Regulatory updates - Germany

On September 1, 2025, Germany's Federal Ministry of Finance (BMF) published a letter amending the Application Decree to the Tax Code (Anwendungserlass zur Abgabenordnung, AEAO). The update modifies AEAO references to incorporate the latest guidance on "Principles for the proper management and storage of books, records and documents in electronic form as well as for data access" (GoBD) from July 14, 2025. 

Key updates include: 

• Revised references across several AEAO sections on bookkeeping and storage requirements for electronic recording systems with cash register functionality. These sections now include the BMF letter dated July 14, 2025 (BStBl I p. 1502);

• Modification of one section to direct readers to existing AEAO provisions outlining procedures for handling certified Technical Security Device (TSE) failures in electronic recording systems.

The letter does not introduce new technical requirements. The detailed operational requirements remain in the AEAO as amended. 

The changes are effective immediately. 

On July 28, 2025, a comprehensive e-invoicing guideline bridging the German VAT Act (Umsatzsteuergesetz, UStG) requirements with the European e-invoicing standard EN 16931 was announced by XStandards for Purchasing’s (XStandards Einkauf).  

The mapping document represents a collaborative effort from several prominent German organizations in the e-invoicing and digitization sector: 

• XStandards for Purchasing (XStandards Einkauf), the government-led framework for standardization and digitization in public procurement, including XRechnung, managed by the Coordination Office for IT Standards (Koordinierungsstelle für IT-Standards, KoSIT). 

• The German e-invoice forum (Forum elektronische Rechnung Deutschland, FeRD), which publishes the ZuGFeRD specifications. 

• The German Association for Economic Administration (Arbeitsgemeinschaft für wirtschaftliche Verwaltung e.V., AWV), which promotes business growth by developing business-friendly administrative solutions and framework conditions while enhancing public sector effectiveness. 

The guideline details a systematic table mapping the mandatory VAT Act requirements to their corresponding EN 16931 elements. For each requirement, the table specifies: 

• The mandatory invoice content required by law; 

• The specific legal reference in the German VAT Act; and 

• The EN 16931 mapping, including relevant business groups (BG) and business terms (BT). 

This detailed resource will help businesses, software vendors, and service providers ensure their e-invoicing systems correctly implement all legally required VAT information in the appropriate EN 16931 data fields. 

The guideline is available on the XStandards Einkauf’s website and will be updated regularly to reflect any changes in requirements. 

On July 14, 2025, the Federal Ministry of Finance (BMF) published a second amendment to the Principles for the Proper Management and Storage of Books, Records, and Documents in Electronic Form, and for Data Access (Grundsätze zur ordnungsmäßigen Führung und Aufbewahrung von Büchern, Aufzeichnungen und Unterlagen in elektronischer Form sowie zum Datenzugriff, GoBD).

The update primarily reflects legal changes resulting from the introduction of mandatory e-invoicing among domestic businesses, effective January 1, 2025. Key changes include: 

Retention and formats 

• For e-invoices (per Section 14(1) UStG), archiving the structured data part, typically the XML file, is sufficient provided all GoBD requirements are met. Storing the PDF or other human-readable image is not required if it does not contain additional tax-relevant information. 

• Incoming electronic documents must be maintained in the format in which they were received (e.g., invoices as XML; bank statements as PDF or image files).  

• For documents received as structured datasets, such as e-invoices, content conformity is sufficient; visual conformity is not required. 

• Format conversion is permitted, but the original structured data must be preserved. If image information is enhanced (e.g., via OCR), the verified and corrected additional data must also be retained. The XML part of an e-invoice must remain intact and preserved. 

• When using an invoicing software, no separate graphic copy, e.g., a PDF or the PDF part of a hybrid invoice, must be stored at the time of creation, provided an identical copy of the outgoing invoice can be generated upon request at any time. 

Hybrid e-invoices  

• For hybrid formats, such as ZUGFeRD, the human-readable component (PDF) only needs to be archived if it contains any additional or different tax-relevant information not present in the structured data, such as accounting notes or qualified electronic signatures. 

Payment processing proofs 

• Technical proofs generated by payment processors (e.g., logs) generally do not have to be retained unless:
  • they are used as accounting documents;
  • they are the only settlement record with the payment processor; or 
  • they are the only way to clearly distinguish cash vs. non-cash transactions in the cash book.

Business letters 

• Incoming electronic commercial or business letters and accounting documents must be retained in the format in which they were received, for example, bank statements in PDF or image format. 

Audits and data access 

• The tax authority may require a machine evaluation of data subject to recording and retention requirements, or have it performed by an authorized third party. The taxpayer must provide the evaluation in a machine-readable format, e.g., export files that the tax office can process, or grant read-only access. Only evaluations using the capabilities available in the taxpayer’s or the commissioned third party’s IT system may be required. 

This GoBD version is effective from the day of publication, July 14, 2025.