The German Ministry of Finance (BMF) has updated the Grundsätze zur ordnungsmäßigen Führung und Aufbewahrung von Büchern, Aufzeichnungen und Unterlagen in elektronischer Form (GoBD). This amendment comes ahead of the mandatory B2B e invoicing start date of January 1, 2025, and aims to align digital archiving requirements with structured e invoicing standards.
One of the key clarifications is that the XML component of a structured e invoice, including hybrid formats such as ZUGFeRD, is the legally relevant element for archiving. If a readable, graphical representation of the invoice can be generated from the XML, companies are no longer required to store a separate PDF version.
The amendment also reinforces that the original file format of a received invoice must be stored. Even if the invoice is converted for internal processing, the original file must remain in the archive to comply with legal retention obligations.
This update provides companies with clearer guidelines on how to handle and store e invoices in the context of GoBD, helping them prepare for the fast approaching e invoicing mandate.
The full text of the amendment is available on the BMF website:
GoBD 2nd amendment (PDF)
Key takeaways
- From January 1, 2025, B2B e invoicing becomes mandatory in Germany.
- XML is the legally relevant element for archiving structured e invoices.
- No separate PDF storage is needed if a visual version can be generated from XML.
- The original file format must always be archived, even after conversion.
- Companies should review their archiving processes to ensure GoBD compliance.
Additional resources
The official BMF document is relevant for accounting departments, compliance officers, ERP managers, and IT teams responsible for invoice processing and archiving. You can read the full text here:
Download the GoBD amendment (PDF)
