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 change character the moment a pharmacy starts taking money over the counter for something that is not a medicine.
Three requirements carry most of the weight. Recording has to be complete, so every single transaction appears and not only the ones entered later 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. And recording has to be unalterable, so a correction is visible as a correction and nothing can be removed without a trace of what was removed and by whom. A cash book that can still be edited afterwards in a spreadsheet fails on the third requirement however accurate its numbers are.
A pharmacy already runs a till built for the reimbursed side of the business. Adding a service in the apothekenübliche Dienstleistung category creates a second revenue line that behaves differently: the customer pays on the spot, the amount is set by the pharmacy, and there is no Krankenkasse settlement to reconcile against. That is exactly what a Betriebsprüfer turns to first, because a new self-pay stream is where undocumented cash is most likely to sit. The records behind Privatliquidation and behind day-to-day Rechnungsstellung an Selbstzahler therefore have to hang together with the till data instead of living beside it in a separate folder.
In practice that means 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, and a Verfahrensdokumentation exists that describes how a day's takings figure actually comes about. The technical side, the signing of each individual transaction, is covered by the TSE-Pflicht and sits underneath all of this.
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 and not only to the software that displays it. How long each type of record has to be held, in which format, and which of these obligations bite on a specific setup depends on the systems in use and belongs with the Steuerberater 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.
