E-Invoice Archiving in Germany: What GoBD Actually Requires

You've got your e-invoicing sending and receiving sorted. The XML validates. Your accountant is happy. Then someone asks: "So how are you storing these invoices?" — and the room goes quiet.

Archiving is the part of e-invoicing compliance that gets the least attention during implementation, and it's where a lot of businesses quietly get things wrong. Let's fix that.

What Is GoBD and Why Does It Apply to E-Invoices?

GoBD (Grundsätze zur ordnungsmäßigen Führung und Aufbewahrung von Büchern, Aufzeichnungen und Unterlagen in elektronischer Form) — yes, that name is exactly as long as it sounds — are the German tax authority's (BMF) principles for keeping electronic records.

For e-invoices specifically, GoBD matters because:

German tax law (§ 147 AO) requires you to retain invoices for 10 years
GoBD defines how you must store them, not just that you must store them
A non-compliant archive can result in your invoices being rejected as deductible expenses during a tax audit

A regular folder on your desktop doesn't cut it. Neither does a Dropbox share. Here's what does.

The Three GoBD Rules That Actually Matter

1. Tamper-Proof Storage (Unveränderbarkeit)

Once an invoice is archived, it must not be modifiable. If someone can open the file, edit a number, and save it — that's not GoBD-compliant.

This doesn't mean the file needs to be encrypted or stored in a blockchain. It means your system needs to be able to demonstrate that a stored document hasn't changed since it was archived. Most accounting software achieves this with write-once storage and audit trails.

What this rules out:

Storing invoices in a regular file system folder where anyone with access can edit files
Keeping them in shared cloud storage (Google Drive, Dropbox) without additional controls
Archiving them as editable formats (Word, Excel)

2. Machine-Readable Format Must Be Preserved

This is the big one that catches people out. If you receive an XRechnung (an XML file), you must archive the XML file itself. You cannot convert it to a PDF and archive only that.

The structured data must remain accessible throughout the retention period. If your accounting software only stores a PDF rendering of the invoice and discards the original XML, you are technically not compliant.

Common mistake: Some older accounting setups automatically convert incoming XML to PDF for display purposes and only store the PDF. The XML gets discarded. Check your settings — this matters.

3. Auditability: The GoBD Audit Trail

GoBD requires that it must be possible to trace every booking from the original document through to the financial statement. In practice, this means:

Each archived invoice must be linked to the corresponding booking in your accounting system
You need to be able to retrieve any invoice quickly (tax auditors generally expect retrieval within a few minutes, not days)
The storage system itself must have an audit log — records of who accessed what, and when

How Long Do You Actually Need to Keep Invoices?

Document Type	Retention Period
Invoices (issued and received)	10 years
Commercial correspondence	6 years
Delivery notes	6 years
Bank statements	10 years

The 10-year clock starts at the end of the calendar year in which the document was created. So an invoice dated March 2025 must be kept until at least 31 December 2035.

One thing that surprises people: if you switch accounting systems in year 5, you can't just delete the old data. You need to either migrate the archived invoices to the new system — including the original XML files — or keep the old system accessible for the remaining retention period.

What Does a Compliant Archive Actually Look Like?

You've got a few options depending on your setup:

Option 1: Accounting Software with Built-In Archiving

Most modern German accounting tools handle this automatically. sevDesk, lexoffice, easybill — they all archive invoices in GoBD-compliant storage as part of their standard workflow. You receive or create an invoice, it gets stored in their system, and you can retrieve it years later.

The catch: your data is in their cloud. If you cancel your subscription, make sure you export a GoBD-compliant archive before you go. Most tools offer this as a ZIP export with an index file — read the documentation before you cancel, not after.

Option 2: Dedicated Document Management System (DMS)

For businesses with higher volume or more complex requirements, a dedicated DMS like ELO, d.velop, or DocuWare handles archiving properly and integrates with most accounting software. These systems were built specifically for GoBD compliance, include audit trails out of the box, and have retention management built in.

More setup effort upfront, but you own your archive infrastructure.

Option 3: DATEV Unternehmen online

If you work with a Steuerberater (tax advisor) using DATEV — and about 80% of German SMBs do — DATEV Unternehmen online can serve as your compliant archive. Invoices processed through DATEV are stored in their GoBD-certified environment. Your Steuerberater will know the setup.

The Migration Problem Nobody Talks About

Let's say you're switching from one accounting system to another. The new system is great, the old one is being shut down, and someone mentions that the old archived invoices need to come along.

This is genuinely tricky. You need:

A full export of all archived invoices from the old system, including original XML files (not just PDF versions)
An index file that maps each document to its metadata (invoice number, date, counterparty, amount)
A way to import this into the new system such that the original creation timestamps and document integrity can still be verified

Most accounting software doesn't make this easy. Before committing to a system migration, ask the vendor specifically: "How do I export a GoBD-compliant archive, and how do I verify the integrity of that export?" If they give you a vague answer, push harder.

A Practical Archiving Checklist

Before you decide your archiving setup is done, run through these:

Original XML files (XRechnung, ZUGFeRD) are being stored, not just PDF conversions
Stored files cannot be edited by anyone after archiving
Each stored invoice is linked to the corresponding booking in your accounting system
You know which system is your "system of record" for invoice archives
You have a documented process for what happens if you change accounting software
Retention periods are tracked — you know when each document can be deleted (in 10 years)
You can retrieve any invoice from the last 10 years within a few minutes

If you're ticking all of these, you're in good shape.

Frequently Asked Questions

Do I need to archive invoices I send, or just the ones I receive?
Both. You must archive outgoing invoices as well as incoming ones. The 10-year retention requirement applies in both directions.

Can I archive invoices in the cloud?
Yes, as long as the cloud storage meets the GoBD requirements for tamper-proof storage and auditability. Using a cloud-based accounting tool that's explicitly GoBD-certified is the simplest path. Storing files in a regular Dropbox folder does not qualify.

What happens if I get audited and my archive isn't GoBD-compliant?
The tax authority (Finanzamt) can disallow those invoices as deductible expenses, estimate your income (Schätzung), and potentially apply penalties. In serious cases, this can get expensive. The risk isn't theoretical — tax audits happen, and the archive is one of the first things auditors check.

I'm a freelancer with about 30 invoices a year. Do I really need a special system?
Any decent cloud accounting tool designed for the German market will handle this for you automatically. You don't need a dedicated DMS. Just make sure you're using software that explicitly supports GoBD-compliant archiving and don't turn that feature off. Check our software comparison for options.

Retention rules and GoBD guidance are based on the BMF letter dated 28 November 2019 (GoBD), §147 AO, and §14b UStG. For complex situations — especially cross-border invoicing or regulated industries — consult a Steuerberater.