Germany Updates GoBD Rules to Reflect Mandatory E-Invoicing

GoBD Amendment Alignment: On July 14, 2025, Germany’s Federal Ministry of Finance published the second amendment to the Principles for the Proper Management and Storage of Books, Records, and Documents in Electronic Form (GoBD), aligning it with the mandatory B2B e-invoicing regime effective January 1, 2025.
Key Changes to Retention and Archiving: The amendment specifies that for e-invoices, archiving structured data (like XML files) suffices, with human-readable copies required only if they contain additional tax-relevant information. Incoming electronic documents must be retained in their original format, and certain proofs from payment processors need to be archived only under specific conditions.
VAT and Invoicing Updates: Alongside the GoBD revisions, Germany has updated its VAT regulations to mandate structured XML formats for B2B e-invoicing, reduced the statutory invoice retention period from 10 years to 8 years, and introduced new credit note rules effective December 6, 2024, regarding unauthorized tax liability.

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Germany Updates VAT Invoicing Rules: Mandatory B2B E-Invoicing and Shortened Retention Periods

Mandatory B2B E-Invoicing Changes: Germany has updated its VAT invoicing and archiving rules to require mandatory B2B e-invoicing starting January 1, 2025, with structured XML formats as the legal record and a reduction in the invoice retention period from 10 years to 8 years.
Credit Note Regulations: Effective December 6, 2024, new rules state that if a non-entrepreneurial person issues a credit note with VAT and does not promptly object, it may trigger unauthorized tax liability, overriding previous court rulings on credit notes.
Compliance and Record-Keeping Requirements: The updated regulations emphasize that only the XML component of e-invoices needs to be archived, while the original format must be retained for audit purposes, ensuring compliance with the GoBD and allowing real-time access for tax authorities.

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Amendment to GoBD Regulations: The German Federal Ministry of Finance has published a second amendment to the GoBD, effective immediately, which allows businesses to retain only structured e-invoice data (like XML files) if the original data remains unchanged, while human-readable formats (e.g., PDFs) are only required if they contain additional tax-relevant information.
Mandatory E-Invoicing Compliance: Starting January 1, 2025, businesses must comply with new e-invoicing regulations, which include maintaining incoming electronic documents in their original formats and ensuring that any converted formats preserve the original structured data.
Audit and Data Access Requirements: The tax authority can request machine evaluations of the retained data, which must be provided in a machine-readable format, ensuring compliance with the updated regulations and facilitating efficient tax audits.

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E-invoicing