E-invoice archiving requirements in eight EU countries: retention periods, original format and storage location

Short answer: Retention periods for invoices differ widely across the eight EU countries with e-invoicing mandates: seven years in Belgium, eight in Germany, ten in Italy, Slovakia and (under commercial law) France, ten years inside KSeF in Poland, six years under Spanish commercial law and five years under Romanian accounting law. In most of them the legally relevant original is the structured file, usually XML, not a PDF rendering. Wherever you store it, the invoice must stay authentic, intact and legible until the period ends, and several countries restrict or require notice of storage abroad.

E-invoicing mandates change little about how long you keep invoices, but a lot about what you keep. When the invoice is a data file, “what is the original?” has a new answer, and in clearance countries part of the archive may already sit with the tax authority. Archiving is the last stage of the inbound invoice process that our guide from e-invoice to archive follows step by step. This guide covers the eight countries in our e-invoicing tracker, each checked against the law or the tax authority as of 3 October 2026, for finance, tax and IT teams running one archive for entities in several countries.

One correction first, because search results disagree on it: Germany no longer requires invoices to be kept for ten years. Since 1 January 2025 the period is eight years. Ten years still apply to books and annual accounts, which is where the confusion comes from. The details are in the Germany section below and on our Germany page.

The EU framework for e-invoice archiving: what the VAT Directive leaves to member states

EU law sets only the common floor for e-invoice archiving: every business keeps its invoices authentic, intact and legible until the storage period ends, and each member state decides how long that period is. The VAT Directive sets that floor in a few articles. Every taxable person must store copies of the invoices it issues and all invoices it receives (Article 244), and must ensure the authenticity of origin, the integrity of content and the legibility of each invoice from issue until the end of the storage period (Article 233). The business decides how; business controls that create a reliable audit trail between invoice and supply are expressly enough.

Almost everything else is left to national law:

• Retention period. Each member state determines how long invoices must be stored (Article 247(1)).
• Original form. A member state may require invoices to be stored in the form in which they were sent or made available, paper or electronic (Article 247(2)).
• Place of storage. The business may choose where invoices are stored as long as the tax authority gets them without undue delay. Member states may require notification if the storage place is abroad, and may require storage in their territory when it is not electronic with full online access (Article 245). They may restrict storage in countries without a mutual-assistance instrument (Article 247(3)).
• Online access. Where invoices are stored electronically with online access, the tax authorities of the country of establishment, and of the country where the VAT is due, may access, download and use them (Article 249).
• Translation. Member states may require translation for certain cases, but not as a general rule (Article 248a).

“‘Integrity of the content’ means that the content required according to this Directive has not been altered.”

Council Directive 2006/112/EC, Article 233(1)

The consequence for a group: one archive can serve all entities, but its retention classes, its location register and its access model must reflect up to eight different rule sets.

Invoice retention periods by country: how long must you keep e-invoices?

Invoice retention periods in the eight countries range from five years in Romania to ten years in Italy, Slovakia, Poland (inside KSeF) and France (commercial law), as checked on 3 October 2026. The table shows the minimum period for invoices under tax and commercial law, as recorded in our country profiles and checked against the primary source in the last column. Where two periods apply, the longer one decides how long you actually keep the document.

Country	Retention period for invoices	Period starts	Primary source
Belgium	7 years; 15 or 25 years for invoices linked to the VAT revision of immovable investment goods and buildings let with VAT	1 January of the year after issue	Law of 18 December 2025, art. 97 (Article 60 VAT Code); FPS e-facture portal
France	10 years under commercial law; tax law: 6 years, rising to 10 years from 1 January 2027	Last entry, or date the document was drawn up	Code de commerce L123-22; LPF L102 B
Germany	8 years (books and annual accounts: 10 years)	End of the calendar year of issue	§ 14b UStG; § 147 AO
Italy	10 years	Last entry	Civil Code art. 2220; DPR 633/1972 art. 39
Poland	Kept in KSeF for 10 years; longer outside KSeF if the tax limitation period has not expired	End of the year of issue	VAT Act art. 112aa
Romania	5 years (accounting registers and supporting documents)	1 July of the year after the end of the financial year	Accounting Law 82/1991, art. 25
Slovakia	10 years	End of the calendar year to which the invoice relates	VAT Act § 76 and § 85o(15)
Spain	6 years under commercial law; tax law: the 4-year limitation period	Last entry in the books (commercial law)	Código de Comercio art. 30; RD 1619/2012 art. 19; LGT art. 66

