From e-invoice to archive: accounts payable document management in eight EU countries
Accounts payable document management for e-invoices in eight EU countries: receive via Peppol or national platforms, validate, approve, post, archive, retain.
Legal and tax statements checked against the linked primary sources as of 3 October 2026. Information, not legal or tax advice.

Short answer: An inbound e-invoice passes through seven stages: it is received through Peppol, a national platform or an agreed channel; validated against EN 16931 and national rules; read and displayed; matched and approved; posted and paid in the ERP; archived as the original XML with its transmission evidence; and kept until the national retention period ends. The stages are the same across Europe, but the channel, the legal original, the buyer's risks and the retention period differ in each of the eight countries we track. Design the process per legal entity, give every stage one owning system, and make sure the XML and its evidence reach the archive unchanged.
For years, accounts payable document management meant scanning paper and reading PDFs. Since 2024 the inbound side has changed faster than the outbound side: Romania made its sealed XML the only original in 2024, every German business must be able to receive e-invoices since 2025, and Belgium, Poland and France have added receiving obligations during 2026. This guide follows one supplier invoice from receipt to deletion and shows, stage by stage, what changes in Belgium, France, Germany, Italy, Poland, Romania, Slovakia and Spain. The country facts come from our e-invoicing tracker, each checked against the law or the tax authority as of 3 October 2026; the detailed rules on retention, original format and storage location are in our guide to e-invoice archiving requirements.
It is written for finance, tax and IT teams who run accounts payable for one or several entities and need to decide which system does what: the ERP, an e-invoicing provider, an accounts payable tool or a document management system.
Accounts payable document management: the seven stages of an inbound e-invoice
Accounts payable document management covers seven stages for every inbound e-invoice: receive, validate, extract and display, match and approve, post and pay, archive, and retain. Whatever the country, the same work has to be done. What differs is who does it and what the law says about each step.
- ReceiveFrom the Peppol network, a national platform (KSeF, SdI, RO e-Factura, French approved platforms) or an agreed channel such as e-mail. One entry point per legal entity.
- ValidateCheck the file against EN 16931 and the national rules, then the business content: right entity, VAT ID, duplicates, mandatory details.
- Extract and displayTake header and line data from the XML, unpack embedded attachments, render a readable view for approvers.
- Match and approveAgainst supplier, purchase order and goods receipt; route exceptions; one approval trail in one system.
- Post and payHand over to the ERP, post, pay, and record the national references such as the KSeF number.
- ArchiveOriginal XML unaltered, with transmission evidence, validation report, approval trail and ERP document number.
- Retain, hold, deleteNational retention class, legal hold during audits, logged deletion at the end of the period.
Two principles keep this manageable across several countries. First, each stage has exactly one owning system; if both the ERP and the DMS run approvals, nobody can tell an auditor which approval counts. Second, the structured file stays the reference from start to finish. Everything people see, from the approval screen to the archived PDF, is derived from it.
How do invoices arrive in 2026? Three models
The eight countries use three models for B2B invoices. Which one applies decides who receives first and what you get.
Open network. Supplier and buyer each choose a service provider, and the providers exchange the invoice over a common network. Peppol is the European example: Belgium uses it as the default channel since 1 January 2026, and Slovakia will route all domestic B2B invoices through certified Peppol providers from 1 January 2027. Germany prescribes no channel at all; Peppol is one option next to e-mail or interfaces.
Clearance platform. The tax authority’s system sits between supplier and buyer. Italy’s SdI checks every domestic invoice before delivery, Poland’s KSeF assigns each invoice a number, and Romania’s RO e-Factura seals valid invoices. What the buyer receives is what the authority has registered.
