ED14 - Authority Interface Practice: ELSTER, DE-Mail, eXTra - Mediation by GitCover
Problem
Many authority interfaces are legally regulated, but in practice barely usable for laypeople:
- ELSTER: complex, error-prone - the ELSTER interface requires certificates, XML formats, client software - a hurdle for laypeople
- DE-Mail: discontinued - DE-Mail was planned as a secure communication channel with authorities, but is officially discontinued (last provider on 31.12.2026). Archived emails in discontinued systems are no longer accessible - a GoBD-relevant retention problem
- eXTra: unknown - the eXTra format (SV data) is for payroll offices, not for entrepreneurs - but during a DRV audit it suddenly becomes relevant
- Z3 data carrier: specialist knowledge - the GoBD-compliant Z3 export requires specialist software or manual preparation
- Interface errors: not documented - if ELSTER or DE-Mail fail, the error is not logged in the repo - the evidence "I tried" is missing
- Regulation binding: not assigned - every interface transmission is bound to a regulation (e.g. LStA → § 41a EStG), but this assignment is not documented
Core message
The GitCover harness mediates between external systems and risk-affine regulations:
- ELSTER mediation - LStA, UStA, LSt certificate via ELSTER interface; receipt as evidence with sidecar
- DE-Mail: discontinued - migration required - historical DE-Mails must be migrated to the repo before shutdown as EML + SHA-256 + sidecar; archived emails in discontinued systems are no longer accessible - GoBD retention problem
- eXTra/euBP export - SV data in eXTra format exportable for DRV audits
- Z3 data carrier export - GoBD-compliant Z3 export for FA external audits (git bundle as self-contained archive)
- Interface error logging - errors/abortions of external systems are logged as repo events
- Regulation binding - every interface operation is mapped to the risk-affine regulation
Compliance by Design: The harness does not hide the complexity of authority interfaces - it documents it. Every transmission, every receipt, every error is captured traceably in the repo.
The authority interface landscape
| Interface | Purpose | Complexity | GitCover mediation |
|---|---|---|---|
| ELSTER | LStA, UStA, LSt certificate, e-invoice viewer | high (certificate, XML, client) | receipt as evidence with sidecar |
| DE-Mail | Secure communication with authorities | discontinued (last provider 31.12.2026) | migration: EML + sidecar into repo; warning |
| eXTra/euBP | SV data for DRV audits | high (specialist format) | export from repo data |
| Z3 data carrier | GoBD-compliant export for FA external audit | high (specialist software) | git bundle as self-contained archive |
ELSTER mediation
| Step | Action | GitCover implementation |
|---|---|---|
| LStA calculated | Payroll tax registration from payroll | JSON artefact in repo (see ED11) |
| ELSTER submission | Electronically via ELSTER (certificate required) | harness calls ELSTER |
| Receipt | ELSTER confirms transmission | receipt as evidence with sidecar |
| Repo entry | LStA with source_sha256 on receipt |
tags: ["lsta", "§41a-estg"] |
| Regulation binding | LStA → § 41a EStG | vorschrift: "§41a-estg" in artefact |
| Error logging | ELSTER error is logged | repo event with error description |
Regulation binding: Every interface operation is mapped to the risk-affine regulation - e.g. LStA → § 41a EStG, UStA → § 18 UStG, LSt certificate → § 41b EStG. This makes it traceable which regulation was fulfilled by which transmission.
DE-Mail - discontinued: migration and archival consequences
DE-Mail is officially discontinued. The project is considered failed. The last provider (FP Digital Business Solutions GmbH) will shut down the service on 31.12.2026 - after that DE-Mail is no longer usable and archived emails in these systems are no longer accessible.
| Event | Date | Source |
|---|---|---|
| Telekom discontinues De-Mail | 31.08.2022 | "due to lack of economic viability" |
| 1&1 De-Mail GmbH discontinues | 07.02.2025 | service no longer reachable |
| § 130a ZPO repealed | 22.12.2025 | De-Mail as secure transmission path abolished (BGBl. 2025 I Nr. 349) |
| Federal administration discontinues | July 2024 | mandatory use ended |
| Last provider (FP Digital) discontinues | 31.12.2026 | "Thus De-Mail is history" |
| Bundesrechnungshof 2021 | 2021 | 2011-2020: ~6,000 De-Mails from authorities, savings ~3,500 EUR, costs >= 6.5 Mio. EUR |
| CCC criticism | 2013 | Linus Neumann (30C3): "Bullshit made in Germany - intentionally built insecure" |
DE-Mail is history: The last provider (FP Digital Business Solutions GmbH) will shut down the service on 31.12.2026. The statutory recognition as a secure transmission path (§ 130a Abs. 4 Nr. 1 ZPO) was repealed on 22.12.2025. The federal administration ended mandatory use in July 2024. The Bundesrechnungshof summarised in 2021: 6.5 Mio. EUR costs for ~3,500 EUR savings. A successor, "European Business Wallet (EBW)", is planned.