1. France (commercial law; tax law from 2027)10 years
2. Italy10 years
3. Poland (in KSeF)10 years
4. Slovakia10 years
5. Germany (invoices)8 years
6. Belgium7 years
7. Spain (commercial law)6 years
8. Romania5 years

Three points the table cannot show:

Belgium shortened its period recently. Article 97 of the law of 18 December 2025 replaced “ten” with “seven” in Article 60 of the VAT Code. Under Article 101 of the same law, the change applies to VAT that became chargeable from 1 January 2023. For older transactions, check with your adviser before deleting anything.

France is moving the other way. Article L102 B of the Tax Procedures Book currently requires six years. In the version in force from 1 January 2027, amended by Article 36 of Law No. 2026-534 of 25 June 2026, the period becomes ten years, and Légifrance notes that it applies to documents whose retention period expires after 1 January 2027. Since the commercial code already required ten years for accounting documents and supporting documents, many French companies will see little practical change. Retention rules configured to the six-year tax period need to be revised.

1. 1 Jan 2023Belgium: 7 yearsApplies to VAT that became chargeable from this date (Law of 18 December 2025, art. 101).
2. 1 Jan 2025Germany: 8 yearsInvoices and accounting vouchers, for periods not yet expired (§ 14b UStG, § 147 AO).
3. 1 Jan 2027France: 10 years for taxLPF L102 B as amended by Law No. 2026-534, for documents whose period expires after this date.

Starting points differ. “Ten years” in Italy runs from the last entry, in Slovakia from the end of the year to which the invoice relates, and in Romania from 1 July of the following year. A DMS that computes every deadline from the invoice date will delete some documents too early.

How long do you have to keep e-invoices in Germany: 8 or 10 years?

In Germany, invoices must be kept for eight years since 1 January 2025; books, records and annual accounts remain at ten years. The Fourth Bureaucracy Relief Act cut the retention period for invoices and accounting vouchers from ten to eight years with effect from 1 January 2025. Section 14b(1) of the VAT Act now reads “acht Jahre”, and Section 147(3) of the Fiscal Code gives eight years for vouchers, ten years for books, records and annual accounts, and six years for business letters. The period starts at the end of the calendar year of issue. It does not end while the documents matter for a tax assessment that is still open.

Common claim: “In Germany, invoices must be kept for ten years.” What the source says: eight years. Since 1 January 2025, § 14b(1) UStG requires a copy of every invoice issued and every invoice received to be kept for “acht Jahre” (eight years), and § 147(3) AO sets eight years for accounting vouchers, ten for books, records and annual accounts, and six for other documents such as business letters. Both changes come from the Fourth Bureaucracy Relief Act (BEG IV, BGBl. 2024 I No. 323); under § 27(40) UStG the eight years apply to all invoices whose old period had not expired by 31 December 2024. Several English-language sources still say ten years, and so did the FAQ of the German federal invoice portal when we checked it on 3 October 2026; the statute is the binding text.

Our Germany profile records one exception: credit institutions, insurers under federal supervision and investment firms keep accounting vouchers for ten years under the Fiscal Code, even though the VAT Act now says eight for their invoices too. For them, the longer period decides. Groups whose German presence is a subsidiary, a branch or only a VAT registration will find the e-invoicing side in our guide to German e-invoicing for foreign companies.

