In GoBD Explained – Part 1 , essential aspects such as immutability, access restriction, and procedure documentation were addressed. But what about GoBS in practice? For example, how do you handle e-mails and scanned paper documents?
E-mails with the function of a commercial or business letter or an accounting record in electronic form are subject to the storage obligation. The new policy confirms this and specifies: “If an e-mail serves only as a ‘means of transport’ e.g. for an attached electronic invoice, and also does not contain any further information that must be stored, it is not subject to the storage obligation (in the same way as the previous paper envelope).” »Ideally, e-mails in a business context are archived in a digital record.
GoBD compliance in practice
Incoming electronic commercial or business letters and accounting documents should generally be kept in the format in which they were received (e.g. as PDF). However, if the data is converted, it is not permissible to reduce the existing “machine evaluability.” An example: An invoice that has been scanned and provided with OCR-recognized text is also to be kept inclusive of this text.
However, there is no explicit mention of metadata in the GoBD – but the aforementioned regulations could be interpreted in such a way that these too must be kept. Another example would be a PDF document that cannot easily be converted into a TIFF format, as otherwise information would be lost.
»ECM systems are not only able to digitally manage and archive documents, but also to clearly document any changes. With version management, the source documents can be stored as a precaution after a format conversion.
Scanning can replace paper documents
Many companies do not yet dare to replace paper documents with scanned documents. It has been confirmed several times that the submission of a scanned document as evidence is recognized by the court (highlighted by this simulation study on “Replacing scanning”). Again, it expressly allows this: paper documents may be replaced by scanning.
That is, once documents have been scanned and are available as files, they no longer need to be kept as a paper document for accounting – unless other regulations require an original document.
The paper document should even be withdrawn from circulation so that no more notes can be made on it. If this does happen, the paper document with the notes must be scanned in again and placed under the same object (same index).
In addition, the directive requires that the scanning procedure itself must be documented. An organizational instruction must specify who, what, when, and how to scan, and what quality control and logging should be performed.
»A digital mailroom can save a lot of money, especially if the paper documents do not also need to be provided. With the enaio® ECM system, such electronic can be easily implemented in practice.
Archiving in PDF format
The PDF format is mentioned several times in GoBD, emphasizing the importance of the format as an archive format (see data conversion). Although PDF/A is not mentioned explicitly in the GoBD, it is still recommended as an archive format due to its immutability and completeness. In this context, the version PDF/A-3 is particularly interesting. This container format also allows the original data (e.g. open Office documents) to be included with the PDF presentation and archived.
» With enaio® you can create PDF/A documents for audit-proof archiving right after scanning. PDF/A-1, -2, and -3 formats are supported.
Electronic invoice exchange
The GoBD also explicitly mentions the electronic invoice format ZUGFeRD, which is based on PDF/A-3. In addition to the PDF file, it also contains XML data that can be automatically evaluated by the specialist applications. Since a purely electronic exchange of invoices is not only promoted by the EU, but also offers considerable savings potential, such an approach will certainly gain in importance in the future. The GoBD stipulates that the invoices must be archived including the XML data in order not to lose the “machine evaluability.”
»Audit-proof archiving of PDF/A-3 data is of course possible in enaio®. The electronic invoices can also be transferred to the inbox workflow.
GoBD compliance in practice: Conclusion
The Federal Ministry of Finance does not stipulate how taxpayers should design their IT environment. However, the GoBD imposes requirements that are difficult to manage adequately with a simple file system. The enaio® supports compliance with these guidelines: It allows you to meet the documentation requirements and logging obligations, as well as implement the requirements for version management, access protection, and audit-proof archiving.
Sources and further information:
- Principles for the proper management and storage of books, records, and documents in electronic form, as well as for data access (GoBD) – BMF letter of 11/14/2014
- Recent changes to the GoBD and e-invoicing, Stefan Groß, Christoph Möslein, Tobias Lieb, electronic tax audit forum.
- PDF Association: New principles encourage the use of PDF.