Almost every real estate business that keeps books for tax purposes in Germany falls under the GoBD, the tax administration's rules for keeping and storing records in electronic form. A developer booking construction invoices against DIN 276 cost groups, a property manager issuing service-charge statements, and an owner filing an Anlage V all create and receive documents that the Finanzamt can later ask to inspect. This guide explains what the GoBD require, how long records must be kept, and what tamper-proof (revisionssicher) archiving really means. It is educational and not a substitute for advice from your tax adviser.
What the GoBD are, and what they are not
GoBD stands for Grundsätze zur ordnungsmäßigen Führung und Aufbewahrung von Büchern, Aufzeichnungen und Unterlagen in elektronischer Form sowie zum Datenzugriff. It is an administrative decree from the Federal Ministry of Finance, originally dated 28 November 2019 and updated by later BMF letters (most recently in 2024), rather than a statute in its own right. It interprets duties that already exist in the Abgabenordnung (sections 140 to 148 AO) and the Handelsgesetzbuch (sections 238 and following HGB). Put plainly, the law says you must keep proper books and retain records; the GoBD describe how to do that when the records are electronic, and how to make them available in a tax audit.
The core principles
The GoBD rest on a handful of principles that every process touching a tax-relevant document has to honour:
- Nachvollziehbarkeit und Nachprüfbarkeit (traceability and verifiability): a knowledgeable third party must be able to follow every entry from voucher to booking and back within a reasonable time.
- Vollständigkeit (completeness): every business transaction is recorded, nothing is left out.
- Richtigkeit (accuracy) and timeliness: entries are correct and made promptly, not months later.
- Ordnung (order): records are systematically filed and retrievable.
- Unveränderbarkeit (immutability): the heart of the GoBD. Under section 146 (4) AO, an entry may not be changed so that its original content can no longer be established. You do not overwrite a mistake; you correct it with a new, documented entry that leaves the original visible.
A related rule of thumb is the Belegprinzip: no booking without a voucher. Every cost line in a development cost cockpit and every maintenance charge in property management should trace back to an underlying invoice or receipt.
How long you must keep records
The retention periods live in section 147 (3) AO. The clock starts at the end of the calendar year in which the last entry was made, the document was created, or the correspondence was sent or received.
| Record type | Retention |
|---|---|
| Books, inventories, annual financial statements, opening balance sheet, management reports, organisation documents | 10 years |
| Accounting vouchers (Buchungsbelege), including incoming and outgoing invoices | 8 years |
| Received and sent business and commercial letters, and other records relevant to taxation | 6 years |
The eight-year figure for vouchers is recent: the Fourth Bureaucracy Relief Act (Viertes Bürokratieentlastungsgesetz) of 2024 shortened it from the traditional ten years. Where a longer period applies under other tax rules, or an outside audit or an open assessment is running, keep the documents until that clears. When in doubt, keep for ten years.
The Verfahrensdokumentation
The GoBD expect a Verfahrensdokumentation: a written description of how tax-relevant documents flow through your business. It usually has four parts, a general description, a user documentation (who does what), a technical system documentation (which software stores what, and where), and an operating documentation (backups, access rights, controls). An auditor should be able to read it and understand your process without sitting next to you. The point is that a knowledgeable third party can reconstruct the lifecycle of any document from receipt to archiving.
What revisionssichere archiving means in practice
Revisionssicher, often translated as tamper-proof or audit-proof, is not a single product you buy but a set of properties your archiving must have:
- Documents are stored complete and unaltered, in their original format. A PDF invoice, or a structured e-invoice (E-Rechnung, mandatory to receive in German B2B since 1 January 2025), is archived as received, not printed and rescanned.
- Nothing can be changed or deleted without a trace. Every version and access is logged.
- Each document is indexed and can be found and reproduced quickly for the whole retention period.
- Data stays readable and machine-evaluable, so the tax office can exercise its access rights (direct access, indirect access, or handover of a data medium).
Where this bites in real estate
Three situations make archiving more than a formality. First, service-charge statements: tenants have a statutory right to inspect the original vouchers behind a Nebenkostenabrechnung, so those invoices must be retrievable years later. Second, development: construction invoices booked against DIN 276 groups are the vouchers that justify capitalised costs, and they carry the eight-year period. Third, WEG management: a Verwalter preparing the annual statement must keep orderly accounts that owners can inspect. In each case the obligation is not just to keep the paper but to keep it findable, unaltered, and tied to the right property.
How a system of record with audit supports compliance
Immutability and traceability are far easier when your operational data lives in one auditable place instead of scattered spreadsheets and email attachments. REPM runs on Microsoft Dataverse, which brings role-based security and an audit log that records who changed what and when. Every unit, lease, tenant, and cost line is one record, and the invoices and receipts behind them attach to that record rather than floating in a shared drive. That gives you the traceability from voucher to booking, and the completeness, that the GoBD ask for, and it turns producing documents for an auditor or a tenant into a search rather than a scramble.
To be clear, REPM is a system of record, not a certified archive. Full GoBD compliance still needs your own Verfahrensdokumentation and, depending on your setup, a dedicated long-term archive. What the platform gives you is the immutable, access-controlled, well-indexed foundation that compliance is built on. Start a free REPM trial to see how the audit trail and document links work on a real property.
Frequently asked questions
How long must I keep invoices under the GoBD?
Invoices are accounting vouchers (Buchungsbelege). Since the Fourth Bureaucracy Relief Act of 2024 the retention period for vouchers is eight years, down from ten. Books, annual financial statements and similar records stay at ten years, and business letters at six. The period starts at the end of the calendar year in which the document was created or received.
What is a Verfahrensdokumentation and do I need one?
It is a written description of how tax-relevant documents are created, received, processed, stored and retrieved in your business, including who is responsible and which systems are used. Any business that keeps electronic records under the GoBD is expected to have one, and an auditor can ask to see it.
Does GoBD-compliant mean I can never edit a record?
No. It means you cannot change an entry so that its original content is no longer recognisable. Corrections are allowed, but they must be made as new, documented, traceable changes that leave the original visible, which is exactly what an audit log provides.
Is REPM a certified GoBD archive?
No. REPM is a system of record on Microsoft Dataverse with role-based access and an audit log, which supports the traceability, completeness and immutability the GoBD require. Full compliance also needs your own Verfahrensdokumentation and, where required, a dedicated long-term archive.