Guides / Why GoBD is applicable to other countries as well
Why GoBD is applicable to other countries as well
GoBD was written by the German tax authorities, but it reads like a generic specification for a trustworthy long-term archive. Strip away the retention periods and almost nothing is specific to Germany.
GoBD is a German rulebook. It is published by the Federal Ministry of Finance (Bundesministerium der Finanzen) and enforced by the local tax offices (Finanzämter) during audits. So it is easy to assume it only matters if you file taxes in Germany.
But read the actual text and something becomes clear: GoBD is not really a description of a German system. It is a description of a generic document management system for long-term, tamper-evident storage — with a German retention clock bolted on top. Almost every principle in it applies to any serious digital archive, anywhere.
What GoBD actually says
GoBD is principles-based, not prescriptive. It builds on the long-standing “principles of proper bookkeeping” (Grundsätze ordnungsmäßiger Buchführung) and restates them for the electronic world:
- Completeness — nothing relevant is missing.
- Accuracy — records reflect what actually happened.
- Timeliness — things are recorded close to when they occur.
- Order — records can be found and followed.
- Immutability — once recorded, content is not silently changed.
- Traceability and verifiability — an independent third party can follow every record from origin to archive within a reasonable time.
That is the whole substance. It is the same list you would write for a court evidence system, a medical records archive, or a bank’s transaction log.
What GoBD deliberately does not specify
This is the part people get wrong. GoBD is technology-neutral and format-neutral by design. It does not tell you:
- which file format to use — there is no requirement for TIFF, PDF/A, or anything else (TIFF is a common practitioner recommendation, not a rule);
- what image resolution or colour depth a scan must have;
- which storage medium, database, or product to run;
- how, mechanically, to prevent changes.
Instead it says: pick an approach, make sure it satisfies the principles, and write down how it works in a procedural document (Verfahrensdokumentation). The scan just has to match the original visually and in content; the process just has to be documented and followed consistently.
The one requirement that really matters
If you reduce GoBD to a single sentence, it is this:
A record must not be changeable in a way that leaves no trace. If it is changed, the original content and the change must both remain visible to an auditor.
That is a write-once + audit-trail requirement. Append-only storage, version history, checksums, a change log that records who changed what and when — any combination that lets an auditor reconstruct the timeline satisfies it. Nothing about that is jurisdiction-specific.
What actually is specific to Germany
Mostly one thing: how long you must keep records. German retention periods are set by § 147 of the Fiscal Code (Abgabenordnung):
| Period | Applies to |
|---|---|
| 10 years | Books, records, inventories, opening balance sheets, annual financial statements, management reports, and the work/organisational instructions needed to understand them |
| 8 years | Accounting vouchers (Buchungsbelege) — invoices, receipts. Reduced from 10 years by the 2024 Bureaucracy Relief Act (BEG IV) |
| 6 years | Received and sent commercial and business letters, and any other documents relevant to taxation |
The clock starts at the end of the calendar year in which the last entry was made or the document arose. And note that even these numbers move — the drop to 8 years for vouchers is recent. Treat retention length as a configuration value, not a fixed property of your archive.
The same principles, elsewhere
Every developed tax and accounting regime has an equivalent, and the retention windows land in a similar range:
| Country | Typical retention | Framework |
|---|---|---|
| Switzerland | 10 years | Code of Obligations Art. 958f; GeBüV (very close to GoBD in spirit) |
| Austria | 7 years | Federal Fiscal Code (BAO) §§ 131–132 |
| France | 6 years (tax) / 10 years (commercial) | Livre des procédures fiscales; Code de commerce |
| Italy | 10 years | Civil Code Art. 2220 |
| Spain | 4 years (tax) / 6 years (commercial) | Ley General Tributaria; Código de Comercio |
| United Kingdom | 5–6 years | HMRC record-keeping rules |
| United States | 3–7 years (longer for fraud / unfiled) | IRS record-retention guidance |
(Indicative only — verify the current figures for your situation.)
More importantly, the principles are the same everywhere. Switzerland’s GeBüV independently arrives at immutability plus a logged audit trail. France layers document-archiving standards (NF Z42-013 / ISO 14641) and, for point-of-sale software, a certification requirement. The US IRS has required electronic records to be as complete and accessible as paper ones since the 1990s. And the vendor-neutral reference model for the whole problem — completeness, fixity, traceability, retrievability — is an ISO standard in its own right (OAIS, ISO 14721).
Practical takeaway
Build the archive for the principles, not for one country’s tax code:
- store documents so they cannot be altered silently;
- keep a complete, timestamped audit trail of every change;
- keep everything findable and exportable for the full retention period;
- document how your process works.
Do that, and meeting the local rules becomes mostly a matter of setting the right retention period and handling a few country-specific formalities (e-invoicing mandates, certified software in France and Italy, and so on). The hard part — a trustworthy archive — is the same everywhere.
How Papermerge helps
Papermerge is built around exactly these principles: immutable document storage, a complete audit trail, versioned documents with cryptographic checksums, and configurable retention policies. The GoBD-specific piece is just the retention period — a setting, not a rewrite.