On form, the Federal Ministry of Finance is precise. Its letter of 15 October 2025 requires at least the structured part of an e-invoice to be kept unaltered in its original form, and in principle in the format received. The second amendment to the GoBD, the administrative principles for electronic bookkeeping, adds three points. Keeping only the structured part is sufficient. The PDF of a hybrid invoice such as ZUGFeRD must also be kept if it contains additional tax-relevant information, for example booking notes. And the XML must not be lost through a format conversion, for example to TIFF.

The same letter says that storing e-invoices outside a GoBD-compliant system is not, on its own, a breach of the VAT rules. For the Fiscal Code the GoBD still apply, including machine evaluability of the data.

What has to be archived: the XML, the PDF or both?

In all eight countries the structured file, usually XML, is the e-invoice; a PDF generated from it for reading is a view, not the original. The countries differ in how strictly they say so.

The structured file (XML)

• Is the invoice in Germany, Poland and Romania
• Kept unaltered, with a hash taken at ingestion
• Carries the tax-relevant data the authority checks
• Keep the transmission evidence with it (KSeF number, SdI receipt, sealed RO e-Factura file)

A PDF rendering

• A view for people, not the original
• Only needed as well if a hybrid invoice's PDF carries extra content
• Converting the XML into PDF and keeping only the PDF makes the burden of proof heavier (Belgium)
• Store as a separate object, never instead of the XML

Country	What counts as the original or must be kept	Source
Belgium	Any format, paper or electronic, as long as authenticity, integrity and legibility are guaranteed. Keeping the original XML is “strongly recommended”, because converting it to another format makes the burden of proof considerably heavier	FPS e-facture portal
France	Documents drawn up or received electronically must be kept in that electronic form for the tax retention period	LPF L102 B
Germany	At least the structured part, unaltered and in its original form; the PDF part of a hybrid invoice only if it carries extra tax-relevant content	BMF letter of 15 October 2025; GoBD amendment
Italy	E-invoices are kept electronically under the legally compliant preservation rules (conservazione a norma); simply saving the file is not enough	DPR 633/1972 art. 39; Agenzia delle Entrate
Poland	The structured invoice stored in KSeF	VAT Act art. 112aa
Romania	The XML file with the Ministry of Finance’s electronic seal is the original e-invoice	OUG 120/2021
Slovakia	The tax authority states that VAT payers must archive e-invoices in XML format	Financial Directorate FAQ, example 59
Spain	Electronic storage must ensure legibility in the original format in which the document was received or sent, together with any data and signature-verification mechanisms that guarantee authenticity and integrity	RD 1619/2012 art. 21

In practice, keep the XML exactly as received or sent, with its file name, and store any rendering alongside it, never instead of it. Two artefacts are worth keeping with the invoice even where no law names them. One is the transmission evidence: the Peppol message or access-point log, the KSeF number, the SdI receipt or the e-Factura message. The other is the validation result. The German Ministry of Finance, in its letter of 15 October 2025, notes that a business may rely on the technical result of a suitable validation of format and business rules, and that it makes sense to keep the validation report as evidence.

Authenticity, integrity and legibility over the whole period

An e-invoice archive must show for the whole retention period that each invoice comes from the stated supplier, has not been altered and can be read by a person. The three conditions come from Article 233 of the VAT Directive and apply from the moment of issue until the end of the retention period. In national law they appear, for example, in Article 289 V of the French General Tax Code, Sections 14(3) and 14b of the German VAT Act, Article 8 of the Spanish invoicing regulation, Article 112a of the Polish VAT Act for invoices outside KSeF, and in the Slovak VAT Act, as the Slovak Financial Directorate’s FAQ notes.

