GoBD is the shorthand for the German tax administration's principles for keeping books, records and documents in electronic form. The rules are not new and they are not specific to pharmacies, but they matter far more once a pharmacy starts taking money over the counter for something that is not a medicine.
Three requirements matter more than the rest:
- Recording has to be complete, so every single transaction appears in the record and not merely the ones entered afterwards from a note.
- Recording has to be timely, so cash takings are captured on the day they happen rather than reconstructed at the end of the week.
- Recording has to be unalterable, so a correction is visible as a correction and nothing can be removed without a trace of what went and who removed it.
A cash book that can still be edited afterwards in a spreadsheet fails the third requirement however accurate its numbers are.
A pharmacy already runs a till built for the reimbursed side of the business, and adding a service in the apothekenübliche Dienstleistung category creates a second revenue line that behaves differently. The customer pays on the spot, the pharmacy sets the amount, and there is no Krankenkasse settlement to reconcile against.
That second line is what a Betriebsprüfer examines first, because a new self-pay stream is where undocumented cash is most likely to be found. The records behind Privatliquidation and behind day-to-day Rechnungsstellung an Selbstzahler therefore have to agree with the till data instead of being kept in a separate folder beside it.
In practice that means three things about the way the service is booked:
- The service is an identifiable item in the till system rather than an open text amount booked as sundries.
- Card payments reconcile against both the till record and the bank statement.
- A Verfahrensdokumentation describes how the figure for a day's takings actually comes about.
The technical side, meaning the signing of each individual transaction, is covered by the TSE-Pflicht and it applies to every transaction described above.
Records have to be kept and produced in machine-readable form when an auditor asks for them, which means the pharmacy needs access to the data itself and not merely to the software that displays it.
How long each type of record has to be held, in which format, and which of these obligations apply to a specific setup depends on the systems in use. That question belongs with the Steuerberater, the pharmacy's tax adviser, before the first invoice is written rather than after the first audit.
This glossary entry is general information about German pharmacy law and practice. It is not legal advice. For binding guidance on your own pharmacy, contact your Landesapothekerkammer.
