How long must e-invoices be retained?

The Deadline

The Fourth Bureaucracy Relief Act has shortened the retention period for accounting documents – which includes invoices – from ten to eight years. The shorter period applies to all documents whose retention period had not yet expired at the beginning of 2025.

The ten-year period for commercial books, inventories, annual financial statements, and management reports remains unchanged. Additionally, if the tax assessment period is still ongoing, the retention obligation is extended accordingly.

What Exactly Must Be Retained

For an e-invoice, the structured data part is the original. This means:

• No printout. A paper printout does not fulfill the obligation.
• No pure PDF copy. For ZUGFeRD, the file must retain the embedded XML – if only the visible PDF is saved, the original is lost.
• Unalterable. Subsequent changes must be excluded or logged.
• Machine-readable. The file must remain readable and searchable throughout the entire retention period.

Common Oversights

The procedural documentation. The GoBD requires a description of how invoices are received, checked, recorded, and archived. If this is missing, an audit can challenge the entire accounting – regardless of whether the files are present.

The email inbox is not an archive. An inbox does not meet the requirements for unalterability or evaluability.

This overview does not replace tax advice.