GoBD for Car Dealers: Requirements, Documentation & Implementation

What Are the GoBD? – Definition and Significance for Car Dealers

The GoBD – in full Grundsätze zur ordnungsmäßigen Führung und Aufbewahrung von Büchern, Aufzeichnungen und Unterlagen in elektronischer Form sowie zum Datenzugriff (Principles for the Proper Management and Storage of Books, Records and Documents in Electronic Form and for Data Access) – are the central regulatory framework of the German Federal Ministry of Finance (BMF) for digital bookkeeping and storage of tax-relevant documents. Since the revised version of November 28, 2019, they apply to all taxpayers who determine their profit under § 4 para. 1, § 5 or § 4 para. 3 EStG – including every automotive business in Germany.

For car dealers, GoBD compliance is particularly demanding: the combination of vehicle trading with margin taxation (§ 25a UStG), workshop operations, cash register and extensive documentation creates a high density of tax-relevant documents and processes. Anyone who does not work cleanly here risks painful additional tax assessments during a tax audit.

Good to know: The GoBD have replaced the former GDPdU (Principles for Data Access and Auditability of Digital Documents) and GoBS (Principles for Proper IT-Supported Bookkeeping Systems) since 2015. All references to GDPdU in older contracts or software descriptions now refer to the GoBD.

The 10 GoBD Principles at a Glance

The GoBD define ten principles that every tax-relevant record must satisfy. The following table summarizes each principle and shows what it specifically means for your car dealership.

These ten principles form the foundation of GoBD compliance. They apply regardless of whether you handle your bookkeeping on paper, electronically or in a mix of both – though for electronic systems, additional requirements apply, which we will examine in detail below.

Procedural Documentation: Mandatory for Every Car Dealership

The procedural documentation is the heart of GoBD compliance and at the same time the point where most automotive businesses fail. It describes all processes related to the recording, processing and storage of tax-relevant data.

Who Needs Procedural Documentation?

In short: every taxpayer who maintains their books and records wholly or partly with IT systems. Since virtually no car dealership operates without software today, procedural documentation is mandatory for all automotive businesses – from the one-person dealer to the multi-brand operation with 200 employees.

What Must the Procedural Documentation Contain?

According to the GoBD guidelines (margin nos. 151–155), the procedural documentation must consist of four parts:

GoBD Requirements Specifically for Car Dealers

While the GoBD principles apply across all industries, there are a number of special features in the automotive trade that require precise implementation. The following areas are particularly relevant for car dealerships.

Vehicle Files and Digital Vehicle Documentation

Every vehicle in your inventory should have a complete, GoBD-compliant vehicle file. This includes:

• Purchase contract with indication of the taxation type (standard/margin)
• Copy of the vehicle registration document (Part II)
• Condition report / appraisal protocol for trade-ins
• Reconditioning and repair receipts
• Sales contract and invoice
• Handover protocol with buyer’s signature
• All associated emails and correspondence

The vehicle file must be structured so that a knowledgeable third party can trace the entire lifecycle of a vehicle in your business – from purchase through reconditioning to sale. This is precisely what the principle of traceability requires.

Margin Taxation Under § 25a UStG – Documenting Correctly

Margin taxation under § 25a UStG is a central topic for used car dealers. The GoBD require particularly careful documentation here:

• Proof of eligibility for margin taxation (purchase from a private individual or small business owner)
• Separate recording of purchase and sale prices per vehicle
• Calculation of the margin and the VAT applicable to it
• Note on the invoice: “Used goods / special scheme” (without separate tax disclosure)
• Seamless documentation that the vehicle was not purchased with input tax deduction entitlement

Practical tip: A common error is the retroactive change of the taxation type. If a vehicle is initially recorded as margin-taxed and later switched to standard taxation (or vice versa), this must be documented and justified without gaps. Traceless changes violate the principle of immutability.

Cash Book and Cash Register in the Car Dealership

Cash transactions are not uncommon in the car trade – especially with lower-priced used vehicles, parts sales and workshop services. The GoBD impose strict requirements on cash management:

• Daily cash book closing with target-actual comparison
• Individual recording of every cash receipt and expenditure
• Immutable recording – Excel cash books are not GoBD-compliant
• Chronological recording without gaps in numbering
• For electronic registers: compliance with the Cash Register Security Regulation (KassenSichV) and TSE obligation

Workshop Orders and Repair Documentation

Workshop orders are tax-relevant documents and are therefore fully subject to GoBD requirements. This means:

• Each order receives a consecutive, gap-free number
• Changes to issued orders must be logged
• Cancellations are made by counter-posting, not by deletion
• Material withdrawals and labor values are recorded individually
• The retention period is 10 years for invoices, 6 years for business correspondence

Learn more about the correct deadlines in our guide to retention periods in the car dealership.

Digital vs. Paper Retention: What the GoBD Prescribe

The GoBD regulate in detail when you may retain documents digitally and when the paper original must be preserved. For car dealerships increasingly adopting digital document management, this is a critical point.

