Germany’s E-Invoice Archiving and Retention Requirements

The e-invoicing retention period in Germany is 8 years from the end of the calendar year in which the invoice was issued. For E-Rechnungen, businesses must also store the structured invoice data while maintaining its authenticity, integrity and readability.

What Is the Germany E-Invoice Retention Period?

Under Section 14b of the German VAT Act (UStG), businesses must retain invoices for 8 years, covering both invoices issued and received.

The retention period begins at the end of the calendar year in which the invoice was issued, rather than on the invoice date.

The 8 year period is the core VAT invoice-retention requirement. Other business records may be subject to different statutory retention periods, so businesses should not apply a single retention period to all financial records.

What E-Invoice Data Must Be Archived for Compliance?

An E-Rechnung is not simply a PDF delivered electronically. At least the structured part of an E-Rechnung must be retained in its original, unaltered form.The structured part contains the machine-readable invoice data, such as XML. 

This distinction is particularly relevant where businesses use e-invoicing providers, ERP systems, accounting platforms, and long-term archives that process or transform invoice data.The BMF states that for E-Rechnungen, retaining the structured portion in its original, unaltered form is sufficient under the GoBD, provided the applicable GoBD requirements are met.

What must the e-invoicing provider store?

Where an external provider performs invoice archiving or retention functions, the business should ensure that the provider stores the legally relevant structured invoice data in the required form and maintains its accessibility throughout the retention period.

The legal retention responsibility remains relevant to the business even when the technical archive is operated by a third-party provider. Provider contracts and service arrangements should therefore clearly address retention, data integrity, retrieval, and access.

What Conditions Must an E-Invoice Archive Meet?

Retention is not limited to keeping an invoice file for 8 years. The retained information must remain available, readable, and retrievable when required, while the structured portion of an E-Rechnung remains unaltered.

• Identification: The retained invoice should be identifiable as the invoice issued or received.
• Integrity: The structured invoice data must remain in its original, unaltered form.
• Readability: The retained information should remain readable throughout the retention period, including after system changes.
• Retrieval: Relevant invoices and associated electronic information should be capable of being located and retrieved when required.
• Tax authority access: Where required, archived information must be capable of being provided to the tax authorities in the prescribed manner.

How should a company test historical retrieval?

Historical retrieval testing is a practical control rather than a separately prescribed statutory test. Finance and IT teams should nevertheless verify periodically that archived invoices can still be located, accessed, read, and retrieved after system changes or migrations.

Testing can include invoices from different retention years and different invoice formats, particularly structured and hybrid invoices. The objective is to identify failures before archived information is needed for a tax audit or other financial process.

Can E-Invoices Be Archived Outside a GoBD-Compliant System?

For VAT purposes, the BMF states that storing and archiving E-Rechnungen outside a GoBD-compliant data-processing system does not, by itself, regularly constitute a violation of Section 14b UStG or the requirement to store invoice integrity.

This does not eliminate the broader requirements governing electronic recordkeeping. The GoBD remains relevant to the orderly management, processing, and retention of electronic business records.

For businesses evaluating e-invoicing and accounting platforms, the relevant consideration is therefore not simply whether a provider labels its archive “GoBD-compliant.” The business should assess whether the overall architecture archives the required invoice data, maintains integrity, supports retrieval, and satisfies the applicable recordkeeping requirements.

Where Can Businesses Store E-Invoices?

Germany requires domestic businesses to retain invoices in Germany or in the territories specified under Section 14b UStG. Electronic retention may also be permitted elsewhere in the European Union and specified territories where the statutory requirements for online access, retrieval, and tax-authority access are satisfied.

Where invoices are stored electronically outside Germany under a permitted arrangement, the business must remain capable of providing the relevant invoices and data to the tax authorities and meeting applicable notification and access requirements.

For organisations using cloud infrastructure or external archiving providers, storage location, data accessibility, retrieval capability, and regulatory control should therefore form part of the provider assessment.

What Happens When E-Invoices Are Converted or Migrated?