Approved platforms. France lets private platforms registered by the tax administration exchange the invoices and report data to it. Spain’s adopted model also relies on private exchange platforms, plus a free public solution of the tax agency, but its start date is not set yet.
| Country | B2B receiving channel | Receiving obligation since | Legal original or format | Retention of invoices |
|---|---|---|---|---|
| Belgium | Peppol by default; another channel only by mutual agreement | 1 Jan 2026 | Peppol BIS Billing 3.0 (UBL) | 7 years |
| France | Approved platform (plateforme agréée) | 1 Sep 2026 | UBL, CII or Factur-X | 10 years (commercial law; tax law from 2027) |
| Germany | Any agreed channel; an e-mail inbox is enough | 1 Jan 2025 | EN 16931 formats such as XRechnung or ZUGFeRD; at least the structured part is kept | 8 years |
| Italy | SdI clearance, delivered to a certified e-mail address or recipient code | 1 Jan 2019 | FatturaPA XML | 10 years |
| Poland | KSeF | 1 Feb 2026 | FA(3) XML with KSeF number | 10 years in KSeF |
| Romania | RO e-Factura; buyer downloads | 1 Jul 2024 (sealed XML as the only original) | RO_CIUS XML with the Ministry’s seal | 5 years |
| Slovakia | Certified Peppol delivery service (“digital postman”) | 1 Jan 2027 | EN 16931 XML, in practice Peppol BIS Billing 3.0 | 10 years |
| Spain | Private platforms or the AEAT public solution | not yet set | UBL (EN 16931) and other accepted syntaxes | 6 years (commercial law) |
Sources: our country pages, each linked to the law or tax authority; retention details and start dates in the archiving guide.
- ItalyAll domestic B2B and B2C invoices through the SdI, issued and received.
- RomaniaThe sealed XML in RO e-Factura becomes the only original of a B2B invoice.
- GermanyEvery business established in Germany must be able to receive e-invoices.
- BelgiumStructured B2B e-invoices, Peppol BIS over Peppol by default.
- PolandAll taxpayers receive invoices through KSeF.
- FranceAll businesses established in France receive through an approved platform.
- SlovakiaDomestic B2B e-invoices through certified Peppol delivery services, with reporting.
- EU (ViDA)EN 16931 e-invoices for intra-EU B2B supplies and digital reporting.
Stage 1: receive
Receiving is where national rules differ most, and where a group needs one decision per entity.
Belgium. Since 1 January 2026, VAT-registered businesses established in Belgium issue and receive domestic B2B e-invoices in Peppol BIS over the Peppol network by default (FPS Finance). Another channel needs mutual agreement, and a customer cannot impose its own portal without the supplier’s consent. Every company must be reachable under its enterprise number (Peppol scheme 0208). Since the tolerance period ended on 31 March 2026, lacking the means to send or receive costs EUR 1,500, then EUR 3,000, then EUR 5,000. Non-established businesses without a fixed establishment are not obliged to receive, even if VAT-registered in Belgium.
Germany. Every business established in Germany has had to be able to receive structured e-invoices since 1 January 2025 (§ 14 UStG). The law prescribes no channel, and an e-mail inbox is enough. A recipient that cannot process an e-invoice has no right to a paper invoice instead. For hybrid formats such as ZUGFeRD, the XML part prevails over the PDF if the two differ, which matters for any approval screen that shows only the PDF. A foreign company with only a German VAT registration is not obliged to receive; our guide on German e-invoicing for foreign companies covers the cases.
France. Since 1 September 2026, every business established in France must receive e-invoices through an approved platform (DGFiP). A central directory run by the State tells the platforms which platform receives for each business. Not using an approved platform to receive leads to a formal notice to comply within three months, then fines of EUR 500 and EUR 1,000 for each further three-month period. During the start-up phase the DGFiP’s practical guide says invoices received by e-mail, PDF or paper must not be rejected for that reason alone, and that VAT deduction is not automatically lost.
Italy. Every domestic invoice passes through the Sistema di Interscambio (SdI), which checks it, rejects it with a notice if it fails, and delivers it to the buyer’s certified e-mail (PEC) address or to the channel identified by a seven-digit recipient code (Legislative Decree 127/2015, art. 1). An invoice between Italian parties sent outside the SdI counts as not issued.
