GoBD

The GoBD were published by the German Federal Ministry of Finance (BMF) on 28 November 2019 in their current version and replace the earlier GDPdU. They specify what the German Commercial Code (HGB §§238, 239, 257) and the German Fiscal Code (§§146, 147) mean for electronic bookkeeping and archiving.

The GoBD define seven central requirements for electronic archiving: traceability and verifiability, completeness, accuracy, timeliness, order, immutability and procedural documentation. Once archived, documents must not be altered or deleted after the fact — if corrections are necessary, the original version must be preserved.

Particularly relevant for technical implementation are sections 58 – 63 on immutability: the GoBD accept both technical and organizational measures to ensure immutability. In practice, tax authorities rate technical measures (hardware WORM) significantly more favorably than purely organizational ones (access controls, dual-control principle), because the latter depend on human discipline and are harder to prove during an audit.

The GoBD apply to all accounting-obligated companies in Germany — from small GmbHs to large corporations. They apply to all tax-relevant electronic documents, including emails with commercial letter status, digitized incoming invoices and all other documents entering the bookkeeping. Retention periods: 10 years for commercial books, annual financial statements and accounting documents; 6 years for commercial correspondence.