As Germany accelerates toward mandatory B2B e-Invoicing, its Ministry of Finance has issued a pivotal update to the GoBD, the framework that governs how businesses manage and archive digital financial records. The second amendment to the GoBD, issued on 14 July 2025 delivers long-awaited clarity on how e-invoices must be stored, especially in light of the mandatory e-invoicing regime introduced in January 2025.
The Structured Format Takes Priority
The revised GoBD confirms that businesses only need to retain the XML file or the structured XML part of a hybrid invoice format like ZUGFeRD. The PDF component is not mandatory, unless it contains additional tax-relevant information.
This is a shift from older interpretations that often assumed visual or printable versions had to be archived alongside XML files. Germany now joins other digital VAT regimes in recognizing structured data as the authoritative source for tax purposes.
Visual Representations (PDFs) Are Optional — But Conditional
For invoices generated through a billing or ERP system, a PDF version no longer needs to be stored, provided that:
- A human-readable copy can be regenerated at any time
- There is no loss of content or discrepancy in interpretation between the structured data and the visual version
However, if a hybrid invoice (like ZUGFeRD) contains tax-relevant details only in the PDF, such as posting remarks, payment conditions, or notes, then that PDF must also be archived.
Original Format Preservation is Mandatory
Businesses must store invoices in the exact format in which they were received. For example:
- If an invoice is received in XML format, that XML must be retained.
- If an invoice is sent in a hybrid format, the structured XML part is mandatory; the PDF part is optional unless it includes additional relevant data.
Format conversions (e.g. XML to PDF) for internal use are permitted, but the original version must remain intact and accessible. The GoBD allows enhancements such as OCR (optical character recognition) during scanning, but such additions must be verified and archived.
10-Year Retention with Audit-Ready Access
E-invoices must be archived for ten years, and during that period, companies must:
- Guarantee integrity, authenticity, and readability
- Retain the invoice in a machine-readable format
- Ensure that tax authorities can access or request evaluations of stored data through a read-only interface or structured export
The GoBD update strengthens the concept of “indirect access” (mittelbarer Datenzugriff) allowing authorities to demand that businesses analyse and provide structured invoice data themselves or via a third party.
New Guidance for Hybrid Formats (ZUGFeRD, XRechnung)
The update includes detailed clarification around hybrid invoice formats, such as:
- ZUGFeRD invoices contain both an XML file and a visual PDF
- The XML part is considered the legally binding record
- If the PDF includes any extra tax-relevant info, it must also be archived
- Any conversion or deletion of the XML part (e.g. converting to TIFF) is explicitly prohibited
No Archiving Needed for Some Payment Service Documents
The updated guidance also notes that documents generated by payment service providers (e.g. transaction confirmations) do not need to be stored, unless:
- They serve as official accounting records
- They’re the only available record for distinguishing cash and non-cash transactions
This reduces the burden of storing ancillary documents that have no direct accounting function.
GoBD 2025: In Effect Now
These revised requirements are effective immediately — from 14 July 2025. Businesses must review their current archiving practices and technical systems to ensure they are in full alignment.
As Germany continues its multi-year rollout of mandatory e-invoicing for B2B transactions, this GoBD amendment provides critical clarity for IT, finance, and compliance teams. By aligning your systems and policies now, you not only ensure legal conformity but also unlock opportunities for process automation, cost savings, and audit efficiency.