Poland. Since 1 February 2026 all taxpayers in Poland receive invoices through KSeF, and since 1 April 2026 all remaining businesses in scope issue through it (KSeF portal). KSeF gives every invoice a unique KSeF number. In the offline24 mode an invoice may be issued offline and sent to KSeF by the next working day, so a buyer can hold an invoice before its KSeF number exists. Until 31 December 2026, invoices totalling up to PLN 10,000 a month and cash-register invoices may still be issued outside KSeF.
Romania. The supplier uploads the RO_CIUS XML to RO e-Factura, now within five working days. Valid invoices receive the Ministry of Finance’s electronic seal and are made available to the buyer; invalid ones go back with an error message (Emergency Ordinance 120/2021). Since 1 July 2024 the sealed XML is the only original of a B2B invoice. The RO e-Factura procedure keeps invoices and error messages available for download for 60 days after publication; after that they are released only on request. Receiving in Romania therefore means an automated download job.
Slovakia. From 1 January 2027, VAT payers established in Slovakia send domestic B2B invoices through a certified delivery service, the “digital postman”, which also reports the data to the Financial Administration (eFaktúra). Every legal person and taxable person in Slovakia, including non-VAT payers, must be able to receive that way. For receiving, one delivery provider per tax number; the Peppol ID uses scheme 0245 with the tax number (DIČ).
Spain. Royal Decree 238/2026 adopts B2B e-invoicing, but it applies 12 or 24 months after a ministerial order on the tax agency’s public solution, which was still unpublished on 3 October 2026 (BOE). Once it applies, invoices travel through private platforms, the free public solution or both; platforms send a UBL copy of each invoice to the public solution, and a business without its own private entry point receives through the public solution.
Receiving as a mailbox
- PDFs and XML files arrive by e-mail and are forwarded by hand
- No transmission evidence kept
- Romanian invoices fetched when someone remembers
- Each entity solves it differently
- The archive sees only what reaches accounting
Receiving as a defined entry point
- One channel per entity and country, documented
- Network or platform metadata stored with each invoice
- Automated downloads well inside the 60-day Romanian window
- Same hand-over format into validation for all entities
- Every invoice reaches the archive, approved or rejected
Stage 2: validate
An e-invoice can fail in two ways: technically, when the file does not meet the standard, and in content, when it does not belong to you or lacks what the law requires.
Technical validation. The European standard EN 16931 defines the content of an e-invoice and the two syntaxes it may use, UBL and CII; a new version, EN 16931-1:2026, was published in May 2026 (European Commission). Countries and networks narrow it with their own specifications: Peppol BIS Billing 3.0, maintained by OpenPeppol with national rules for several countries (Peppol BIS), XRechnung in Germany, RO_CIUS in Romania. Poland’s FA(3) and Italy’s FatturaPA are national formats of their own.
Where a clearance platform is in the path, part of this work is done before delivery: the SdI rejects failing invoices, and RO e-Factura seals only valid ones. Everywhere else, validation is yours or your provider’s. Germany’s Federal Ministry of Finance notes that a business may rely on the technical result of a suitable validation of format and business rules, and that keeping the validation report as evidence makes sense (BMF letter of 15 October 2025). Store the report with the invoice.
Content checks. A technically valid invoice can still be wrong for you:
- addressed to the wrong legal entity or with the wrong VAT ID, which happens easily in groups with similar company names;
- a duplicate, sent once by e-mail as a PDF and again over Peppol;
- missing details your national rules require, or VAT treatment that does not match the transaction;
- a hybrid file whose PDF and XML differ, where the XML governs in Germany.
Duplicates deserve a rule rather than a judgement call. Business Central, for example, does not create a new incoming e-document for a duplicate with the same vendor, external document number and date, as our ERP integration guide describes. Whatever system receives first should apply a comparable rule across channels.
Stage 3: extract and display
With a structured invoice, extraction means mapping fields, not reading pixels. Supplier, buyer, dates, totals, VAT breakdown and invoice lines come straight from the XML. That removes most of the recognition cost of paper and PDF invoices, which is often billed by page: docuvita lists EUR 0.19 net per processed page for its invoice recognition, and Microsoft charges USD 0.01 per page for prebuilt document processing such as its invoice model (both checked on 2 October 2026, as recorded in our cost guide).
