E-Invoice Archiving in Germany: GoBD Rules and Retention Periods

To archive an e-invoice in Germany, keep the received XML file unchanged, complete and machine-readable for eight years (§ 14b UStG, § 147 AO). For a ZUGFeRD invoice, the XML part is enough; the PDF is needed only if it carries extra tax-relevant information. These are the rules of the GoBD as amended on 14 July 2025.

Last reviewed: September 2026. This article is general information, not tax advice.

Which file do you have to keep?

The GoBD (principles for keeping and storing books, records and documents electronically, including data access) are the Federal Finance Ministry's rules for digital bookkeeping. The second amendment of 14 July 2025 (opens in a new tab) adapted them to mandatory e-invoicing. Incoming electronic documents must be kept in the format in which they were received (para. 131), so an XRechnung is kept as XML. For e-invoices under § 14(1) sentences 3 and 6 UStG, the structured part is sufficient. You only need to keep the human-readable part as well if it holds additional or deviating tax-relevant information, such as booking notes or qualified electronic signatures.

For ZUGFeRD, example 10 of the GoBD makes clear that it does not matter whether you only use the invoice image. What matters is that the XML part exists and is not deleted by a format conversion, for example to TIFF. If the PDF carries booking notes, those must be kept too, and machine readability then extends to the whole PDF. Our comparison XRechnung vs. ZUGFeRD explains how the two formats differ, and our guide what is ZUGFeRD covers the hybrid format in detail.

How long must e-invoices be kept in Germany?

Since 1 January 2025, accounting vouchers (Buchungsbelege) have an eight-year retention period instead of ten. The change came with the Fourth Bureaucracy Relief Act (Viertes Bürokratieentlastungsgesetz). The periods are set in § 147 AO (opens in a new tab), the German Fiscal Code; for invoices, § 14b(1) UStG sets the same eight years.

The period starts at the end of the calendar year in which the invoice was issued or received. Example: an e-invoice dated 15 March 2026 must be kept until 31 December 2034 and may be deleted from 1 January 2035 at the earliest. However, the period does not expire as long as the documents matter for taxes whose assessment period is still open, for example during an ongoing tax audit. The glossary entry on the retention obligation (Aufbewahrungspflicht) has more background.

What do the GoBD require from your archive?

Immutability

Under § 146(4) AO, a record must not be changed in a way that makes the original content impossible to determine. The GoBD do not prescribe a specific technology. Common approaches are archives that lock files after storage, log every change or keep every version. A file in an ordinary network folder, by contrast, can be replaced by anyone with write access without leaving a trace.

Completeness, order and retrieval

Every invoice must be captured, and an auditor must be able to find it within a reasonable time. That requires an index, for example invoice number, date, issuer and amount. It must also be possible to trace the path from the accounting entry to the document and back. Many programs do this with a document number or a link in the booking record.

Machine readability and legibility

Structured data must stay machine-readable, so the tax office can process the XML as data, not just as an image. You must also be able to make documents readable; under § 147(5) AO you provide the tools needed. A raw XRechnung is hard to read. Our xrechnung viewer renders UBL and CII files as a readable invoice. For ZUGFeRD files, you can extract XML from PDF to check the embedded data. Other XML documents open formatted in the XML Viewer.

Procedure documentation

The procedure documentation (Verfahrensdokumentation) describes how documents arrive, are checked, booked, archived and deleted once the period ends. It covers receiving channels (such as an invoice mailbox or Peppol), software used, access rights, backups and internal controls. Update it whenever processes or software change.

Data access during a tax audit (Z1, Z2, Z3)

Under § 147(6) AO, the tax authority has three types of access:

• Z1, direct access: the auditor gets read-only access to your system.
• Z2, indirect access: you evaluate the data by machine according to the auditor's specifications, or have it evaluated, and provide the result in machine-readable form (GoBD para. 166 as amended in 2025).
• Z3, data transfer: you hand over the data in a machine-readable format.

Test in advance whether your archive can export the original XML files together with their index.

VAT law or Fiscal Code: which rules apply where?

The Finance Ministry letter of 15 October 2025 (opens in a new tab) separates the two levels. For VAT, § 14b UStG requires every invoice to be kept for eight years while ensuring authenticity of origin, integrity of content and legibility. For an e-invoice, at least the structured part must remain intact in its original form. Storing e-invoices outside a GoBD-compliant system is not, by itself, a breach of § 14b UStG for VAT purposes (para. 60).

For all other purposes, such as an income tax audit, the letter refers to the GoBD (para. 61). Storage that satisfies VAT law can therefore still be challenged in a tax audit. Serious defects can lead the tax office to reject the bookkeeping and estimate the tax base (§ 162 AO).

Why is an email inbox not an archive?

An ordinary email inbox is enough for receiving e-invoices. As an archive it usually falls short: messages can be deleted or moved, many mailboxes have automatic deletion rules, and there is no index and no link to the accounting entry. When an employee leaves, their mailbox often goes with them.

Move XML attachments into the archive promptly. If the email only transports the invoice and contains no other tax-relevant content, the email itself need not be kept. If it does contain tax-relevant information, such as an agreed price reduction, keep it as well.

What archiving options are there?

German vendors often advertise 'revisionssicher' (audit-proof) archiving. It is not a legal term; it describes an archive that meets the GoBD requirements above. Common setups:

• Archive module of your accounting or ERP software: document and booking live in the same system.
• Document management system (DMS): useful for high volumes or several source systems.
• Plain file storage on a network drive or cloud service: only with versioning, logging, access rights and a documented process; risky without them.
• The docutools.pro Pro plan includes a 'GoBD Vault' for storing e-invoices. Assess it like any other option in your procedure documentation; details are on the pricing page.

Software certificates or audit opinions are a helpful signal, but they do not bind the tax authority. What counts is how you use the system.

Step by step: from incoming invoice to archive

1. Receive: the e-invoice arrives by email, portal or Peppol.
2. Check: validate the file and run the VAT details through our German invoice requirements checker. Our guide to fixing XRechnung validation errors explains the error messages.
3. Save the report: the Finance Ministry recommends keeping the validation report as evidence.
4. Archive: store the original file unchanged, assign an index, attach the report.
5. Book: link the accounting entry and the document unambiguously.
6. Delete: only after the period has ended and only if no extension applies.

Checklist: storing e-invoices under the GoBD

• Original XML stored unchanged; for ZUGFeRD, the received file
• PDF part kept as well if it has booking notes or deviating data
• No conversion that replaces the XML
• Eight-year period from year end recorded
• Index and link to the accounting entry in place
• Export for Z1, Z2 and Z3 tested
• Procedure documentation up to date

Our GoBD checklist template goes into more detail. The obligations for receiving e-invoices since 2025 are covered in our guide to the German e-invoicing mandate. More articles are in the invoicing category.