GoBD: The compliance-
Checklist 2026.

The principles of proper bookkeeping in electronic form (GoBD) are not a new topic — but in 2026, the tax office will scrutinize more rigorously than ever before. Those who fail here risk rejection of the accounting and estimation. The checklist.

What GoBD requires

The GoBD from the BMF letter dated 28.11.2019 (last updated) define how electronic books and records must be maintained. The six core principles:

1. Traceability and verifiability: A knowledgeable third party must be able to review the accounting in a reasonable time.
2. Truth, completeness, accuracy: All business transactions must be recorded completely.
3. Clarity and comprehensibility: Transactions must be documented in an understandable manner.
4. Timely recording: Cash transactions daily, other transactions within 10 days.
5. Order and Irrevocability: Documents chronologically, changes traceable.
6. Retention for 10 years: All tax-relevant documents.

The Compliance Checklist

Procedural documentation

• ☐ Written description of how documents are recorded, checked, booked, and archived
• ☐ Responsible persons designated
• ☐ Software procedures described (DATEV, Lexware, others)
• ☐ Interfaces to other systems documented
• ☐ Annual update

Document Capture

• ☐ Incoming invoices captured digitally (PDF or scan)
• ☐ Original documents scanned in OCR-readable format
• ☐ Document identity clearly defined by document number
• ☐ Payment verification documented (confirmation of factual and computational review)
• ☐ Retention in machine-readable format

Cash Management (for cash-based industries)

• ☐ TSE-compliant cash register (Technical Security Device)
• ☐ Z-receipts created and retained daily
• ☐ Cash count verification documented
• ☐ Cash book maintained in a timely manner
• ☐ Document issuance obligation adhered to (since 2020)

Data Backup and Retention

• ☐ Backup concept (daily, geographically redundant)
• ☐ Migration capability in case of system change
• ☐ Readability secured for over 10 years
• ☐ Z2/Z3 access for auditors possible

Software Requirements

• ☐ Software is GoBD certified or confirmed by the manufacturer
• ☐ Bookings immutable (no subsequent changes without cancellation trail)
• ☐ Document identity and linkage of document-booking ensured
• ☐ Authorization concept implemented

Consequences of violations

If the tax office rejects the orderliness, it can estimate according to § 162 AO. Estimate results are typically 20–40% above actual values — which means a significant additional tax burden. Additionally, delay penalties and, in extreme cases, criminal consequences (§ 370 AO tax evasion) threaten.

What we do at TABAK

For every new client, we create a procedural documentation based on their systems and processes. Existing clients receive an annual GoBD compliance check. In case of critical gaps, we provide follow-up. This is not spectacular — but in the event of an audit, it makes the difference between €5,000 in hourly fees for handling the audit and €50,000 in back payments due to estimations.