GoBD explained simply
Principles of proper accounting in the digital age: what the GoBD concretely mean for your invoices — without the bureaucratic jargon.
What it's about
The GoBD ('Principles for the proper keeping and retention of books, records and documents in electronic form and for data access') are the tax authorities' rules of the game for digital accounting. They apply to every business — regardless of size and legal form — and a tax audit measures your processes against them.
| Principle | What it means in practice |
|---|---|
| Traceability & verifiability | A knowledgeable third party must be able to understand your documents and processes within a reasonable time |
| Completeness | Every business transaction is recorded — gap-free invoice numbers are the most visible symptom |
| Accuracy | Documents match the actual transactions |
| Timeliness | Recording close to the transaction, not months later |
| Orderliness | systematic filing, findable by number/date/partner |
| Immutability | once recorded = no longer changeable without a trace; corrections only in a traceable way (cancellation/credit note) |
Retention: 8 years, in the original
Invoices are among the documents with an eight-year retention period (§147 AO as amended by BEG IV 2024; previously ten years). For e-invoices the original is the structured XML — it must remain electronic, tamper-proof and machine-analysable. Printing and filing expressly does not fulfil the obligation.
What auditors typically want to see
- Gap-free document sequences (outbound) and complete inbound records
- Immutability: who could change documents? (The answer in CoolHanX: no one — sealed with a checksum)
- Procedural documentation: how does the process run from document to posting?
- Data access: being able to provide documents electronically (Z1–Z3 access)
Procedural documentation: the pragmatic starting point
- Describe the processHow is an invoice created? Who records inbound items? One page is enough to start — keywords, not prose.
- Name the systemsCoolHanX for the e-invoicing process (the feature pages provide the technical description), your firm's software for the posting.
- Assign responsibilitiesWho issues, who approves inbound items, who exports to the tax firm?
- Coordinate with your tax firmThe firm knows audit practice and adds what the auditor wants to see — set up once, briefly updated each year.
How CoolHanX covers the GoBD points
Gap-free number assignment only upon successful issuing; automatic archiving in the same transaction; SHA-256 checksums; deletion blocked before the end of the retention period; a timestamp and origin for each document; export for data access. What stays with you: the timely recording of your other transactions and the procedural documentation of your overall process — your tax firm can help with this.
Frequently asked questions
Does this also apply to Kleinunternehmer?
Yes — the GoBD have no de minimis threshold.
Is a backup hard drive enough as an archive?
No — backups protect against loss, not against alteration. The GoBD require immutability plus analysability.
Do I have to digitise old paper invoices?
No — but documents received digitally must be retained digitally.
What is procedural documentation?
The description of how documents are created, checked, posted and retained at your business. For the CoolHanX part, the feature pages provide the basis; the overall documentation is usually prepared together with your tax firm.
May documents be stored in the cloud?
Yes — what matters is immutability, analysability and data access. With processing in Germany (as here: Frankfurt), the special questions of foreign storage locations also no longer arise.
What is Z1/Z2/Z3 data access?
The three access types of a tax audit: direct access within the system (Z1), indirect access via evaluations (Z2), and handover on a data medium (Z3) — the export from CoolHanX serves the practically most important case, Z3.
The ten principles — what matters
The GoBD can be condensed into a few core principles: traceability and verifiability (a knowledgeable third party must be able to understand the process), completeness, accuracy, timely posting/recording, orderliness, immutability, and the obligation to maintain a procedural documentation and to enable data access. For electronic documents subject to retention, retention in the original format is added.
| Principle | Meaning | In everyday practice |
|---|---|---|
| Immutability | later changes excluded/logged | WORM archive, checksum |
| Completeness | no document missing, no gap | gap-free numbers, a status per document |
| Timely | recording without unnecessary delay | documents on an ongoing basis, not only at year-end |
| Original format | the XML, not a printout | the structured data set is archived |
| Data access | the audit can evaluate | export (Z3) with supporting evidence |
Procedural documentation — the often forgotten piece
The GoBD require a procedural documentation: a description of how documents are created, checked, posted and retained. It need not be extensive — one page of keywords is enough to start. For the e-invoicing part, the CoolHanX feature pages provide the technical description (issuing, validation, archiving); you add the operational framework (responsibilities, other document types) together with your tax firm. Once set up, it is briefly updated each year.
Related topics
Allgemeine Produktinformation — keine Rechts- oder Steuerberatung. Verbindliche Auskünfte gibt Ihr Steuerberater bzw. Ihre Rechtsberatung.
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