Germany's principles for proper electronic bookkeeping (GoBD) are nothing new — but in 2026, the tax office is auditing more rigorously than ever. Fail here and you risk having your books rejected and your tax base estimated. Here is the checklist.
What the GoBD Require
The GoBD, set out in the Federal Ministry of Finance circular of 28 November 2019 (as last updated), define how electronic books and records must be kept. The six core principles:
- Traceability and verifiability: A knowledgeable third party must be able to review the books within a reasonable time.
- Truth, completeness, accuracy: Record all business transactions in full.
- Clarity and orderliness: Document entries in a comprehensible way.
- Timely recording: Cash entries daily; all other entries within 10 days.
- Order and immutability: Records kept chronologically; changes fully traceable.
- 10-year retention: All tax-relevant documents.
The Compliance Checklist
Procedural Documentation
- ☐ Written description of how documents are captured, reviewed, posted and archived
- ☐ Responsible persons designated
- ☐ Software procedures described (DATEV, Lexware, others)
- ☐ Interfaces to other systems documented
- ☐ Updated annually
Document Capture
- ☐ Incoming invoices captured digitally (PDF or scan)
- ☐ Original documents scanned in OCR-readable quality
- ☐ Each document uniquely identified by document number
- ☐ Payment approval documented (confirmation of factual and arithmetical review)
- ☐ Retained in machine-readable form
Cash Management (for cash-based sectors)
- ☐ TSE-compliant till (certified technical security device)
- ☐ Daily Z-reports generated and retained
- ☐ Cash count checks documented
- ☐ Cash book maintained on time
- ☐ Receipt issuance obligation observed (since 2020)
Data Backup and Retention
- ☐ Backup concept (daily, geographically redundant)
- ☐ Migration capability on system changes
- ☐ Readability guaranteed for 10 years
- ☐ Z2/Z3 access available for auditors
Software Requirements
- ☐ Software GoBD-certified or confirmed by vendor attestation
- ☐ Entries immutable (no retroactive changes without a reversal trail)
- ☐ Document identity and document-to-entry linkage ensured
- ☐ Access rights concept implemented
Procedural documentation is missing entirely (90% of SMEs). Documents are filed in Outlook instead of a structured archive. Excel spreadsheets are used for general ledger records. Software without demonstrable GoBD compliance is in use.
Consequences of Non-Compliance
If the tax office rejects your books as non-compliant, it can issue an estimated assessment under § 162 AO. Estimated figures typically run 20–40% above actual values — a substantial additional tax burden. On top of that, you face late-submission penalties and, in extreme cases, criminal consequences (§ 370 AO, tax evasion).
What we do at TABAK
For every new client, we prepare procedural documentation based on their systems and processes. Existing clients receive an annual GoBD compliance check. Where we find critical gaps, we close them. It is not spectacular work — but when the auditors arrive, it is the difference between €5,000 in professional fees for handling the tax audit and €50,000 in back taxes from an estimated assessment.
More than 20 years advising entrepreneurs, investors and family businesses. Reserved tax services are provided by our partner tax firm, TABAK Steuerberatung.
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We review your bookkeeping for GoBD compliance and, where needed, deliver procedural documentation and a remediation plan.