What they mean for an archive:

• Authenticity of origin is the assurance that the invoice really comes from the stated supplier. For e-invoices received over Peppol, KSeF, SdI or RO e-Factura, the network or clearance record is the most direct evidence, which is why the transmission metadata belongs in the archive.
• Integrity of content means the content required by law has not been altered. An archive shows this with write-once storage or a retention lock, hash values recorded when the file is ingested, and versioning: annotations and booking stamps are stored as new objects, never written into the original file. If the archive is SharePoint, retention labels and records in Microsoft Purview provide the lock; our SharePoint guide shows which Microsoft 365 licence each function needs.
• Legibility means a human can read the invoice when the tax authority asks. The Slovak Financial Directorate’s FAQ, relying on the EU’s explanatory notes on invoicing, says XML and other structured messages in their original format do not count as readable by the human eye; the condition is met if the invoice can be shown on request, within a reasonable time, in human-readable form on screen or in print. For an archive, that means a viewer or stylesheet that renders every syntax you hold, reliably, for the full retention period.

Belgium makes a point that applies everywhere. Business practice and software will change during the retention period, and the way the three conditions are met may change with them. If you change the form or format, for example during a migration, the burden of showing that authenticity and integrity were preserved is yours. The FPS Finance does not approve archiving systems in advance and will not rule on a particular product.

Where may you store e-invoices: in the country, in the EU or abroad?

Within the EU, an electronic archive with online access for the tax authority is generally allowed; the differences lie in notification duties and in rules for storage outside the EU. For groups with central archives, the place of storage is often the question with the most practical weight.

Country	Place of storage	Notification or approval
Belgium	Free choice for VAT purposes, provided invoices can be produced without delay. Businesses established in Belgium store them in Belgium unless they are kept electronically with full online access from Belgium. Cloud storage and third-party providers are allowed	No prior approval of the archiving method required (FPS e-facture portal)
France	Invoices must be stored in France unless stored electronically with immediate, complete online access. Electronic storage is not allowed in a country without a mutual-assistance convention with France or without online access	The storage place and any change must be declared with the profit return if it is outside France (LPF L102 C)
Germany	In Germany, or electronically elsewhere in the EU with full online access, download and use	Tell the tax office where invoices are kept if not in Germany (§ 14b(2) UStG); electronic storage outside the EU requires approval on application (§ 14b(5) UStG with § 146(2b) AO)
Italy	Electronic storage may be located in another state if a legal instrument on mutual assistance exists with it; the business ensures automated access to the archive for audits	None stated in Article 39 (DPR 633/1972)
Poland	Businesses with their seat in Poland store invoices in Poland, unless stored electronically abroad with online access for the tax authorities. KSeF invoices are held in KSeF	None stated in Article 112a (VAT Act)
Romania	Not recorded in our Romania profile; the sealed XML must be downloaded from RO e-Factura within 60 days (see below)	Check with your adviser
Slovakia	No place-of-storage rule in § 76 of the VAT Act; electronically stored invoices must be accessible to the tax office for audit, download and use	None stated; translation into Slovak may be requested (§ 76(5) and (7))
Spain	Free choice, provided documents are available without undue delay. Outside Spain, only electronically with online access, remote download and use by the tax authority	Prior notice to the AEAT before storing outside Spain; also before using a third party established outside the EU in a country without a mutual-assistance instrument (RD 1619/2012 arts. 19 and 22)

For a group archive, the location register is therefore a compliance record, not an IT document, and hosting outside the EU needs a country-by-country check: approval in Germany, a mutual-assistance instrument in France and Italy, prior notice in Spain.

Clearance countries: what KSeF, SdI and RO e-Factura store for you

Of the three clearance platforms, only Poland’s KSeF takes over the statutory storage of the invoices it holds; Italy’s SdI is not an archive, and RO e-Factura in Romania keeps invoices available for download for 60 days. In clearance systems the tax authority sees every invoice before or as it reaches the buyer. Whether that also covers your archiving duty differs from country to country.

Poland: KSeF keeps invoices for ten years

Article 112aa of the Polish VAT Act, introduced by the KSeF law of 16 June 2023, says structured invoices sent to the National e-Invoice System are stored there for ten years from the end of the year in which they were issued, and that the general storage rules in Articles 112 and 112a do not apply to them. If that period ends before the tax limitation period, the taxpayer keeps the invoices outside KSeF until the limitation period expires, and the general rules apply again.

