Regulation Statutory · Germany
Principles for the Proper Management and Storage of Books, Records and Documents in Electronic Form and for Data Access (GoBD).
The GoBD is an administrative circular of the German Federal Ministry of Finance (BMF) that sets out in detail how books, records and electronic documents are to be kept properly, recorded immutably and retained under the Fiscal Code (Sections 146 f. AO), together with requirements on procedural documentation and the tax authorities' data access. It is relevant to you if you are obliged to keep books or records in Germany - for example via a German subsidiary, permanent establishment or your own business activity in Germany. Retention periods under Section 147 AO were checked in full text: 10 years for books, records, inventories, annual financial statements and customs documents, 8 years for accounting records, 6 years for commercial and business correspondence.
01 Triggers
When does GoBD apply to you?
GoBD may apply to you if one of these triggers applies. The Regulatory Check tests them against your details.
- Markets: Germany (applies if additionally: Markets: Germany) (Likely applies): If you conduct business in Germany - for example through a German subsidiary or permanent establishment - you must align your electronic bookkeeping and retention with the GoBD and Sections 146 f. AO.
Exceptions
- Per a secondary source, the GoBD is addressed to everyone obliged to keep books or records under German tax law - not only to companies obliged to keep accounts under commercial law in the classic sense. The exact scope of addressees was not examined in the BMF circular itself, only via a secondary source.
- Whether and to what extent a Swiss company without a German permanent establishment or subsidiary can be affected (e.g. when registering for German VAT purposes) was not clarified in this research.
02 Obligations
What does GoBD require?
- Individual, complete, accurate, timely and orderly recording of entries and other required records; for cash register systems, ongoing (typically daily) cash records are required (Section 146(1) AO, checked in full text).
- Immutability: changes to entries or records may not be made in a way that the original content is no longer ascertainable; ambiguous changes in substance are also inadmissible (Section 146(4) AO, checked in full text).
- For electronic storage: data must be available at all times during the entire retention period and be made legible without delay (Section 146(5) AO, checked in full text); under Section 147(2) AO, electronic documents subject to retention must additionally be machine-evaluable (checked in full text).
- Relocating electronic bookkeeping abroad: permissible within the EU, provided the tax authority's data access is guaranteed; in third countries only with written approval of the tax authority under further conditions (Section 146(2a) f. AO, checked in full text).
- Retention under Section 147(1) AO: books, records, inventories, annual financial statements and management reports as well as customs documents for 10 years; accounting records for 8 years; commercial or business correspondence received and sent, and other documents, for 6 years (checked in full text).
- Start of the period under Section 147(4) AO: at the end of the calendar year in which the last entry was made in the book or record (checked in full text).
- Maintain procedural documentation that makes the GoBD-compliant course of data processing traceable (per secondary sources, a core GoBD component; not examined in full text in the BMF circular itself).
- Enable the tax authority's data access as part of a field audit, including machine evaluation or provision in evaluable formats (Section 147(6) AO, checked in full text).
03 Evidence
What evidence is needed?
- Procedural documentation on the IT systems and processes used (content not examined in full text in the BMF circular).
- Evidence of the immutability of electronic records (e.g. via audit-proof archiving systems).
- Complete documentary records retained within the deadlines under Section 147(1) and (3) AO.
- Readiness for the tax authority's data access (Z1 direct access, Z2 indirect access, Z3 provision of data carriers) - these types of access are generally known GoBD terminology but were not verified in the BMF circular itself in full text in this research and are therefore noted under 'unsicher'.
04 Deadlines
Which deadlines apply?
- Revised version of the GoBD circular (reference number per a secondary source IV A 4 - S 0316/19/10003), in force from 1 January 2020 - date verified not in the BMF circular itself but only via a secondary source (Wikipedia).
- First known amendment of the GoBD circular (reference number per a secondary source IV D 2 - S 0316/21/10001:002) - not verified in the BMF circular itself.
- Further amendment, per a secondary source with a focus on electronic invoices - not verified in the BMF circular itself.
Information as of: 24 September 2026. Past dates are grey, upcoming ones highlighted (as of when the page was built).
05 Penalties
What are the consequences of violations?
Checked in full text is the sanction under Section 146(2c) AO: for breaches of the requirements on relocating electronic bookkeeping abroad, the tax authority can impose a delay penalty of EUR 2,500 to 250,000. Further consequences of improper bookkeeping (e.g. estimation of the tax base) are possible under the general understanding of German tax law, but were not verified in the statutory text (e.g. Section 162 AO) in this research and are therefore noted under 'unsicher'.
06 Related
What is connected with it?
- Ordinance on the Keeping and Retention of Accounting Records (GeBüV, SR 221.431) and Code of Obligations, Art. 957–958f (duty to keep and retain accounts): Anyone obliged to keep accounts under Art.
07 Open
What is still uncertain?
- The actual BMF circular on the GoBD (full text) could not be technically retrieved in this research: bundesfinanzministerium.de is protected by a bot-management system (Radware/perfdrive) that blocks automated access; archived Wayback Machine copies also returned only 404 error pages. All statements on procedural documentation, the types of data access (Z1/Z2/Z3) and the exact reference numbers/dates of the amendment circulars come from a single secondary source (Wikipedia) and are marked accordingly.
- The existence and content of the data access types Z1 (direct access), Z2 (indirect access) and Z3 (provision of data carriers) are generally known GoBD terminology but were not verified in the BMF circular itself in this research.
- Whether an even more current version exists beyond the three amendment circulars named (2019, 2024, 2025) was not examined.
- Sanction consequences for improper bookkeeping beyond the Section 146(2c) AO provision checked in full text (e.g. the power of estimation under Section 162 AO) were not verified.
08 Sources
Sources
Information as of: 24 September 2026.
- § 146 AO – Ordnungsvorschriften für die Buchführung und für Aufzeichnungen, Bundesministerium der Justiz / gesetze-im-internet.de, retrieved on 24 September 2026
- § 147 AO – Ordnungsvorschriften für die Aufbewahrung von Unterlagen, Bundesministerium der Justiz / gesetze-im-internet.de, retrieved on 24 September 2026
- GoBD – Übersichtsartikel (Datierung der BMF-Schreiben und Änderungen), Wikipedia (Sekundärquelle, nicht das BMF-Schreiben selbst), retrieved on 24 September 2026
A professional assessment based on publicly available sources, not legal advice. Whether a given rule applies in your specific case depends on circumstances that are not fully captured here.
FAQ Answers
Questions about GoBD.
Does the GoBD also apply to our Swiss parent company, or only to the German subsidiary?
The GoBD is tied to the German duty to keep books and records under Sections 146 f. AO. For a purely Swiss parent company without a German permanent establishment or subsidiary, applicability was not clarified in this research; what generally matters is the tax liability of the respective German entity.
How long do I have to retain accounting records in Germany - 10 years as in Switzerland?
No, not identical: under Section 147(1) AO, a period of 8 years applies to accounting records in Germany, while books and records themselves must be retained for 10 years. This differs from the Swiss rule under Art. 958f CO, where a uniform 10-year period applies to business books and accounting records (see the norm file gebuev_or).
Is electronic archiving sufficient if the accounting runs abroad?
Within the EU, relocating electronic bookkeeping is permissible provided the German tax authority's data access remains guaranteed. For third countries such as Switzerland, prior written approval of the tax authority is required under Section 146(2a) AO, combined with further conditions.
Does GoBD apply to you?
The Regulatory Check gives an initial assessment. In a conversation, we clarify what really applies in your situation and in which order you address it.
