Germany’s Federal Ministry of Finance has amended the Application Decree to the Tax Code (AEAO) to align with the July 2025 GoBD update and the new mandatory e-invoicing framework. The revision clarifies bookkeeping, recording system, and document retention rules, ensuring consistency within Germany’s digital tax environment.
Amendment aligns AEAO with digital tax reporting
On 1 September 2025, Germany’s Federal Ministry of Finance published an amendment to the AEAO. The update, effective immediately, adapts key tax administration rules to the ongoing digitalization of fiscal reporting. It covers three main areas: bookkeeping obligations, the operation of electronic recording systems with certified technical security devices (TSE), and document retention requirements.
This adjustment follows the July 2025 GoBD update, which modernized principles for managing and storing digital financial records. Read more in our earlier post, Germany updates GoBD rules for 2025 e-invoicing mandate. Together, both measures prepare the ground for Germany’s transition to mandatory B2B e-invoicing, which will be phased in between 2025 and 2028.
Clarifications on TSE and fallback procedures
A practical clarification in the latest amendment defines how companies should respond if a technical malfunction occurs in their certified TSE systems. It specifies cross references to other sections of the decree that outline compliant fallback procedures, supporting operational continuity and auditability.
Part of Germany’s wider e-invoicing reform
This update is part of a wider effort by German tax authorities to consolidate and simplify the e-invoicing infrastructure. Earlier this year, the ZRE and OZG-RE platforms were merged to support a unified digital reporting framework. For a broader overview of what these changes mean in practice, see our article with the most common FAQs about the German e-invoicing mandate.
The BMF will publish the full amendment in the Federal Tax Gazette (Bundessteuerblatt). The official letter dated 1 September 2025 is available on the Ministry’s website: Download the BMF letter (PDF).
Key takeaways
- Review bookkeeping and document management processes to align with the updated AEAO and GoBD.
- Ensure that TSE equipped recording systems meet updated operational and fallback requirements.
- Recognize that this reform supports Germany’s broader e-invoicing and tax digitalization agenda for 2025 to 2028.
- Stay informed through future BMF publications and updates to the Federal Tax Gazette.
Changes companies need to implement include updating internal compliance procedures, reviewing documentation policies, and ensuring that accounting systems are fully compatible with the new e-invoicing and TSE standards.
