Germany’s Ministry of Finance issued a second amendment to the GoBD on July 14, 2025, updating electronic record-keeping rules to align with mandatory e-invoicing from January 1, 2025. Key changes clarify that storing structured data (e.g., XML) is sufficient, while PDFs or hybrid elements only need archiving if they contain additional tax-relevant information.
Reminder: Germany’s BMF Published Second Amendment to GoBD
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Germany
Author: Ivana Picajkić
Category:
Fiscal subject related
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Content accuracy validation date:
28.08.2025
Content accuracy validation time:
09:27h
On July 14, 2025, the German Federal Ministry of Finance (BMF) released the second amendment to the GoBD (rules for managing and storing electronic records). The update aligns the GoBD with the new mandatory domestic e-invoicing rules starting January 1, 2025.
Changes:
- E-invoice storage:
- Keeping the structured data (usually XML) is enough, as long as all GoBD requirements are met,
- PDFs or other readable versions don’t need to be stored unless they include extra tax-relevant details not in the XML,
- Outgoing invoices from software don’t need a PDF copy if an identical invoice can be reproduced at any time.
- Hybrid invoices (e.g., ZUGFeRD):
- The PDF part only needs to be archived if it has additional or different tax-relevant info, such as notes or electronic signatures.
- Other electronic documents:
- Documents must be kept in the format in which they were received (e.g., XML for e-invoices, PDF for bank statements),
- Format conversion is allowed, but the original structured data must remain unchanged,
- OCR-enhanced data must also be stored if used.
- Payment processor records:
- Technical logs generally don’t need to be kept, unless they serve as accounting records or are the only evidence of payment settlement.
- Audits and data access:
- Tax authorities can demand machine-readable data for audits,
- Businesses must provide exports or read-only access, but only with tools they or their IT providers already use.
The changes took effect immediately on July 14, 2025.
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