So the statutory archive is in KSeF. In practice your DMS still holds a copy of each FA(3) file with its KSeF number, because approval workflows and group reporting run on it. Invoices that may still be issued outside KSeF (our Poland page lists the cases and their end dates) fall under the general rules: kept until the tax limitation period expires, in a way that ensures authenticity, integrity and legibility.

Italy: SdI is not an archive, conservazione a norma is

The SdI routes and checks invoices. It does not take over the storage duty. Under Article 39 of DPR 633/1972, e-invoices are kept electronically in line with the ministerial decree adopted under the Digital Administration Code. The Agenzia delle Entrate puts it plainly: legally compliant preservation is not the simple saving of the invoice file on a PC, but a process regulated by law. Both issuer and recipient must do it.

The preservation process must be completed within three months of the deadline for filing the annual tax return, as FiscoOggi, the Revenue Agency’s magazine, summarises the Ministerial Decree of 17 June 2014. Most businesses use a certified private provider. The Revenue Agency also offers a free preservation service through its “Fatture e Corrispettivi” area; under Article 5 of its service agreement, invoices are preserved for 15 years. According to our Italy profile, the Italian rules move into a new Consolidated VAT Act from 1 January 2027; the article numbers above refer to the text in force until then.

Romania: download the sealed XML within 60 days

In Romania the legal original is created by the system. Emergency Ordinance 120/2021 applies the Ministry of Finance’s electronic seal to every valid e-invoice, and the XML file with that seal is the original. The RO e-Factura procedure (Order 1365/2021, Article 8) adds the operative detail: invoice XML files and error messages are available for download for 60 days after publication in the system; after that they are archived electronically and released on request.

For an archive this is a hard deadline: download the sealed XML automatically as soon as it is published. A PDF printed from the portal, or the unsealed XML the supplier uploaded, is not the original.

Spain and France: platforms that do not replace your archive

Spain’s B2B mandate is adopted but has no start date yet, as our Spain page explains. Once it applies, Law 56/2007 provides that e-invoices held in the AEAT’s public e-invoicing solution are kept there for the tax retention period, and never longer than 12 years. Our Spain profile does not record a rule that this storage relieves businesses of their own duty under the invoicing regulation, so plan to keep your own archive.

In France, invoices travel between approved platforms. The retention and storage-place duties in Articles L102 B and L102 C of the Tax Procedures Book stay with the business; our France page records no rule that makes the platform the archive.

Conservazione sostitutiva: the Italian model in brief

Italy is the only one of the eight countries that prescribes a formal preservation process for e-invoices, with a responsible party and a deadline. “Conservazione sostitutiva” is the term still widely used for the process the law calls conservazione a norma. It is the most formalised model among the eight countries: a defined preservation process with a responsible party (usually a certified provider), a deadline three months after the tax-return deadline, periodic integrity checks (the Revenue Agency’s agreement provides for verification of archive integrity and file legibility at intervals of no more than five years) and, in the Agency’s words, the ability to retrieve the original invoice at any time.

Elsewhere, the law states the result (authentic, intact, legible, accessible) and leaves the method to the business. An archive built to the Italian process therefore covers most of what other countries ask for; a generic archive does not meet the Italian rules unless that process is in place.

What does ViDA change for e-invoice archiving?

ViDA does not change how long or where e-invoices must be kept; it changes what counts as an e-invoice and, from 1 July 2030, makes structured e-invoices the default. Council Directive (EU) 2025/516, the VAT in the Digital Age package, changes several invoicing rules. It does not amend Articles 244 to 249 of the VAT Directive, the articles on storage. Retention periods, place of storage and form requirements stay national, as our ViDA page records.