Two parts of this stage are easy to underestimate.
Attachments. Delivery notes, time sheets or contracts travel inside the e-invoice. The Belgian administration lists pdf, png, jpg, csv, xlsx and ods as allowed attachments and forbids sending them separately by e-mail. File them as separate, linked documents so approvers can open them, and keep the XML with its embedded attachments untouched.
A readable view. XML is not readable by people. The Slovak Financial Directorate’s FAQ, citing the EU’s explanatory notes on invoicing, says the legibility condition is met if the invoice can be shown on request, within a reasonable time, in human-readable form on screen or in print (FAQ of 14 September 2026). The German tax administration offers a free viewer, and OpenPeppol publishes a stylesheet for UBL invoices. Your approval screen and your archive need a viewer for every syntax you receive, working for the whole retention period: UBL, CII, FatturaPA, FA(3) and RO_CIUS.
Stage 4: match and approve
Matching compares an invoice with the purchase order and, in a three-way match, with the goods receipt; approval then runs in one system with one trail. Approval is the stage most companies already know from paper invoices, and the one that changes least. What changes is the speed: structured data makes automatic matching realistic.
Matching compares the invoice with what was ordered and received. A two-way match checks invoice against purchase order; a three-way match adds the goods receipt. Invoices that match within tolerance can go straight to posting; the rest go to the buyer, the cost-centre owner or accounts payable. The ERPs have their own tools for parts of this: Dynamics 365 Finance can match product receipts to pending invoice lines and submit imported invoices to workflow, and Business Central is moving to an agent that matches incoming purchase invoices with open orders. A DMS or accounts payable tool has to fit into that, not duplicate it.
Three rules make approvals hold up later:
- One system approves. Decide whether approval runs in the DMS or the ERP workflow, not both.
- The approval trail stays with the document. Who approved, when, with which amount and comment, stored with the invoice in the archive, not only in a workflow log that is purged after a year.
- Rejections are documented too. A rejected invoice is still a received document. In Spain, once the mandate applies, buyers will report acceptance or rejection to the supplier, and a rejection to the tax agency’s public solution, within four calendar days, excluding weekends and national holidays, according to our Spain profile.
If you are choosing the system for this stage, the guide to choosing a document management system explains how to shortlist vendors with an invoice module and a documented connector for your ERP.
Stage 5: post and pay
Posting hands the invoice to the ERP as a parked, pending or posted document, and the ERP document number should flow back to the archived invoice. Two countries add references that must survive into payment and reporting. In Poland, the SAF-T VAT file (JPK_VAT) records the KSeF number of each invoice for periods from February 2026, and from 1 January 2027 the KSeF number must be quoted in payments between active VAT taxpayers and in split payments. In Spain, once the mandate applies, buyers report full payment, with payment and due dates, within the same four-day window.
The buyer’s side carries real risk, which is why receiving and posting cannot be left to chance:
| Country | What the buyer risks with a non-compliant inbound invoice | Source |
|---|---|---|
| Germany | After the supplier’s transition ends, a paper or PDF invoice where an e-invoice is required is not a proper invoice; input VAT in principle only after correction | Germany profile |
| Belgium | VAT deduction can be refused if authenticity and integrity cannot be shown | Belgium profile |
| Italy | Fine of 70% of the VAT (minimum EUR 250) unless the buyer reports the missing or irregular invoice through the Revenue Agency’s tools within 90 days | Italy profile |
| Romania | Receiving and booking a B2B invoice issued outside RO e-Factura: fine of 15% of the total invoice value | Romania profile |
| France | During the start-up phase, VAT deduction is not automatically lost for invoices received by e-mail, PDF or paper | DGFiP guide |
| EU from 2030 | Member states may make holding a compliant e-invoice a condition for deducting VAT (new Article 168) | Directive (EU) 2025/516 |
For accounts payable this means a control before posting: is this invoice in the form and through the channel the law requires for this supplier and this entity? If not, ask for a corrected invoice before the payment run, not after the audit.
