Tax & Law

Document Retention Obligation

Definition

The statutory retention obligation requires companies to retain invoices and other tax-relevant documents for a period of 10 years (§ 147 AO). Electronic invoices must be archived in their original electronic form — retention solely as a printout is insufficient. The GoBD specify the technical and organisational requirements for audit-compliant archiving.

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Related terms

GoBD (Principles for the Proper Keeping and Storage of Books, Records and Documents in Electronic Form)The GoBD are administrative guidelines issued by the German Federal Ministry of Finance for audit-compliant archiving and retention of tax-relevant documents in electronic form. They set requirements for immutability, completeness, orderliness, traceability, and machine readability. Electronic invoices must be retained in compliance with GoBD requirements — i.e., in their original electronic format, not as printouts.PDF/A-3PDF/A-3 is an ISO standard (ISO 19005-3) for long-term archiving of PDF documents that, unlike earlier variants (PDF/A-1, PDF/A-2), allows embedding of arbitrary file types as attachments. ZUGFeRD and Factur-X exploit this capability to embed the XML invoice data inside the PDF file, making the document simultaneously human-readable and machine-processable.E-InvoiceAn e-invoice in the strict sense is an invoice that is issued and received in a structured, machine-readable format and enables automatic electronic processing. In the German context, particularly following the Growth Opportunities Act, e-invoice explicitly refers to structured formats (XRechnung, ZUGFeRD/Factur-X, Peppol BIS), while pure PDF invoices no longer qualify. Hybrid formats such as ZUGFeRD count as e-invoices because they contain the XML structured data.Input VATInput VAT refers to the value added tax a business pays on purchases of goods and services, which it can deduct from its own VAT liability to the tax authority (input tax deduction). A prerequisite for the input tax deduction is a proper invoice (§ 14 UStG), which for electronic invoices means correct compliance with all mandatory fields under EN 16931.