GoBD for small businesses: what the rules require
Unalterable, traceable, retained for 8 or 10 years: what the German GoBD expect from small firms, what a Verfahrensdokumentation is, and what software can and cannot do.
Not legal or tax advice. This page summarises public rules and describes what the software does. It does not replace advice from your tax adviser. The linked official sources, in their current version, are what counts.
The GoBD apply to any business that keeps books or must retain records, including sole traders and small limited companies. This page explains the requirements in plain words, gives the retention periods with their legal source, and separates what software can take over from what stays with you.
What the GoBD are
GoBD stands for “Grundsätze zur ordnungsmäßigen Führung und Aufbewahrung von Büchern, Aufzeichnungen und Unterlagen in elektronischer Form sowie zum Datenzugriff” (principles for proper keeping and retention of books, records and documents in electronic form, and for data access). It is a letter from the Federal Ministry of Finance (BMF), not a statute: it sets out how the tax administration reads the statutory duties in §§ 145 to 147 of the Fiscal Code (AO) and §§ 238 ff. of the Commercial Code (HGB) for electronic bookkeeping. The duties themselves are in the law; the GoBD are the yardstick a tax audit applies to your books.
The requirements
§ 146 (1) AO requires entries and records to be made “individually, completely, correctly, in good time and in order”. § 146 (4) AO forbids changing an entry so that its original content can no longer be determined; changes that leave it unclear whether they were made originally or later are also not allowed. In practice this comes down to:
- Unalterability: a posted or issued transaction is not overwritten. Corrections are fine as long as the original stays visible, for example through a reversal entry or a credit note.
- Traceability: a knowledgeable third party must be able to follow a transaction from the document through the entry to the financial statements, and back.
- Completeness and correctness: every transaction is recorded, with its actual content.
- Timeliness: recorded close to the event; cash receipts and payments must be recorded daily under § 146 (1) AO.
- Order: documents and entries are filed systematically and can be found.
Retention: 8, 10 and 6 years
The periods are in § 147 (3) AO and, for merchants, § 257 (4) HGB. The Fourth Bureaucracy Relief Act (Bürokratieentlastungsgesetz IV) shortened the period for accounting vouchers from ten to eight years; the current statute texts give eight years for accounting vouchers.
| Records | Period | Rule |
|---|---|---|
| Books and records, inventories, annual accounts, management reports, opening balance sheet, working instructions and organisational documents | 10 years | § 147 (1) no. 1, (3) AO |
| Accounting vouchers, including incoming and outgoing invoices | 8 years | § 147 (1) no. 4, (3) AO; § 14b UStG |
| Received and sent business letters, other tax-relevant records | 6 years | § 147 (1) nos. 2, 3, 5, (3) AO |
Under § 257 (5) HGB the period starts at the end of the calendar year in which the voucher was created or the book was closed. In some cases tax assessment periods run longer than the retention period; your tax adviser can clarify that. Under § 147 (2) AO, electronic records may be kept on data carriers if they stay available at all times, can be made readable without delay and can be machine-analysed. For e-invoices, see the e-invoicing guide; the tax administration treats the structured file as the original to keep, not a printout.
Data access during an audit
In a tax audit, the authority may access your data in three ways under § 147 (6) AO: inspect the stored data and use your system, have the data analysed by machine to its specification, or have the data handed over in a machine-readable format. If a service provider holds the data, they must cooperate too. The taxpayer bears the cost. An export an auditor can analyse is therefore more than a convenience, see DATEV export and SAF-T.
Procedure documentation
The word “Verfahrensdokumentation” is not in the statute but in the GoBD. The legal hook: § 147 (1) no. 1 AO requires keeping the “working instructions and other organisational documents needed to understand” the books, and § 200 AO lets the authority ask for the explanations needed to understand the records. The GoBD describe what the documentation should contain: a general description (which documents exist, how they flow), user documentation (who operates what), technical system documentation (which software, which interfaces) and operations documentation (backups, access rights, archiving).
For a small firm a few pages that match your real process are often enough. What counts is that it is accurate and stays current: it describes your process, not the software vendor’s.
Software and firm: who does what
| Topic | Software can | Stays with the firm |
|---|---|---|
| Unalterability | Lock posted and issued documents; corrections only via reversal or credit note | Follow the process; do not correct around the software (spreadsheets, paper) |
| Traceability | A change log with who, when, before and after | Record documents completely and link them to transactions |
| Retention | Store, export and back up the data | Observe the periods, do not delete too early, test backups and keep a copy elsewhere |
| Data access | Machine-readable exports | Be able to provide them when audited |
| Procedure documentation | Nothing: it describes your organisation | Write it and keep it current |
| Assessment | Nothing | Your tax adviser settles doubtful cases |
A “GoBD compliant” badge should therefore be read with care: the tax administration does not certify software, and whether your books are in order also depends on your process. OpenBusinessERP carries no certificate and does not claim compliance; what the software actually does is listed below.
What OpenBusinessERP implements
Checked in the source code:
- Documents: invoices and other documents can only be edited while in draft. An issued invoice can no longer be edited. Without payments it can be cancelled, which reverses its ledger entry with an offsetting entry. An issued invoice can also be corrected with a credit note.
- General ledger: posted journal entries are immutable, and corrections go through a reversal entry. Entry numbers are assigned without gaps per fiscal year. A reversal in a closed period is refused.
- Change log: every create, update and delete in the business modules (sales, CRM, items, inventory, purchasing, ledger, banking, dunning and more) is logged automatically with user, time and a before/after summary of the changed fields. It happens at the database layer, not in individual screens.
- Export: DATEV bookings and SAF-T, see the export guide; plus a data backup with restore.
Not covered by the software: the source has no monitoring of retention periods, so deleting and archiving is your responsibility. You must write the procedure documentation yourself. A draft is not yet an issued document and stays editable, but every change and deletion is logged.
Sources
- § 146 AO, rules for keeping books (German)
- § 147 AO, rules for retaining records (German)
- § 200 AO, duty to cooperate (German)
- § 257 HGB, retention of records (German)
- § 14b UStG, retention of invoices (German)
- GoBD (BMF letter of 28 Nov 2019 as amended), official AO handbook 2025, annex 33 (German)
- OpenBusinessERP: journal entries and reversals in the source
- OpenBusinessERP: document status and issuing in the source
- OpenBusinessERP: the automatic change log in the source