What the GoBD are
GoBD is short for the principles on properly keeping and retaining books, records and documents in electronic form and on data access. They are not a statute but a letter from the Federal Ministry of Finance dated 28 November 2019. It was amended on 11 March 2024 and on 14 July 2025, most recently because of e-invoicing.
The GoBD explain how the tax office reads the duties of the German Fiscal Code (AO) for digital bookkeeping. They concern you as soon as you keep tax-relevant data on a computer. That includes freelancers who keep no books and only prepare a profit statement (EÜR). Your invoicing app is part of it too.
The principles in plain words
The basis is § 146 Abs. 1 AO: entries and records are made individually, completely, correctly, on time and in order. The GoBD turn this into these principles:
- Traceable and verifiable. A knowledgeable third person understands within a reasonable time what happened, from the receipt to the figure in the return and back.
- Complete. Every business transaction is recorded, including the small ones.
- Correct. What is recorded matches the receipt and what really happened.
- Timely. Cash transactions are recorded daily, others promptly. For non-cash transactions the GoBD treat ten days as unobjectionable.
- Orderly. Receipts and records can be found and matched, for example by a receipt number.
- Unchangeable. Once something is recorded, it is not overwritten.
Unchangeable means: correct, never overwrite
§ 146 Abs. 4 AO says an entry or record must not be changed in a way that makes the original content impossible to determine. Changes that leave open whether they were made at the time or later are not allowed either.
For your invoices this means: while an invoice is a draft, you change it freely. Once you finalize and send it, it is part of your records. You do not fix a mistake by opening the invoice and changing the amount. You write a new document:
- a cancellation invoice that reverses the whole invoice when it should never have existed, for example sent to the wrong recipient,
- an invoice correction for the amount of the change when only part of it is wrong, for example a discount agreed afterwards.
Both refer to the original invoice, which itself stays unchanged. Which one to choose is covered in the guide Correct an invoice.
The same idea applies to invoice numbers. They should have no gaps. If a number is missing, you write down why.
The procedure documentation
Proper bookkeeping includes a procedure documentation (Verfahrensdokumentation). It describes how your receipts come in, how you record, process and keep them, and which software you use. It usually has four parts: a general description, user documentation, technical system documentation and operations documentation.
For a freelancer it does not have to be long. What matters is that it matches how you actually work and grows when something changes. You keep it as long as the records it describes. According to IHK München a missing one is not automatically a serious defect as long as the bookkeeping stays traceable. If in doubt, agree it with your tax advisor.
Data access in a tax audit
In a tax audit the tax office may look at your stored data and ask for it in a machine-readable format (§ 147 Abs. 6 AO). Your data therefore has to stay readable and exportable for the whole retention period, even if you no longer use the software actively.
For e-invoices, since the amendment of 14 July 2025 the structured XML file is enough. You only keep a PDF as well if it carries additional information.
A word on software and seals
Software alone does not make bookkeeping proper. The GoBD look at your whole procedure: how you record, file, correct and keep. The tax administration issues no positive attestations of proper bookkeeping, and certificates from third parties for software do not bind it (GoBD of 28 November 2019, Rz. 179 to 181). Software can take work off your hands, though, by locking finalized invoices, creating corrections as documents of their own, logging changes and handing out your data at any time. How Folnaro does this is below and on the page Tax advisor.
This guide is not tax advice. Whether your procedure is enough in your case is something to settle with your tax advisor.