Stage 6: archive
An archived e-invoice is the original XML plus its transmission evidence, validation report, readable view and process record, kept unaltered until the retention period ends. The archive is where the earlier stages leave their evidence. The VAT Directive requires the authenticity of origin, the integrity of content and the legibility of each invoice to be ensured from issue until the end of the storage period (Article 233 of the VAT Directive). The Directive also defines the first of the three conditions:
“‘Authenticity of the origin’ means the assurance of the identity of the supplier or the issuer of the invoice.”
Council Directive 2006/112/EC, Article 233(1)
For an e-invoice, an archive meets these conditions with one object per invoice that holds more than the file.
- Original structured fileXML exactly as received, with file name and a hash taken at ingestion; locked against change and deletion
- Transmission evidencePeppol message ID and sender and receiver IDs, KSeF number, SdI receipt, sealed RO e-Factura file, platform status
- Validation reportResult of the format and business-rule check, as the German Ministry of Finance recommends keeping
- Readable view and attachmentsRendering for people and embedded attachments, stored as separate linked objects
- Process recordApproval trail, ERP document number, payment reference, retention class and legal hold status
The national rules on the original point the same way. Germany requires at least the structured part to be kept unaltered in its original form (§ 14b UStG with the BMF letter of 15 October 2025), and the amended GoBD add that the XML must not be lost through a conversion, while the PDF of a hybrid invoice must also be kept if it carries additional tax-relevant information such as booking notes.
In Romania the sealed XML is the original. Slovakia’s tax authority expects e-invoices to be archived as XML. Spain requires legibility in the original format received or sent (RD 1619/2012). France requires documents received electronically to be kept in that form for the tax retention period (LPF L102 B). Belgium allows other formats but strongly recommends keeping the original XML, because a conversion makes the proof of authenticity and integrity considerably harder (FPS e-facture portal).
What the platforms keep for you, and what they do not
Clearance and platform systems store invoices too, but none of them makes your own archive unnecessary in every case:
- Poland: structured invoices sent to KSeF are stored there for ten years from the end of the year of issue, and the general storage rules do not apply to them (Article 112aa of the VAT Act). If the tax limitation period ends later, you keep them outside KSeF until it expires. Approval and group reporting still need a copy with the KSeF number in your systems.
- Italy: the SdI is a router, not an archive. E-invoices must go through legally compliant preservation (conservazione a norma); simply saving the file is not enough, and both supplier and buyer must do it (Agenzia delle Entrate). The Revenue Agency offers a free preservation service; most businesses use a certified provider.
- Romania: 60 days of download availability; after that, release only on request.
- Spain: once the mandate applies, the public solution keeps the invoices it holds for the tax retention period and never longer than 12 years; our Spain profile records no rule that relieves businesses of their own storage duty.
- France and Belgium: platforms and access points transport; the retention and storage-place duties stay with the business.
Stage 7: retain, hold and delete
Retention is set by each member state (Article 247 of the VAT Directive), and ViDA does not change that. The periods for invoices, as checked on 3 October 2026, and where they start:
| Country | Retention period | Period starts |
|---|---|---|
| Belgium | 7 years (15 or 25 years for certain real-estate cases) | 1 January of the year after issue |
| France | 10 years under commercial law; tax law 6 years, 10 years from 1 January 2027 | last entry, or the date of the document |
| Germany | 8 years (§ 14b UStG, § 147 AO); books and annual accounts 10 years | end of the calendar year of issue |
| Italy | 10 years | last entry |
| Poland | 10 years in KSeF; longer outside it if the tax limitation period has not expired | end of the year of issue |
| Romania | 5 years | 1 July of the year after the end of the financial year |
| Slovakia | 10 years | end of the calendar year to which the invoice relates |
| Spain | 6 years under commercial law; tax law: the 4-year limitation period | last entry in the books |
Three practical consequences for the archive:
- Retention classes per country, not per group. A single group-wide period either deletes too early in Italy or keeps personal data longer than necessary in Romania. Record the legal basis in each rule.
