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In Brief
01. Oct 2025

Amended Principles of Proper Keeping and Retention of Accounts, Records and Documents in Electronic Form and for Data Access - Adjustments to take account of electronic invoices from 2025

The Federal Ministry of Finance (Bundesministerium der Finanzen, BMF) has revised its circular on the Principles of Proper Keeping and Retention of Accounts, Records and Documents in Electronic Form and for Data Access (Grundsätze zur ordnungsmäßigen Führung und Aufbewahrung von Büchern, Aufzeichnungen und Unterlagen in elektronischer Form sowie zum Datenzugriff, GoBD). The reason for the amendments was the introduction of the electronic invoice for transactions between (German) domestic companies since 1.1.2025.

The GoBD govern, among other things, the timely recording of business transactions, the inalterability of postings and data, the retention of digital documents as well as the documentation of procedures. In the updated circular, the BMF clarifies that, in the case of electronic invoices as defined in Section 14(1) sentences 3 and 6 of the German VAT Act, it is sufficient if solely the structured data component is archived -  provided that the other requirements under GoBD have been fulfilled. 

Please note

The human-readable portion of a hybrid e-invoice (e.g., the PDF of a ZUGFeRD format invoice) would then only have to be additionally stored if it contained additional data or variance information that were tax-relevant, for example, booking references.