GoBD amendment 2025: what now applies to archiving e-invoices

With its circular of 14 July 2025, the Federal Ministry of Finance (Bundesfinanzministerium) amended the GoBD for the second time. These principles govern how books, records and supporting documents are to be kept and stored electronically and how tax auditors access the data. The main reason is e-invoicing, which businesses in Germany have had to be able to receive since 1 January 2025. The amended version has applied since 14 July 2025.

The structured part is sufficient

For e-invoices under § 14 Abs. 1 UStG, the BMF clarifies that it is sufficient to keep the structured part, provided the other GoBD requirements are met. For an XRechnung, this is the XML file. You do not need to archive a human-readable version generated from it by your accounting software as well.

With hybrid formats such as ZUGFeRD, the XML file is embedded in a PDF. You only need to keep the image part if it contains tax-relevant information that is missing from the XML part or differs from it. The BMF gives booking notes or a qualified electronic signature as examples.

Format and conversion

Incoming electronic documents must be kept in the format in which they were received. If you convert invoices on import, the XML part must remain machine-readable. Older processes in which invoices are printed, scanned or transferred to the document archive only as PDFs are therefore not compatible with e-invoicing.

Data access and proof of payment

With indirect data access, the tax authorities may require you to analyse the data yourself or through a third party and provide them with the result, or to grant read-only access. Only analyses that the system in use already offers may be requested. In addition, certain technical records from a payment service provider relating to an electronic payment no longer have to be kept.

Eight years for accounting vouchers

Irrespective of the GoBD, a shorter retention period has applied since 1 January 2025. Accounting vouchers, including invoices, must be kept for eight years instead of ten (§ 147 Abs. 3 AO, § 14b UStG). The new period applies to all documents whose retention period had not yet expired on 31 December 2024. For credit institutions, insurance companies and investment firms, it takes effect one year later.

In practice, this means: check with your software provider or tax firm whether the archive stores the XML file unchanged, and include the e-invoice receipt channel in your process documentation.