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How to set up an email mailbox with archiving function according to GoBD?

Right from the first contact, the official name "Principles for the proper management and storage of books, records, and documents in electronic form as well as for data access" (GoBD) appears at first glance to be at least as cumbersome and complex as its more extensive and complex content. Often, misunderstandings and problems arise around the 2014 newly created and six years later revised administrative regulation, which can be traced back not least to an overlap of sub-areas with other important regulations such as the General Data Protection Regulation (GDPR or DSGVO). It proves to be time- and labor-intensive without understandable explanation to want to equip an email mailbox with a legally compliant archiving function according to GoBD.

What important requirements must an archiving function according to GoBD meet?

The archiving function in the GoBD does not contain technical details that, for example, prescribe storing information in an email mailbox in predefined, certified systems or a specific format. Instead, it sets framework conditions that define minimal requirements for the legally compliant management of an email mailbox in commercial environments. The most important requirements that every archiving function must meet according to the GoBD are as follows:

• Emails are stored as copies unchanged and with original metadata
• Each email mailbox belonging to a business must be securely archived in the long term by the archiving function of the GoBD
• External access must be available quickly or "within a reasonable time"
• Messages in an email mailbox must be viewable and printable in their original state
• All processes must be reconstructible even after a change in the archive structure or a company restructuring
• A migration to other platforms or operating systems must not lead to a loss of data or information

Aside from communication such as the email inbox, the required archiving function according to the GoBD also includes all other tax and legally relevant documents that are stored digitally or electronically. This includes, among other things, photographic document capture (for example, with a smartphone). It also contains detailed minimum requirements for internal controls, documentation, electronic business records, and secure IT infrastructures that prevent data loss from hardware failures or network outages.

How can an archiving function according to the GoBD be integrated into an email inbox?

Most small and medium-sized businesses (SMBs) use a major provider like Microsoft or Google for email communication, whose products already fundamentally include an archiving function according to the GoBD. However, for self-managed email servers, it is important to ensure regular backups and redundant data storage at a second, physically distant location to document sufficient care. For quick traceability in legal or business matters, it is often useful to link messages or an email inbox to a specific business transaction and embed them in it or create references. Plug-ins provided for free by most software vendors for mail clients are suitable for this purpose. They enable a legally compliant archiving function according to the GoBD, as well as GDPR and other legal requirements. Additionally, they offer a significantly greater number of features for functions such as search, assignment to business cases, or thematic organization of messages.

What other solutions enable an archiving function according to the GoBD?

Even in a medium-sized SMB, the issue quickly arises that the high number of active and already processed messages makes a structured filing system sensible to expedite business processes or external audits. A reliable solution in this situation is software for Enterprise Resource Planning (ERP), which categorizes, maps, and, if desired, organizes and displays the entire value creation process in a company according to individual criteria in a clear manner. Depending on the industry, scope, and reach, these solutions vary significantly from one another and range from free open-source projects to highly specialized IT solutions tailored to individual cases.

The by far easiest, but also the most inconvenient option in terms of research, is to redundantly back up each email inbox to external storage devices or a fail-safe NAS to create legally relevant copies and to store them even after discontinuing business operations without ongoing expenses for the legally required retention period. Another option is to use pre-made solutions like Hosted Exchange, which are usually associated with long-term costs.