Effective July 14, 2025, the German Ministry of Finance (BMF) issued an amendment to the GoBD (German Principles on Bookkeeping), aligning the country’s digital archiving requirements with the upcoming mandatory B2B e-invoicing as of January 1, 2025.
The update provides long-awaited clarity for taxpayers and software providers regarding the format, retention, and machine readability requirements for structured e-invoices, especially in hybrid formats like ZUGFeRD.
Key Takeaways:
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PDFs not required for archiving – For fiscal purposes, the XML component of structured e-invoices issued under Section 14(1) of the German VAT Act is considered the legally relevant element and must be archived. A separate PDF copy is not required, provided a graphical representation with identical content can be generated on demand. This aligns archiving practices more closely with the new e-invoicing regulations.
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Format of receipt must be stored – The format in which an invoice is received determines how it must be archived. Even if converted for processing, the original file structure must be retained to meet audit requirements.
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Archiving of ZUGFeRD and hybrid formats – Hybrid formats like ZUGFeRD are now explicitly referenced in the GoBD. In these cases, the embedded structured XML is considered the legally binding element and must be archived accordingly.