- Start dates matter. A system that counts every period from the invoice date will delete Romanian or Italian invoices too early.
- Legal hold beats deletion. No period ends while documents matter for an open audit, appeal or assessment; Germany’s Fiscal Code says so explicitly. Suspend deletion per entity and year while that is the case, then delete with approval and a log that records class, year and count, not content.
Where you store matters as well. Germany requires notice to the tax office for storage elsewhere in the EU and approval for electronic storage outside the EU, France a declaration with the profit return for storage abroad, and Spain prior notice to the tax agency. The country-by-country rules are in the archiving requirements guide.
What do tax auditors ask for?
Tax auditors ask for machine-readable data, online access, evidence of the process and proof that nothing was changed. An audit is the test of every earlier stage. The requests are similar across countries even where the wording differs:
- Machine-readable data. German auditors may demand tax-relevant data in a machine-evaluable format (§ 147(6) AO). For e-invoices that means the XML originals with their metadata, not a folder of PDFs.
- Online access without undue delay. Spain’s invoicing regulation describes it as display, selective search, online copy or download, and printing. A read-only auditor account with an export function covers this in most countries.
- Evidence of the process. How invoices arrive, how they are checked, who approves, where they are stored and how they are protected. In Germany this belongs in the procedural documentation required by the GoBD; in Italy, the preservation process itself is regulated.
- Proof that nothing was changed. Hashes from ingestion, locked storage, version history and, after a migration, a record of what was moved and how integrity was checked. Belgium puts the burden of proof for format changes explicitly on the business.
A quick self-test: pick one supplier invoice per country from last year and try to show, within an hour, the original XML, its transmission evidence, the readable view, the approval and the ERP posting. If any piece takes longer than the rest, that is the stage to fix.
Who does what in accounts payable document management: ERP, e-invoicing provider, AP tool or DMS?
No single type of system covers all seven stages in all eight countries. Most groups combine two or three:
| Role | Typically covers | Watch out for |
|---|---|---|
| E-invoicing provider or Peppol access point | Stage 1, often stage 2; connections to Peppol and national platforms | Whether it passes on the original XML and the delivery metadata, and how long it keeps logs |
| ERP | Stages 4 and 5; increasingly stages 1 to 3 through built-in e-document functions | Attachment storage without retention rules; deletion in the ERP must not remove the archived original |
| Accounts payable tool | Stages 2 to 5, with capture, matching and approval | Whether it archives compliantly itself or hands over to an archive |
| Document management system | Stages 3, 4 and 6 to 7; sometimes 1 and 2 through own access points or partners | Formats and networks per country, viewer for every syntax, audit evidence |
Our checked vendor data sheets show how differently vendors position themselves. On 3 October 2026, five vendors with a checked data sheet were Peppol access points themselves: ARXivar, Medius, OpenText, Siav and Yooz. Yooz is also registered as an approved platform in France according to its data sheet, so it can be the legal receiving channel there. ARXivar’s data sheet records accreditation as an intermediary for the SdI and, by the Italian agency AgID, as a preservation provider; Siav’s records a qualification by AgID as a preservation provider. Together that covers stages 1 and 6 in Italy for ARXivar, and stage 6 for Siav. Among the formats recorded per vendor, OpenText lists RO e-Factura, and d.velop and DocuWare list KSeF. Others receive from any access point: ELO’s invoice module takes invoices from the customer’s or a service provider’s access point.
Read these as starting points for questions, not as a ranking. A vendor that covers your countries on paper still has to show, in a pilot, that the XML and its evidence reach the archive unchanged. The DMS finder filters vendors with a checked data sheet by e-invoice formats, Peppol, ERP and archive audits; the vendor directory has the sources for every value.
How should groups with entities in several countries set it up?
