An overview of the most important changes to the archiving of eInvoices

1. Archiving structured data

For eInvoices pursuant to Section 14 (1) sentences 3 and 6 of the German Value Added Tax Act (UStG), it will suffice in future to store only the structured part (e.g., the XML file). The human-readable PDF part only needs to be archived additionally if it contains deviating or tax-relevant additional information, e.g., accounting notes.

"For eInvoices within the meaning of Section 14 (1) sentences 3 and 6 of the German Value Added Tax Act (UStG), it is sufficient if only the structured part is retained and the requirements of this letter are met. Retention of the human-readable data part of a hybrid e-invoice (e.g., the PDF part of a ZUGFeRD invoice) is only necessary if it contains additional or deviating information that is relevant for taxation purposes (e.g., accounting notes)."

2. No pictorial copy required

If an invoicing program is used, it is not necessary to store a visual copy of the outgoing invoice (e.g., PDF or PDF portion of a hybrid format) if multiple copies with identical content can be created at any time.

3. Substantive rather than pictorial correspondence

Accounting documents, commercial or business letters in structured data format (e.g., as e-invoices) only need to match the original in terms of content, not image. This makes accounting easier, especially for companies that work with structured formats such as XRechnung or ZUGFeRD.

4. Regulations on hybrid formats

In the case of hybrid invoice formats (e.g., ZUGFeRD/Factur-X), only the structured data part (e.g., XML) must be retained—unless the PDF part contains additional information relevant for tax purposes. In this case, both parts must be archived.

5. Conversion remains permissible

Converting incoming electronic commercial and business letters and accounting documents into another format is still possible under the usual conditions.

6. Indirect data access

The tax authorities may require that tax-relevant data be evaluated automatically in accordance with their specifications and made available in a machine-readable format.

7. Immediate application

The revised version of the GoBD will come into effect on July 14, 2025, with immediate effect.

What does the GoBD amendment mean for companies?

• Obligation to electronically archive structured invoice data: In future, companies will only have to archive the machine-readable, structured part of the e-invoice – provided that no additional tax-relevant information is contained in the human-readable part.
• Digitization potential: The adjustments promote a consistent switch to digital and GoBD-compliant archiving systems.
• Hybrid formats at a glance: Companies should check whether and when both components (structured and human-readable) need to be archived.
• No more paper or image copies: Paper or PDF copies are no longer required, provided that the content of the document can be verified at any time.

FAQ: The most important questions about the GoBD amendment 2025

When do the new rules come into effect?

• Effective immediately: The GoBD in the version dated July 14, 2025, shall apply with effect from July 14, 2025.

Does this apply to all eInvoices?

• Yes, for all e-invoices within the meaning of Section 14 (1) sentences 3 and 6 of the German Value Added Tax Act (UStG), i.e. also for XRechnung, ZUGFeRD, Factur-X, and other EU-compliant formats.

What specifically needs to be archived?

• Only the structured data set (e.g., XML), except that the human-readable PDF contains additional tax-related information.

Does the email containing the invoice need to be archived?

• No, the GoBD requires the archiving of the invoice document itself, but not the transmission path. Nevertheless, separate verification and integrity requirements apply, especially for audit-proof storage.

Practical tip: Check digital archiving solutions for GoBD compliance now

The new GoBD guidelines set clear standards for the digital archiving of eInvoices. To ensure legal compliance and future viability, companies should adapt their processes and systems to the current requirements now.

1. Review your archiving processes: Record where and how invoice documents have been archived to date.
2. Focus on XML! Make sure that your accounting or ERP software can save XML invoices (XRechnung, ZUGFeRD) and store them in an audit-proof manner.
3. Be aware of hybrid cases: Check whether the PDF contains additional information—if so, both parts must be archived.
4. Take advantage of specialized services: With solutions such as the TRAFFIQX® Invoice API, you can automate archiving, integration, and verification directly—without any additional effort for your accounting department.
5. Digitize incoming and outgoing invoices: The amendment is the ideal opportunity to close analog gaps and process e-invoices digitally throughout.

Digital first – and remain audit-proof!

The 2025 amendment to the GoBD brings clarity and finally puts an end to the obligation to use file folders. However, digital archiving remains a demanding requirement. Those who implement the GoBD properly will benefit from efficiency, legal certainty, and lower costs.

Our tip: Review your processes, seek expert advice if necessary, and rely on a strong partner for technical implementation, such as TRAFFIQX®.