The Basic Rule

Digital documents must be retained digitally; paper documents may be digitized – but only under certain conditions. The key rules at a glance:

Substitute Scanning – Requirements for the Scanning Process

Anyone wishing to replace paper documents with scans (so-called substitute scanning) must meet the following requirements:

• Visual consistency: The scan must faithfully reproduce the paper document (color for colored documents)
• Timely digitization: Documents should be scanned as soon as possible after receipt
• Readability: A minimum resolution of 300 dpi is recommended
• Immutability: The scan must be saved in a format that prevents or logs subsequent changes (e.g. PDF/A)
• Indexing: Each scan must be tagged with unique search criteria
• Logging: The scanning process must be documented (who, when, which scanner)
• Procedural documentation: The entire scanning process must be described in the procedural documentation

Note: After successful, documented scanning, paper documents may generally be destroyed – unless other laws require retention of the original (e.g. notarized deeds, contracts requiring written form).

Email Archiving Under the GoBD

Emails play a central role in the modern car trade – from vehicle inquiries and price negotiations to invoice dispatch and complaints. The GoBD require the audit-proof archiving of all tax-relevant emails.

Which Emails Must Be Archived?

• Emails that qualify as commercial correspondence (quotes, order confirmations, complaints)
• Emails with invoices as attachments or in the text
• Emails that constitute or contain posting receipts
• Emails with tax-relevant correspondence (e.g. contract negotiations)

Private emails and purely internal communications without tax relevance do not need to be archived. In practice, however, it is advisable to set up complete archiving and only exclude explicitly private folders.

Technical Requirements for Email Archiving

Archiving must be carried out so that emails are preserved in the original format, stored immutably and remain readable and searchable at any time during the retention period. Simply saving in the Outlook mailbox or printing out emails does not meet GoBD requirements.

A GoBD-compliant archiving system handles this task automatically and ensures that no tax-relevant email is lost or altered.

Tax Audit: GDPdU and Z3 Data Access

During a tax audit, the tax office has the right to access your electronic data. The GoBD define three forms of data access:

In practice, data carrier provision (Z3) is the most common form. Your system must be able to export all posting data, master data and transaction data in a standardized, machine-readable format – including links to the associated receipts.

Penalties and Consequences for GoBD Violations

The GoBD themselves do not define direct fines. However, the consequences of a violation are considerable and affect car dealers particularly strongly:

Common GoBD Violations in Car Dealerships

From our experience with hundreds of automotive businesses, we repeatedly see the same errors. If you recognize the following points in your business, there is an urgent need for action:

• Excel cash book: Still the most common violation – entries can be changed without a trace
• Missing procedural documentation: Many car dealerships simply have not created one
• Emails only printed: Digitally received documents must be archived digitally
• Incomplete vehicle files: Missing purchase contracts or appraisal protocols
• No logging of changes: Price corrections without an audit trail in the DMS
• No GDPdU export possible: The software in use cannot provide auditor export data
• Inadequate §25a documentation: No proof of purchase source for margin taxation
• Paper documents destroyed after scanning – without documented scanning process: Without procedural documentation for scanning, destruction is impermissible
• Missing data backup: No regular backup of tax-relevant data
• Deleting workshop orders instead of canceling: Violation of the principle of immutability

GoBD Compliance with AutoPult: How to Implement Requirements Automatically

AutoPult was developed specifically for the requirements of the automotive trade and covers all GoBD requirements automatically – without you having to worry about technical details.

Audit-Proof Archiving

All documents – contracts, invoices, emails, scans – are stored immutably in AutoPult’s GoBD-compliant archiving. Every change is versioned and logged with a timestamp and user.

Automatic Procedural Documentation

AutoPult generates the procedural documentation for your car dealership largely automatically. Process descriptions, system configurations and authorization concepts are continuously updated and available immediately during an audit.

Complete Vehicle Files

AutoPult’s document management system automatically creates a structured file for each vehicle. Mandatory documents are displayed as a checklist – so you can immediately see if a document is missing.

§ 25a-Compliant Documentation

When recording a vehicle purchase, AutoPult automatically checks the prerequisites for margin taxation and documents the decision in an audit-proof manner. A change of taxation type is logged and justified.

GoBD-Compliant Cash Book

The integrated cash book meets all GoBD requirements: individual recording, immutability, daily closing with target-actual comparison and gap-free numbering.

DATEV Interface

Via the seamless DATEV interface, your accounting data flows directly and GoBD-compliantly to your tax advisor – including all receipt images and links.

GDPdU Export for Tax Audits

During an audit, AutoPult exports all relevant data at the push of a button in GDPdU/Z3 format. The export includes posting data, master data, receipt links and analysis capabilities – exactly as the auditor expects.

Email Archiving Included

AutoPult automatically archives tax-relevant emails, links them to the respective vehicle files or business transactions and stores them in an audit-proof manner in the original format.