In the first part of this blog series, we looked at the basics of the GoBD: Why they are mandatory for online retailers, what the threat is for non-compliance and why typical processes in eCommerce – from invoice processing to archiving – are directly affected.
This article goes one step further. We take a closer look at the requirements for GoBD-compliant digital accounting. Because if you want to have your processes under control, you need to know which rules apply – and where auditors take a particularly close look.
What many underestimate: The GoBD are not a rigid set of rules for tax offices, but affect very practical processes in your company. Whether you write invoices manually or generate them automatically via a system, whether you save PDF files locally or in a cloud – all of this can be relevant. The decisive factor is not the tool, but whether you meet the requirements that the tax office places on the regularity, completeness and traceability of your digital data.
Where digital accounting reaches its limits in online business
The requirements of the GoBD often sound simple on paper – but in practice, it quickly becomes clear how complex digital accounting in eCommerce really is. This is because online retailers work with many systems simultaneously: store system, ERP, payment providers, marketplaces, shipping service providers, tax consultant tools if necessary – and each of these generates its own data.
If you don’t establish well-thought-out processes here, you risk data gaps, double entries or contradictory information – a real treat for auditors.
Problem 1: Distributed data sources without a central structure
Many online retailers use several systems in parallel – often without central data storage. Invoices are created in the store, customer data is maintained in a CRM, returns are processed in ERP, emails are managed in Outlook. This often means that documents are not fully archived or bookings are not documented in a traceable manner.
Practical example: An invoice is created in the store system and sent by email, but not recorded in the ERP. If a return is processed later, the link to the original sales transaction is missing.
Problem 2: Manual processes instead of automation
Many processes in eCommerce are still carried out manually – e.g. saving documents as PDFs, changing file names by hand or compiling export files. This not only costs time, but is also prone to errors and in many cases contradicts the GoBD requirements for traceability and immutability.
Typical weakness: Accounting data is compiled manually from various tools and transferred to the tax consultant – without a traceable change log.
Problem 3: Missing document link
Ideally, a business case can be traced digitally from listing to payment without any gaps. In reality, however, there is often no end-to-end link between documents: A delivery bill is not linked to the invoice, or a payment cannot be assigned to an order. This is a frequent reason for auditing, especially in complex multichannel setups (store + marketplaces).
Why this is dangerous:
At first glance, these weaknesses seem harmless – but from the point of view of the tax authorities, they are a clear violation of the regularity of accounting. The less automated, systematic and traceable your processes are, the greater the risk that the tax office will object to your accounting.
Important: It’s not about doing everything perfectly – it’s about establishing verifiably structured processes that are documented in an audit-proof manner.
What a Good System Must Do
Anyone who organizes their accounting digitally needs more than just an invoicing solution. It is crucial that all tax-relevant data is processed automatically, comprehensibly and permanently retrievable – ideally in such a way that it is available at the touch of a button in the event of an audit.
This is only possible if the systems used do not work in isolation, but are intelligently linked with each other – from order receipt to payment to archiving the documents.
To meet the requirements of the GoBD, your system should cover the following functions, among others:
- Automated document storage & versioning
Invoices, refunds, delivery bills, etc. must be stored automatically and ideally in an audit-proof manner. The system should log changes and make them traceable. - Central data storage & structured export
All relevant data should be bundled in one place and systematically exportable – e.g. for the tax consultant or, in the event of an audit, for the tax office (e.g. as a Z3 export). - Authorization management & access control
It should be clearly regulated who is allowed to see and change what. Changes to sensitive data must be documented – keyword: traceability. - Integration with third-party providers & legally compliant archiving
It should be possible to integrate tools for archiving (e.g. emails or e-invoices). Ideally, these systems should be GoBD-compliant.
A well-thought-out setup consisting of ERP, additional tools and structured processes is not an optional extra, but a real necessity – not only for GoBD compliance, but also for efficiency and transparency in day-to-day business.
Create clarity - so that you can make informed decisions
Digital accounting in eCommerce is demanding. Different systems, various data sources and manual work steps make it difficult to maintain an overview – especially when tax requirements such as the GoBD have to be taken into account.
This makes it all the more important to know the central weak points in your own company: Where are there gaps? Which processes are not documented in a comprehensible manner? And which tools or working methods ensure that data is structured, complete and audit-proof in the long term?
The GoBD provides the legal framework – how this is implemented in practice depends heavily on your own structures. Those who deal with the issue at an early stage, identify risks and improve processes in a targeted manner create the best conditions for avoiding unpleasant surprises later on.
