E-Invoice Archiving in Germany: GoBD Standards, Retention & Compliance

Germany’s B2B e-invoicing rollout is changing how businesses handle invoice archiving. From January 2025, businesses must be able to receive structured e-invoices, while mandatory B2B e-invoice issuance is being introduced in phases from 2027 onwards. 

Due to this important change in law, businesses are now required to store invoices as per the GoBD standards. GoBD is short for ‘Grundsätze zur ordnungsmäßigen Führung und Aufbewahrung von Büchern, Aufzeichnungen und Unterlagen in elektronischer Form sowie zum Datenzugriff’. In English, this translates to principles for the proper management and storage of books, records, and documents in electronic form, as well as for data access.

Key Takeaways

• Germany requires businesses to archive invoices according to GoBD principles.
• As per GoBD standards, invoices usually need to be retained for 8 years.
• Once a digital record is entered, it cannot be altered or deleted.
• Poor invoice archiving can affect VAT claims and audit outcomes.

What is e-invoice archiving?

E-invoice archiving refers to the storing of electronic invoices in a way that ensures that they are secure, readable, and unchanged over time. Further, they should be stored in a way that they can be retrieved at any point in time for audit or tax purposes. 

In Germany, businesses are expected to retain not only the invoice itself but also the underlying structured data connected to it.

What is GoBD archiving?

GoBD archiving refers to Germany’s standards for storing digital business and tax records correctly. These rules require that invoice records remain complete, tamper-proof, traceable, and accessible during audits. 

It also means that businesses should be able to retrieve archived invoices without unnecessary delays or manual reconstruction.

In the case of an e-invoice, its structured data embedded in the XML must be stored in such a way that it remains intact in its original form throughout the retention period. 

Why is Invoice Archiving Required?

Invoice archiving exists as a source of evidence for tax and audit purposes. German tax authorities want businesses to prove that financial transactions actually happened the way they were reported. Invoices become part of this proof, especially for VAT deductions. If a business cannot retrieve invoices during an audit, tax authorities can classify the expenses as invalid and disallow VAT claims. 

This can result in overstating profits and an inflated tax burden. The business could also be liable to fines and penalties. This is especially true for structured electronic invoices such as XRechnung and ZUGFeRD because these are not ordinary invoice files. 

XRechnung is a machine-readable, pure XML format, while ZUGFeRD is a hybrid format that embeds structured XML data inside a human-readable PDF. In both cases, there is data contained within these invoices in the form of a machine-readable XML, meant to be read and processed by computers. 

If this data is altered or lost while stored or migrated, the invoices will no longer comply with data retention norms. Several companies still make a common mistake here. They archive the PDF version of a ZUGFeRD invoice but lose the XML data embedded within it. On the surface, this may look fine because the invoice is still visible. But technically, the invoice information has been lost.

Retention Periods in Germany

Germany generally requires businesses to retain invoices for a period of 8 years*. This applies to electronic invoices as well as paper invoices.

For VAT purposes, the German VAT Act (UStG) stipulates that- 

• A business must retain a copy of every incoming and outgoing invoice for eight years.
• Recipients of property-related services must retain invoices or payment evidence for 2 years. This applies when the recipient:
• is not a business, or
• is a business owner, but used the service privately rather than for business purposes.

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

For electronic records, the structured portion must be stored in such a way that it remains intact in its original form. The archived invoice should remain readable throughout the retention period. 

*Under the Fourth Bureaucracy Relief Act (Viertes Bürokratieentlastungsgesetz effective 1st January 2025), Germany reduced the retention period for certain documents such as payroll records/pay slips, account statements, and invoices from ten years to eight years. However, vital financial and tax records, such as accounting ledgers, stock records, inventory lists, and yearly financial reports must still be kept for ten years.

Risks of Non-Compliance

Poor invoice archiving creates more issues than most businesses realise. Sometimes, invoices cannot be retrieved during audits. Sometimes, the files open, but the structured data behind them is missing or corrupted. Situations like these can create compliance exposure.

Businesses may face issues such as:

• Rejected VAT deduction claims
• Lengthy and expensive audit processes
• Mandatory tax reassessments
• Financial penalties
• Questions around accounting integrity

GoBD principles expect archived records to remain protected against unauthorised changes. If invoices can be edited, replaced, or deleted without proper controls, auditors may question the reliability of the archive itself.

Advantages and Disadvantages of E-Invoice Archiving

E-invoice archiving comes with both advantages and disadvantages.

Advantages

• Enhances record organisation
  The archiving of e-invoices will reduce the reliance on conventional methods of storing information, such as across scattered email folders and physical files.
• Facilitates better compliance
  Archiving makes it easy for companies to comply with German compliance regulations related to GoBD standards and the VAT Act (UStG).
• Improves audit readiness
  It is easier for organisations to access invoices during audit checks.
• Simplifies long-term storage
  Long-term storage at scale is much simpler and more convenient compared to paper-based storage.

Disadvantages

• Setup costs 
  Businesses may need new ERP-integrated archiving software or process changes, resulting in additional unbudgeted costs.
• Migration risks
  Migrating invoice records from one system to another can create data integrity issues if handled poorly.
• Internal misunderstandings and additional training
  It is common practice in many companies to save invoices in PDF format as they are considered digital documents. Under e-invoicing norms, this would amount to non-compliance, and staff will need to be trained accordingly.
• Ongoing maintenance
  The e-invoice archiving solution should be constantly monitored and updated. Further, access control must be maintained.

How to Archive E-Invoices in Germany

No specific software has been prescribed for archiving electronic invoices according to German regulations. Nonetheless, it is important that the stored invoices must be accessible, readable, protected against any alterations, and easy to access at a later date. In practice, most medium and large companies use ERP-integrated archiving systems or document management platforms for invoice archiving.

The guidelines for proper archiving of e-invoices include that the invoice be archived-

• In their original electronic format;
• Along with its structured XML data;
• In systems that prevent unauthorised edits;
• With proper timestamps and audit trails;
• In a format that is easily searchable and retrievable.

Moreover, access control is equally important. No employee should be able to overwrite an archived invoice record.

Another important thing that businesses often forget is that these compliance obligations apply to incoming (supplier) invoices too. 

Conclusion

Germany’s VAT compliance rules now extend to e-invoicing and are changing the way businesses store and retrieve their invoices. It is no longer just a document sitting in a folder somewhere, but is now part of a structured digital audit trail.

This shift matters because tax authorities are increasingly expecting businesses to preserve invoice records exactly as they were created. For e-invoices, this means that its structured data has to be preserved in its original form.