What does change, with effect from 1 July 2030:

• The definition of an e-invoice. The new Article 217 defines it as an invoice issued, transmitted and received in a structured electronic format that allows automated and electronic processing, at least for the data to be reported. A PDF sent by e-mail will no longer be an “electronic invoice” in the Directive’s sense.
• E-invoices become the default. The new Article 218 says invoices are issued as electronic invoices compliant with EN 16931; member states may still accept other formats for transactions outside the EU reporting obligations.
• Reporting replaces recapitulative statements for intra-EU supplies, with transaction data sent at the time of issue.
• Data storage for reporting may continue. The new Article 273 allows member states to keep requiring businesses to store transaction data for VAT returns or audits.

For archiving, this means cross-border invoices that often arrive as PDFs today will also come as structured files, so the XML-first archive becomes the normal case. How long and where to keep them remains national law.

Checklist: e-invoice archiving requirements for your DMS

A DMS that meets e-invoice archiving requirements in several countries needs retention rules per country, the unaltered XML with its evidence, a viewer for the whole period and controlled deletion.

• Retention class per country and document type, with the legal basis
• Period computed from the right start date for each country
• XML stored unaltered, hashed and locked until the period ends
• Transmission evidence filed with the invoice
• Viewer for every syntax you receive, for the whole period
• Legal hold, then logged deletion when no duty applies

Use this list to check an existing archive or to compare vendors; how to weigh archiving against the other selection criteria is covered in how to choose a document management system. The DMS finder shows which vendors document the relevant functions with a source. To see which countries and deadlines apply to each of your entities, use the readiness check.

1. Retention classes per country and document type. Configure the periods from the table above as rules, not as a single group-wide value. Where commercial and tax periods differ (France until 2027, Spain), use the longer one, and record the legal basis in the rule.
2. Correct start of the period. End of the calendar year of issue (Germany, Poland), 1 January of the following year (Belgium), last entry (Italy, Spanish and French commercial law), 1 July after the end of the financial year (Romania), end of the year to which the invoice relates (Slovakia).
3. XML stored unaltered. Ingest the structured file exactly as received or sent, compute a hash at ingestion and lock the object against changes and deletion until the period ends. Store renderings and booking stamps as separate objects.
4. Hybrid invoices complete. For ZUGFeRD or Factur-X files, keep the PDF container too if it carries information not present in the XML.
5. Transmission evidence attached. Peppol or access-point records, KSeF number, SdI receipts, the sealed RO e-Factura XML, and the validation report where you have one.
6. Romania download automated. Fetch sealed XML and error messages from RO e-Factura well within the 60-day window.
7. Italian preservation in place. Either a certified preservation provider or the Revenue Agency’s free service, with the three-month deadline monitored.
8. Legibility for the full period. A viewer for every syntax you receive (UBL, CII, FatturaPA, FA(3), RO_CIUS), tested on old files after each upgrade.
9. Location register. Where each entity’s invoices are stored, with the notifications made: German tax office, French profit return, prior notice to the AEAT.
10. Online access for auditors. What the Spanish regulation calls full access: display, selective search, online copy or download, and printing, without undue delay.
11. Legal hold. Suspend deletion while an audit, appeal or open assessment needs the documents.
12. Deletion after the period. Invoices contain personal data. Once no retention duty applies, delete by retention class and year, with approval and a log that records class, year and count, not content.
13. Migration plan. When you replace the archive, move XML, hashes, metadata and transmission evidence together, and document how authenticity and integrity were preserved. Belgium explicitly puts that burden of proof on the business.

Storage growth, migration and archive modules rarely appear in a licence price; our guide to what a document management system costs lists published prices and the hidden costs to ask about.

Sources and status

Every rule in this guide comes from the law or tax authority linked in the text, checked on 3 October 2026. Our country pages carry the same facts with sources and are re-checked monthly; changes appear in the change log. Gaps, such as Romania’s rules on storage location, are marked above. This guide is information, not legal or tax advice; involve your tax adviser before deleting records or moving an archive abroad.