Converting an E-Rechnung can create a retention risk if the structured invoice data is changed, removed, or no longer accessible.

BMF guidance requires the invoice to be retained in the format received. For an E-Rechnung, at least the structured portion must remain in its original, unaltered form. Converting an XML invoice to PDF and retaining only the PDF can therefore result in the loss of required invoice data.

The same principle applies when historical invoices are migrated between systems. Businesses should ensure that the structured data remains intact and that historical E-Rechnungen remain readable and retrievable for the applicable retention period.

How Should ZUGFeRD E-Invoices Be Retained?

ZUGFeRD is a hybrid invoice format containing structured invoice data together with a human-readable PDF component.

The structured portion must be retained in its original, unaltered form. The human-readable PDF component also requires retention where it contains additional or different tax-relevant information.

Businesses should therefore avoid treating ZUGFeRD as a PDF-only document for archival purposes. The archive design should distinguish between the structured component and the PDF component and determine whether the PDF contains information that must also be stored.

What Evidence Should Finance Request From an E-Invoice Provider? 

This is practical provider-governance guidance rather than a statutory evidence checklist.Finance and procurement teams should assess whether the provider can demonstrate that:

• Invoice data is stored correctly: The structured portion of each E-Rechnung is retained in its original, unaltered form, including relevant components of hybrid invoices such as ZUGFeRD.
• Records remain protected and accessible: The archive maintains data integrity and prevents unauthorised changes while keeping records readable and accessible throughout the retention period.
• Historical records can be retrieved: Invoices can be located and retrieved when required, including after system changes or migrations.
• Records remain portable: Historical invoices can be exported or handed over in a usable form if the provider or archive system is replaced.
• Tax-authority access can be supported: Required records can be made available for tax-authority review.

Note:The objective is to verify that the provider’s technical controls support the company’s legal retention obligations rather than relying solely on a general compliance statement.

How Does VAT Retention Differ From Broader Corporate Record Retention?

The 8-year retention period under Section 14b UStG is the core VAT requirement for invoices. It should not be treated as a universal retention period for every financial or corporate record.

Other records may be subject to different statutory retention requirements under German tax and commercial requirements. In addition, the retention period applicable to a particular record may depend on its nature and purpose.

For enterprise finance teams, the practical implication is that invoice retention should be mapped to the company's broader records-retention framework rather than managed as an isolated 8-year framework.

Conclusion 

Germany’s e-invoice retention period is 8 years from the end of the calendar year in which the invoice was issued. Compliance requires more than keeping a copy of the invoice. The structured invoice data must remain in its original, unaltered form, while the archive must support integrity, readability, accessibility, and retrieval throughout the retention period.

For businesses, the priority is to build retention into the full e-invoicing lifecycle. ERP systems, e-invoicing providers, migration processes, cloud archives, and ZUGFeRD workflows should all preserve the legally relevant invoice data and maintain reliable access for tax and audit requirements.

Frequently Asked Questions

When does the 8-year e-invoice retention period begin?

The 8-year retention period begins at the end of the calendar year in which the invoice was issued.

Do businesses need to retain the original XML file of an e-invoice?

Yes. At least the structured part of an E-Rechnung must be retained in its original, unaltered form. For hybrid invoices such as ZUGFeRD, the PDF component must also be retained if it contains additional or different information relevant for taxation. 

What must an e-invoice archive demonstrate during a tax audit?

The archive should demonstrate that the invoice remains authentic, complete, unaltered, readable, and retrievable throughout the retention period.

What happens if an e-invoice is converted into another format before archiving?

Converting an e-invoice does not replace the requirement to archive its structured data in its original, unaltered form.

Can e-invoices be archived outside Germany?

Yes, e-invoices may be archived outside Germany where the applicable legal conditions for electronic storage, access, and retrieval are satisfied.

Do You Need to Archive Both XML and PDF for E-Invoices?

For standard e-invoices, retain the unaltered structured data; for ZUGFeRD, retain the PDF where it contains additional or different tax-relevant information.