Consequences of archived emails in discontinued systems
When a DE-Mail provider shuts down its service, immediate GoBD-relevant retention problems arise:
| Problem | Consequence | GoBD reference |
|---|---|---|
| Mailbox no longer accessible | emails can no longer be retrieved | § 146 Abs. 5 AO ("available at any time") |
| Provider-side deletion | after shutdown data is deleted | § 147 Abs. 1 AO (retention obligation 6 years) |
| No export possible | if the provider offers no export function, data is irretrievably lost | GoBD Rz. 146 (traceability) |
| Evidentiary value lost | DE-Mail-specific confirmations (dispatch/delivery confirmation) can no longer be verified | loss of evidence in authority dispute |
| No forensic preservation | a layperson can hardly forensically upgrade the authenticity of old emails afterwards - without provider infrastructure the verification data (signature check, timestamp server, provider logs) is missing | evidentiary downgrade to "mere PDF copy" |
| Retention period still running | emails from 2024 must be retained until 31.12.2030 - but the system is gone in 2026 | GoBD violation through unavailable retention |
Forensic preservation - barely recoverable: DE-Mail-specific evidentiary features (qualified electronic signature of the dispatch and delivery confirmation, provider timestamp, integrity hash) can only be verified within the running provider infrastructure. After shutdown these verification data are no longer available. A layperson cannot subsequently verify an exported EML file for its DE-Mail-specific authenticity - signature checking fails for lack of the provider certificate, the timestamp server is offline, the provider logs are deleted. The email loses its status as "legally binding DE-Mail communication" and degenerates to a mere PDF copy with strongly reduced evidentiary value. Subsequent forensic preservation by an expert would be theoretically possible, but practically barely feasible - the required provider infrastructure data no longer exist.
Critical warning - migrate before shutdown: Entrepreneurs who still have a DE-Mail mailbox must before shutdown export all relevant emails as EML files and migrate them into the Git repo (EML + SHA-256 + sidecar). After shutdown an export is no longer possible - the data is irretrievably lost. This is a GoBD violation if the retention period is still running (6 years from year-end, § 147 Abs. 1 Nr. 2/3 AO).
GitCover migration: DE-Mail -> repo
| Step | Action | Deadline |
|---|---|---|
| Export | export all relevant emails as EML | before shutdown (at the latest 31.12.2026) |
| SHA-256 | compute hash per EML file | on migration |
| Sidecar | .v7g.md per EML with classification |
on migration |
| Storage | EML + sidecar in sources/korrespondenz/ |
on migration |
| Verification | check completeness (number of emails) | after migration |
Practical tip: The migration should be carried out immediately, not just before shutdown. Providers may restrict the service early (e.g. no new registrations, restricted export). Those who wait risk data loss.
| Aspect | Problem | GitCover solution |
|---|---|---|
| Status | DE-Mail officially discontinued (last provider 31.12.2026) | warning: do not use; migration required |
| Cost/benefit | 6.5 Mio. EUR costs, ~3,500 EUR savings (Bundesrechnungshof) | git bundle and ELSTER mailbox are free |
| Security | "intentionally built insecure" (CCC, Linus Neumann 2013) | Git + GPG + SHA-256 |
| Statutory recognition | § 130a ZPO repealed on 22.12.2025 | no longer relevant |
| Archiving | archived emails in discontinued systems no longer accessible | migration: EML + SHA-256 + sidecar into repo |
| Retention period | emails from 2024 must be retained until 2030 - system gone in 2026 | GoBD violation for non-migrated data |
| Successor | European Business Wallet (EBW) planned | open; GitCover independent |
DE-Mail disaster mitigation: The harness warns on use of DE-Mail (if historical mailboxes still exist) and recommends immediate migration of all relevant emails as EML + sidecar into the repo. After shutdown (at the latest 31.12.2026) the data is irretrievably lost - a GoBD violation if the retention period is still running. As an alternative for future communication: ELSTER mailbox for tax topics, regular email + sidecar archiving for correspondence.
eXTra/euBP export and Z3 data carrier
| Export | Purpose | Format | Recipient |
|---|---|---|---|
| eXTra/euBP | SV data for DRV audit | eXTra V3.4.0 (XML) | DRV |
| Z3 (git bundle) | GoBD data for FA external audit | git bundle + manifest + static web (Z3+) | FA |
Practical example: The DRV requests SV data in eXTra format during a Betriebsprüfung. The harness exports the relevant payroll and SV data from the repo as eXTra XML. The FA requests GoBD-compliant data (Z3) during an external audit - the harness generates a git bundle + static web (Z3+, see ED04). Both exports can be generated from the structured repo data (JSON, sidecars) - no manual preparation needed.
