29 jul 2025
New Legal Requirements for Storing and Managing Electronic Data in Germany: A Focus on Structured Data
As of July 14, 2025, Germany's tax authorities have introduced key changes to the GoBD (Principles for the Proper Management and Storage of Books, Records, and Documents in Electronic Form, as well as Data Access). These updates bring a focus on the electronic storage and management of data, emphasizing the importance of not just storing digital copies of documents, but ensuring that they are stored in a structured and accessible format.
The changes highlight the following critical points:
Electronic Invoices and Structured Data:
The updated regulations stress that electronic invoices must be stored in a structured data format, such as XML or other machine-readable formats. While a scanned copy or PDF version of a document may be stored, it is the structured data (e.g., XML) that holds legal significance. This means businesses must ensure that their invoices are properly formatted for both human and machine access, ensuring compliance with tax regulations.
Data Recording and Accessibility:
The principle of data recording implies that business records must be digitally stored in a systematic, structured way within an electronic system, such as a database. This allows for easy querying, analysis, and retrieval of data when required by tax authorities or for auditing purposes. It is no longer sufficient to simply store documents in a non-editable format like PDF; the underlying data must be recorded in a way that can be processed and understood by digital systems.
Implications for Businesses:
This means that businesses must adopt modern systems that not only allow the storing of digital versions of physical documents but also ensure that the data within those documents is properly structured for easy access and compliance with the law. This could include using a database or other structured storage systems where data can be queried and processed efficiently.
Ensuring Legal Compliance:
Businesses must ensure that they are storing their records in a format that meets the legal requirements. This structured storage can be achieved through the use of databases or well-organized files in formats like XML, CSV, or JSON. These formats allow for automated processing, compliance with tax regulations, and a streamlined auditing process.
Changes Come Into Effect in 2025:
With the introduction of these changes, businesses have until July 2025 to update their systems and ensure they are compliant with the new requirements. The key takeaway is that businesses must go beyond merely scanning physical documents; they must also structure and store the underlying data in a way that is accessible, verifiable, and compliant with GoBD regulations.
As Germany moves toward greater digitalization, these updates reflect the growing need for businesses to adapt their data storage systems to comply with legal standards while facilitating smooth interactions with the tax authorities.