is mandatory for anyone subject to bookkeeping, recording, or retention obligations. It describes the entire organizational and technical process of document processing – from receipt to recording, posting, and archiving. Those outsourcing processes to external service providers still remain responsible for mapping them in their own documentation and ensuring their regularity. The fear of overregulation is often unfounded: for a small company with standard software, procedural documentation of 5 to 15 pages is completely sufficient. The decisive factor is content completeness and traceability, not a specific number of pages. The goal is for an expert third party to understand the process in a reasonable time.

How a compliant system takes over the work

A modern document and accounting system processes documents without media breaks and ensures compliance up to the DATEV export. Procedural documentation is directly integrated into such systems and designed to be audit-proof. Governance is not an afterthought here, but built-in: approvals, logs, and limits are part of the tool. Incoming documents are read via OCR and AI vision, which also works reliably with handwriting. The system creates finished booking proposals including accounts, splits, and tax keys. An orchestrator decides based on four sources – fixed rules, history, machine learning, and large language models – in three stages: automatic processing, submission for review, or manual processing. Nothing is waved through blindly. Every confirmed or corrected booking trains the system, continuously increasing the quality of proposals per creditor. The archive serves as a central database for receipts, marketplace settlements, and balance sheets. Questions to the archive are answered in seconds, with each answer providing a direct source link to the respective document. This keeps every step traceable and audit-proof up to payment.