Interface error logging
| Event | Action | GitCover implementation |
|---|---|---|
| Success | receipt archived | evidence with sidecar, source_sha256 in artefact |
| Error | error logged | repo event with error description, timestamp, regulation |
| Evidence | "error not self-inflicted" | repo event as evidence during audit |
Important - liability shift: If an interface fails (e.g. ELSTER timeout on the 10th of the month), the error logging in the repo documents that the entrepreneur tried to transmit in time. This is evidence under § 152 AO (late payment surcharge)
- the entrepreneur can argue that the error was not in their sphere.
Risk leverage
| Today (cheap) | Tomorrow (audit-proof) | Risk mitigated |
|---|---|---|
| ELSTER receipt as evidence with sidecar | transmission verifiable | late payment surcharge § 152 AO |
| DE-Mail warning + alternative | suitable channel chosen | loss of communication |
| eXTra export from repo data | SV data available for DRV audit | GoBD violation during DRV audit |
| Z3 export as git bundle | GoBD data available for FA audit | GoBD violation during FA audit |
| Interface error logging | evidence "tried" | liability shift on interface failure |
| Regulation binding | regulation per transmission documented | dispute of regulation fulfilment |
Harness requirement (preview)
Derivable from ED14:
| ID | Requirement | Priority |
|---|---|---|
| FA-12.1 | ELSTER mediation: LStA, UStA, LSt certificate; receipt as evidence with sidecar | MUST |
| FA-12.2 | DE-Mail/De-Mail bridge: EML + SHA-256 + sidecar; sender verification | SHOULD |
| FA-12.3 | eXTra/euBP export: SV data in eXTra format for DRV audits | SHOULD |
| FA-12.4 | Z3 data carrier export: GoBD-compliant Z3 export (git bundle) | SHOULD |
| FA-12.5 | Interface error logging: errors as repo event | MUST |
| FA-12.6 | Regulation binding: every operation mapped to risk-affine regulation | SHOULD |
| FA-12.7 | DE-Mail disaster mitigation: warning on unsuitable channels | NICE |
| FA-12.8 | Authority identifiers registry | MUST |
The full requirement list in Harness-Anforderungen.md.
Sources
- AO (§ 147 Abs. 6 - data access Z1/Z2/Z3, § 152 - late payment surcharge)
- EStG (§ 41a - payroll tax registration, § 41b - LSt certificate)
- UStG (§ 18 - VAT pre-registration, § 14 - e-invoice)
- SGB IV (§ 28p - DRV Betriebsprüfung, § 28a - DEÜV registrations)
- GoBD (BMF letter, Rz. 147 - verifiability, Z3 data access)
- DE-Mail (Wikipedia, as of 14.08.2026) - "Thus De-Mail is history": Telekom 31.08.2022, 1&1 07.02.2025, § 130a ZPO 22.12.2025 repealed, federal administration July 2024, FP Digital 31.12.2026, Bundesrechnungshof 2021
- BGBl. 2025 I Nr. 349 - Act repealing § 130a Abs. 4 Nr. 1 ZPO (DE-Mail)
- Bundesrechnungshof annual report 2021 - DE-Mail: 6.5 Mio. EUR costs, ~3,500 EUR savings
- CCC 30C3 2013 - Linus Neumann: "Bullshit made in Germany"
AFJD/agents/(anonymised) - SSoT concept with ELSTER, interface error logging
Source topology and CDN reference links
| Role | Location | Purpose |
|---|---|---|
| Primary / SSoT | git.gitcover.org/GCC | Canonical storage (GPG-signed, versioned) |
| Public OSS Mirror / CDN | codeberg.org/gitcover-commons | Read-only mirror; FLOSS discovery |
| Community Hub | github.com/gitcover-commons | Issues & discussions; source code reference to Codeberg |
Note: This assignment of sources, mirror and community hub reflects the current state and may change. Please check the respective canonical source on gitcover.org for the current state.