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E-RECHNUNG

E-Rechnung Archivierung: what must survive, and in what form

Archiving is where e-invoicing compliance quietly succeeds or fails, years after the invoice was paid. The rules are specific: eight years, the structured part unaltered in its original form, machine-readable throughout, and the GoBD were amended in 2025 to say so about e-invoices explicitly. This guide covers the retention rules, what counts as compliant storage, and the mistakes that only surface in an audit.

Last updated: September 16, 2026

The retention rules

Under § 14b UStG, a business keeps a duplicate of every invoice it issued and every invoice it received for eight years, the period starting at the end of the calendar year in which the invoice was issued. The duty covers both directions of your invoicing and applies regardless of format; what the e-invoice changes is what "keeping the invoice" means, because the invoice is now a data record.

The operative standard is the GoBD, the BMF’s principles for keeping books and records in electronic form, issued November 28, 2019 and amended most recently on July 14, 2025 precisely to accommodate the mandatory e-invoice. The amended text is explicit: of an e-invoice, at least the structured part must be preserved so that it exists unaltered in its original form. The BMF FAQ says the same. A rendering, a printout, or a re-export is not the original.

What GoBD-compliant archiving means for e-invoices

Four properties, all of them checkable in an audit:

  • Unaltered original. The received or issued file itself is what you store; the archive must guarantee the structured part stays byte-true from capture to the end of the retention period.
  • Immutability (Unveränderbarkeit). Changes must be impossible or fully logged. A shared drive where anyone can overwrite files fails this; a DMS or archive system with versioning and audit trail passes.
  • Machine evaluability (maschinelle Auswertbarkeit). Auditors may process your records electronically, so the XML must remain readable as data. Flattening an XRechnung into a PDF or paper destroys exactly the property the format exists for.
  • Traceability and documentation. The GoBD expect an orderly, documented process: where invoices enter, how they are captured, who can do what in the archive, laid down in a Verfahrensdokumentation.

Common practices, judged

PracticeCompliant?
Storing the received XRechnung XML in an immutable DMS with audit trailYes; this is the intended pattern
Archiving a ZUGFeRD invoice as the complete original file (PDF with embedded XML)Yes; the structured part is preserved inside the original
Keeping only the PDF layer of a ZUGFeRD invoice, discarding the XMLNo; the legally decisive structured part is lost
Printing e-invoices and filing paperNo; neither original form nor machine evaluability survives
Leaving invoices in the email inbox as the archiveRisky; mailboxes rarely guarantee immutability, retention, or orderly retrieval
Re-keying invoice data into the ERP and deleting the fileNo; the data record itself must be retained, not just its content

For hybrid invoices, the safe default is archiving the complete original file; the embedded XML is the part the law cares about, per the BMF letter of October 15, 2025 and the amended GoBD.

Where the archive may live

§ 14b UStG also regulates geography: a business established in Germany keeps invoices in Germany or, as electronic records with full remote access for the tax authorities, elsewhere in the EU, notifying the tax office where the archive is kept outside Germany. Standard European cloud archives fit this comfortably; sovereignty questions start where storage leaves the EU. The same online-access condition is what makes purely electronic archiving legally equivalent to the filing cabinet.

One boundary is worth drawing honestly: an extraction layer is not an archive. Talonic reads, validates, and structures incoming invoices, and hands your systems schema-validated data with confidence and provenance per field, processed on EU infrastructure in Germany; the audit-proof eight-year retention of the originals belongs in your DMS or ERP archive. The clean architecture keeps both: originals immutable in the archive, extracted data driving the process.

Frequently asked questions

How long must e-invoices be archived?+

Eight years under § 14b UStG, for issued and received invoices alike, starting at the end of the calendar year the invoice was issued. The duty applies to the invoice as a data record: the structured part must remain unaltered in its original form throughout.

Is printing an e-invoice an acceptable archive?+

No. A printout destroys the original form and the machine evaluability the GoBD require; the amended GoBD name the structured part of an e-invoice explicitly as what must survive unaltered. Paper can accompany the archive; it cannot be the archive.

Which part of a ZUGFeRD invoice must I keep?+

At least the structured XML, unaltered, and in practice the complete original file, which contains it. Keeping only the PDF layer fails the requirement, because since the BMF letter of October 15, 2025 the embedded XML is the legally decisive representation.

May the archive be in the cloud?+

Yes. § 14b UStG allows electronic storage in Germany, and elsewhere in the EU when full online access for the authorities is ensured and the tax office is notified of the location. What decides compliance is immutability, retention, and access, not whether the disks are yours.

Do the GoBD apply to a small business without an ERP?+

Yes; the principles scale with the business, but they do not switch off. Even a minimal setup must keep received e-invoice files unaltered and findable for eight years, which a disciplined folder structure with backups or a small DMS already achieves. What fails is ad-hoc storage in mailboxes and desktop folders.

Sources

Primary sources, last checked September 2026. Statutory texts and BMF publications are authoritative; where guidance rests on the BMF letter of 15 October 2025, the text says so.

This guide is general information for businesses, compiled from the cited official sources. It is not legal or tax advice; for decisions about your own obligations, consult your tax advisor (Steuerberater).

One inbox, every invoice format, one schema

The mandate makes structured formats the norm, but your accounts payable will keep receiving paper scans and plain PDFs beside XRechnung and ZUGFeRD for years. Talonic normalizes that mixed inflow into one schema-validated output: typed fields, a confidence score, and provenance on every value, processed on EU infrastructure in Germany. Send a sample batch and judge the output field by field.