For a group, the inbound process is a matrix of entities and countries, and it works best with obligations mapped per entity, one archive with national rule sets and one internal hand-over format. A few patterns make it manageable:
- Map obligations per entity, not per country. A French company with only a German VAT registration is in the French mandate and outside the German one. Belgium, Germany, Italy and Poland exclude non-established businesses from receiving obligations in different ways; each country page states the rule with its source.
- One archive, many rule sets. A central archive can serve all entities if its retention classes, location register and access model reflect the national rules. The VAT Directive allows electronic storage with online access across the EU, with notification duties in some countries.
- One hand-over format. Whatever each country’s channel delivers, convert it into one internal hand-over to validation and approval, while the original goes untouched to the archive.
- Plan for 2030. Under ViDA, intra-EU B2B invoices become EN 16931 e-invoices from 1 July 2030, with digital reporting. Cross-border supplier invoices that arrive as PDFs today will then arrive as structured files too.
The readiness check takes your entities and countries and returns the dated obligations for each, with sources and a calendar file. It runs in your browser.
Checklist for an inbound e-invoice process
Eight points cover all seven stages of an inbound e-invoice process; review them for each new entity and mandate.
- One documented receiving channel per entity and country, including the Romanian download job
- Technical validation with the report stored, plus duplicate and entity checks
- A viewer for every syntax you receive: UBL, CII, FatturaPA, FA(3), RO_CIUS
- Approval in one system, with the trail stored next to the invoice
- KSeF number and other national references carried into posting and payment
- Original XML, transmission evidence and validation report archived together and locked
- Retention classes per country with the correct start date, legal hold and logged deletion
- Read-only auditor access and a tested export with metadata
Where to start
Start with stage 1 for the entities whose obligations already apply: Germany, Belgium, Poland, France, Italy and Romania. List how invoices arrive today, which system receives first and whether the XML and its evidence reach the archive. Then fix stage 6, because an archive that keeps only PDFs cannot be repaired later for invoices already received. Slovakia’s start on 1 January 2027 and Spain’s pending order are next; the e-invoicing tracker shows every date with its source, and the change log records when one moves.
This guide is information, not legal or tax advice. Country facts were checked against the linked primary sources on 3 October 2026; involve your tax adviser before changing retention rules or moving an archive.
Frequently asked questions
What is accounts payable document management?
It is the handling of supplier invoices as documents from receipt to deletion: receiving them from e-mail, scans, Peppol or national e-invoicing platforms, checking and reading their data, routing them for approval, handing them to the ERP for posting and payment, and archiving the original with its evidence for the legal retention period. It can sit in a document management system, an accounts payable automation tool, the ERP or a combination, as long as each step has one owner.
What happens to an e-invoice between receipt and archive?
Seven stages: it is received through a network, platform or agreed channel; validated against EN 16931 and national rules; its data is read and displayed for people; it is matched against orders and receipts and approved; it is handed to the ERP for posting and payment; the original XML is archived with its transmission evidence, validation report and approval trail; and it is kept, protected and finally deleted when the national retention period ends.
Do we have to keep the XML file or is the PDF enough?
Keep the XML. In Germany at least the structured part must be kept unaltered in its original form, in Romania only the XML with the Ministry of Finance's seal is the original, Slovakia's tax authority expects e-invoices to be archived as XML, and Spain requires legibility in the original format received. A PDF rendering is a view for people; store it next to the XML, never instead of it. For hybrid invoices such as ZUGFeRD, keep the PDF part too if it carries additional tax-relevant content.
Do KSeF, SdI or RO e-Factura replace our own invoice archive?
Only partly, and differently in each country. Poland's KSeF stores structured invoices for ten years from the end of the year of issue, and the general storage rules do not apply to them. Italy's SdI routes and checks invoices but is not an archive: e-invoices must go through legally compliant preservation, for which the Revenue Agency also offers a free service. Romania's RO e-Factura keeps invoices available for download for only 60 days, so you must fetch and store the sealed XML yourself.
Who should receive e-invoices: the ERP, the DMS or an e-invoicing provider?
