Simply printing out an e-invoice and filing it away is not enough – this means the machine-readable part is lost. This guide explains how e-invoices should be stored.

Introduction

Like all invoices, e-invoices must be retained for many years – in such a way that they remain unchanged, complete and machine-readable. For structured formats, this has specific implications that differ from those for paper invoices.

A few clarifications first, as there are often misunderstandings regarding archiving:

‘Printing them out and filing them away in a folder is enough’ is not true. Printing them out does not replace the obligation to store them digitally and destroys the structured data. What was sufficient in the past is no longer enough today.

Nor is it sufficient simply to store the file digitally somewhere. An ordinary folder on a hard drive or standard cloud storage does not meet the requirements for immutability.

Finally, there is a specific requirement under ZUGFeRD: what matters here is the embedded data record, not the appearance of the PDF.

This guide walks you through the retention period, explains the GoBD principles and the principle of retaining originals, and shows how we can take care of archiving for you.

However, if you have any doubts, please do contact us separately, as there are many specific considerations to bear in mind, particularly in the context of GoBD (procedural documentation, the exact process flow within your organisation, etc.), which can only be outlined briefly in this article.

How long you must retain documents

The retention period for invoices has changed. Under the Fourth Bureaucracy Reduction Act, it was reduced from ten to eight years for accounting documents and invoices (Section 147(3) of the German Fiscal Code (AO), Section 14b(1) of the German Value Added Tax Act (UStG)).

This shorter period applies to invoices whose retention period had not yet expired at the start of 2025 – in other words, to current and new invoices. The period begins at the end of the calendar year in which the invoice was issued.

Not everything is affected by this reduction. The ten-year period remains in force for ledgers, inventories, annual accounts and opening balance sheets. Furthermore, the period may be extended as long as the documents are relevant for tax purposes and the assessment period has not yet expired – for example, in the case of an ongoing tax audit.

The GoBD principles

The principles governing the proper keeping and storage of books, records and documents in electronic form – known as GoBD for short – set out how electronic documents are to be retained. They are based on the revised version of the Federal Ministry of Finance (BMF) circular dated 28 November 2019.

The GoBD sets out a number of requirements that every e-invoice must meet throughout the retention period.

• Immutability: Once an invoice has been archived, it must not be altered retrospectively. If a change cannot be avoided, it must be logged.
• Completeness: All invoices must be recorded and retained in full, including all components of the e-invoice.
• Machine-readability: During an audit, the tax authorities must be able to access and analyse the documents digitally.
• Retrievability and organisation: Every invoice must be retrievable and presentable within a reasonable time.
• Timeliness: Supporting documents must be recorded promptly and not only after weeks have passed since they arrived in the post.

These principles apply equally to paper and digital documents. In the case of e-invoices, the structured data must also be preserved.

Retaining original e-invoices

An e-invoice must be retained in the form in which it was issued or received. Converting it to another format is not sufficient, as this may result in the loss of the structured data.

XRechnung

An XRechnung is an XML file and must be stored as such – with the .xml extension. Exporting it as a PDF or taking a screenshot does not preserve the original, but only a copy without the structured data.

ZUGFeRD

A ZUGFeRD invoice must be retained as the original file, i.e. as a PDF containing the embedded XML data record. If the PDF is edited or saved again after receipt, the embedded data record may be lost without you realising it – the file is then no longer a complete e-invoice.

Why printing out an e-invoice is no longer of any use

The most common mistake is to print out an e-invoice, file it away in a folder and delete the file. This contravenes several principles at once.

When you print it out, the machine-readable part is lost. The printout is merely a copy and fulfils neither the requirement for machine-readability nor the obligation to retain the original.

What counts legally with ZUGFeRD

ZUGFeRD consists of two parts: the visible PDF and the embedded structured data set. The legally binding part is the structured section, i.e. the XML data.

For archiving purposes, this means that the structured part must be preserved unchanged. If the visible PDF part contains additional tax-relevant information – such as accounting notes – these must also be retained in their original form. This is set out in the BMF circular of 28 November 2019, in paragraphs 131 and 133.

In practice, this means: retain the complete ZUGFeRD file, not just the XML or just the PDF. As long as the original file is stored unchanged, both parts are covered.

Where you should not simply file e-invoices

Storing files digitally is not the same as archiving them in an audit-proof manner. A standard folder on a PC, a server or in ordinary cloud storage does not meet the requirement for immutability, as files there can be altered or deleted at any time.

Standard cloud storage services such as Dropbox, OneDrive or Google Drive are not GoBD-compliant without an appropriately secured configuration. Suitable options include archiving or document management solutions with write protection, version control and a traceable log.

For clients who work with us via DATEV Unternehmen Online, audit-proof archiving is usually handled through this system. You send us the original file, and it is stored in a GoBD-compliant manner – without you having to set up an archive yourself. Nevertheless, certain specific requirements must be observed here too (e.g. the availability of procedural documentation) in order to meet all the tax authorities’ requirements for digital archiving.

Here’s how to proceed with archiving

If you are responsible for storage, a fixed procedure helps ensure compliance with the principles. The process is the same for every incoming e-invoice.

1. Save the original file

   Save the e-invoice exactly as you received it – the XRechnung as an .xml file, the ZUGFeRD invoice as a PDF with an embedded data record.

2. You store it in a read-only format

   You transfer the file to a system that stores it in a tamper-proof format – an audit-proof archive or, if you’re working with us, DATEV Unternehmen Online.

3. You do not convert the file

   You do not convert the file or re-export it. An additional view for reading is possible, but does not replace the original.

4. You comply with the retention period

   You retain the invoice for the applicable retention period – eight years for invoices from 2025 onwards, or longer if in doubt – and do not destroy anything without prior consultation.

Common sources of error

• Printed and file deleted: The invoice is printed, filed away and the file deleted. The original, machine-readable file is then missing, which will be flagged during an audit.
• ZUGFeRD resaved: The PDF is edited or re-exported. In doing so, the embedded data record may be lost, and a complete e-invoice is no longer available.
• XRechnung saved as a PDF: A PDF is generated from the XML and only this is retained. The structured data is missing; the original is not preserved.
• Stored in a standard folder: The file is located in a standard directory or cloud storage. Without immutability, this does not comply with the GoBD.
• Destroyed too early: Documents are disposed of after eight years, even though a longer retention period applies. This can lead to problems if an audit is ongoing or the assessment period is still open.
• Recorded too late: Invoices remain in the inbox for weeks. This breaches the requirement for timely recording and makes it difficult to record them in full.

Frequently asked questions

Legal notice

This article provides an overview and is not a substitute for individual advice. The legal situation and its interpretation may change; the current status at any given time is decisive. Which retention period applies to a specific document and whether an extension applies depends on the individual case.

Before you destroy any documents, please contact us directly.

As at: June 2026