GoBD and retention periods: what the self-employed in Germany need to know in 2026

What are the GoBD – and do they apply to me?

The GoBD are a circular from the Federal Ministry of Finance (Bundesfinanzministerium) that interprets the obligations of the Fiscal Code (Abgabenordnung, §§ 145–147 AO) and tax laws for the digital world. The version of 28 November 2019 has been amended twice, most recently on 14 July 2025, mainly because of e-invoicing. The GoBD are not a law in their own right, but the tax office audits against them.

They apply to everyone who has to keep books or records for tax purposes – so also to freelancers and trade businesses using the cash-basis profit statement (EÜR), not only to companies that prepare balance sheets. Small businesses do not need the same systems as a corporate group, but they must follow the same principles.

The GoBD principles in practice

Each principle can be translated into a concrete rule for your everyday work:

Retention periods 2026 at a glance

With the Fourth Bureaucracy Relief Act (Viertes Bürokratieentlastungsgesetz, BEG IV), the period for accounting vouchers was shortened from ten to eight years from 1 January 2025; it applies to all vouchers whose old ten-year period had not yet expired on that day. For banks, insurers and investment firms the reduction only applies one year later. The periods are set out in § 147 Abs. 3 AO; for invoices § 14b UStG repeats the eight-year period.

When does the retention period start?

Under § 147 Abs. 4 AO the period starts at the end of the calendar year in which the document was created, the last entry was made or the accounts were drawn up. So what counts is not the document date but the end of the year.

The suspension of expiry (Ablaufhemmung) is important: the period does not end as long as the documents are relevant for a tax whose assessment period is still running – for example during a tax audit (Betriebsprüfung), an objection or if an assessment is subject to review (Vorbehalt der Nachprüfung). Check this before destroying anything.

Process documentation: mandatory for small businesses too

The process documentation (Verfahrensdokumentation) describes how receipts reach you and how they are recorded, booked, archived and protected against loss. It is mandatory for every business that keeps its bookkeeping electronically. If it is missing, that alone is not a reason to reject the bookkeeping – as long as traceability does not suffer. But at the latest with substitute scanning it becomes important.

For a sole proprietorship three to five pages are often enough. Keep it for ten years and update it with every change, such as a software switch. These points belong in it:

• General description: business, activity, programs used and who does what.
• Receipt intake: paper mail, email, customer portals, e-invoices – how are receipts collected?
• Recording and booking: when, by whom, with which program, how are errors corrected?
• Scanning: who scans, when, quality control, when is the paper destroyed?
• Archiving and backup: where is the data stored, how is it backed up, how is unalterability achieved?
• Data access: how can the tax office access the data or obtain an export during an audit?

Substitute scanning: paper gone, image stays

You may scan paper receipts or photograph them with your smartphone and then destroy the original. Conditions: the image matches the original visually and is fully legible, the process is described in the process documentation, and the file is archived in an unalterable way. Important: thermal paper till receipts often fade after a few months – scan them immediately.

There are exceptions where a law requires the original, for example certain customs documents or deeds. Scan first, then book – not the other way round with a pile of paper digitised months later.

Archiving digital receipts and e-invoices correctly

What arrives digitally must be kept digitally – a printout does not replace the original. This applies to PDF invoices by email, online invoices from customer portals and above all to the e-invoice, which every business must be able to receive since 2025.

• XRechnung: the XML file is the original and is kept unchanged; a human-readable view is only an aid.
• ZUGFeRD: the hybrid file (PDF with embedded XML) is kept as a whole. According to the 2025 GoBD amendment, you only have to keep the image part as well if it contains tax-relevant information that is not in the XML data.
• Emails: you only have to keep the email itself if it is an accounting voucher or business letter; if it only serves to transport the invoice, the attachment is enough.
• Conversion: if you convert files into another format, keep the original too if it contains tax-relevant data.
• Readability: you must be able to make the data readable throughout the entire period – even after a software switch.

Self-made receipt: when the receipt is missing

If you have lost a receipt or there is none, as with a parking machine without a ticket, you create a self-made receipt (Eigenbeleg). It replaces the third-party receipt as proof of the business expense but does not entitle you to deduct input VAT, because there is no invoice within the meaning of the VAT Act. Self-made receipts are the exception: if they pile up, the tax office becomes suspicious.

• Date of payment and date the self-made receipt was created.
• Payee with name and address, if known.
• Type of service or goods and business reason.
• Amount, cash or non-cash, if possible with proof of payment (bank statement, card statement).
• Reason why there is no original receipt.
• Your signature or electronic approval.

What happens if you breach the GoBD?

Minor formal defects usually do not lead to your bookkeeping being rejected. But if the defects are material – missing receipts, data altered after the fact, no individual recording of cash receipts – the tax office may estimate the tax bases under § 162 AO, usually with safety surcharges. For cash registers there are also fines under § 379 AO. During a tax audit the auditor also demands access to your data: directly in the system (Z1), indirectly through evaluations according to their specifications (Z2) or by handing over a data carrier (Z3). That is why your software should be able to produce a complete export.

Most questions can be avoided in advance with a clean bookkeeping routine and a proper cash book (Kassenbuch) (if you handle cash). The same applies to entertainment receipts and invoices: what you do not keep, you cannot deduct.

GoBD with Kontelio

In Kontelio you upload or photograph receipts into the receipt inbox (PDF, JPG, PNG, HEIC and XML e-invoices) and link them to the expense. Booked data is not overwritten: every entry receives a checksum, corrections are made through reversal entries or invoice corrections, and changes are recorded in the audit log. E-invoices are stored in their original format, and you create self-made receipts directly with the expense. All receipts are archived unalterably for ten years – more on the page managing receipts digitally.

Frequently asked questions