Any of them can, as long as one system receives first and the others take over from it. A provider or access point connects you to Peppol or a national platform; the ERP or the DMS then validates, shows, routes and posts the invoice. What matters is that the original XML and its transmission evidence end up in the archive unchanged, that approval happens in one system only, and that the ERP document number flows back to the archived invoice.
How long must received e-invoices be kept in the eight countries?
As of 3 October 2026: Belgium 7 years, Germany 8 years, Italy 10 years, Slovakia 10 years, Poland 10 years inside KSeF (longer outside it if the tax limitation period has not expired), France 10 years under commercial law and 10 years for tax from 1 January 2027, Spain 6 years under commercial law, Romania 5 years under accounting law. The periods start at different points, from the end of the calendar year of issue to the last entry in the books.
What do your entities have to do, and by when?
Add your entities and countries and get one dated plan with sources and a calendar file. Runs in your browser.
Run the readiness checkSources
- Council Directive 2006/112/EC (VAT Directive), Articles 233 and 244–249, The National Archives (copy of EU legislation as at 31 December 2020)
- Council Directive (EU) 2025/516 of 11 March 2025 amending Directive 2006/112/EC as regards VAT rules for the digital age, Publications Office of the European Union
- Obtaining a copy of the European standard on eInvoicing (EN 16931-1:2026), European Commission
- Peppol BIS Billing 3.0, May 2026 release, OpenPeppol AISBL
- Structured electronic invoices between companies are compulsory since 2026, FPS BOSA / FPS Finance, Belgium
- Comment conserver des factures reçues via la facturation électronique ? (8 April 2026), FPS BOSA / FPS Finance, Belgium
- § 14 UStG – Ausstellung von Rechnungen, Federal Ministry of Justice (Germany)
- § 14b UStG – Aufbewahrung von Rechnungen, Federal Ministry of Justice (Germany)
- § 147 AO – Ordnungsvorschriften für die Aufbewahrung von Unterlagen, Federal Ministry of Justice (Germany)
- BMF letter of 15 October 2025: introduction of the mandatory e-invoice (validation, retention of the structured part), Federal Ministry of Finance (Germany)
- BMF letter of 14 July 2025: second amendment of the GoBD (retention of e-invoices), Federal Ministry of Finance (Germany)
- Fragen und Antworten zur Einführung der obligatorischen E-Rechnung (as of March 2026), Federal Ministry of Finance (Germany)
- Je découvre la facturation électronique (updated 26 May 2026), DGFiP, France
- Facturation électronique : guide pratique de démarrage au 1er septembre 2026 (July 2026), DGFiP, France
- Livre des procédures fiscales, article L102 B (version in force from 1 January 2027), Légifrance (DILA)
- Decreto legislativo 5 agosto 2015, n. 127, art. 1 – Fatturazione elettronica, Normattiva
- Come si conservano le fatture elettroniche, Agenzia delle Entrate
- KSeF 2.0: Podstawy prawne oraz kluczowe terminy, Ministry of Finance and Economy, Poland
- Ustawa o podatku od towarów i usług, consolidated text Dz. U. 2025 poz. 775 (arts. 112, 112a, 112aa), Dziennik Ustaw Rzeczypospolitej Polskiej
- Ordonanța de urgență a Guvernului nr. 120/2021 privind RO e-Factura (consolidated), Portal Legislativ / Ministry of Justice
- Procedura de utilizare și funcționare a sistemului RO e-Factura, Ordinul ministrului finanțelor nr. 1365/2021, art. 8, Portal Legislativ / Ministry of Finance
- eFaktúra: Peppol, certified delivery service providers, Financial Administration of the Slovak Republic
- Najčastejšie otázky a odpovede k eFaktúre (version of 14 September 2026), Financial Directorate of the Slovak Republic
- Real Decreto 238/2026, de 25 de marzo (mandatory B2B e-invoicing), Boletín Oficial del Estado
- Real Decreto 1619/2012, Reglamento por el que se regulan las obligaciones de facturación, Boletín Oficial del Estado
Vendor facts come from our data sheets, each value with source and check date. How we work: methodology.