Can I print out an e-invoice and archive the printout?

No. Under GoBD regulations, electronic documents must be retained in the original format. A printout of a ZUGFeRD PDF or XRechnung XML does not meet the requirements. The original file must remain stored digitally.

Is it enough to save the ZUGFeRD PDF as a regular PDF?

The ZUGFeRD file IS a PDF — you save it like any other PDF file. Important: use “Save as” instead of “Print to PDF,” as the latter removes the embedded XML.

Do I also need to archive the visual copy for XRechnung?

No. Only the original XML file is subject to the archiving requirement. A visual copy (PDF visualization) can be stored additionally but is not mandatory.

Can I store e-invoices in the cloud?

Yes, provided the cloud provider meets GoBD requirements: immutability, traceability, access for tax audits. Servers must be located in the EU. Providers like Google Cloud, AWS (Frankfurt), or Microsoft Azure (Germany) are suitable.

What happens if I don't archive e-invoices correctly?

During a tax audit, the tax office can reject your bookkeeping and estimate your profit (§ 162 AO). Additionally, input tax deduction can be denied if the original invoice cannot be produced.

E-Invoice Archiving: GoBD-Compliant Retention of ZUGFeRD and XRechnung

With the e-invoice mandate from 2025, companies face an often-overlooked question: how do I archive ZUGFeRD and XRechnung files so they comply with GoBD requirements (Grundsätze zur ordnungsmäßigen Führung und Aufbewahrung von Büchern — Principles for the Proper Management and Retention of Books, Records, and Documents in Electronic Form)?

> Quick answer: E-invoices must be retained in the original digital format for 10 years — ZUGFeRD as PDF, XRechnung as XML. Printing or converting to another format is not GoBD-compliant. Cloud storage is permitted if the servers are in the EU.

How long must e-invoices be retained?

The retention requirement is 10 years (§ 147 AO, § 257 HGB). The period begins at the end of the calendar year in which the invoice was issued or received.

Example: An invoice from March 15, 2026 must be retained until December 31, 2036.

This requirement applies to:

Outgoing e-invoices (those you send)
Incoming e-invoices (those you receive)
All formats: ZUGFeRD, XRechnung, Factur-X

What does GoBD require for electronic invoices?

GoBD sets four central requirements for archiving electronic documents:

1. Retention in original format

An e-invoice must be retained in the format in which it was received or created:

ZUGFeRD: The original PDF file with embedded XML
XRechnung: The original XML file

A printout, screenshot, or conversion to another format (e.g., JPEG, TIFF) is not sufficient.

2. Immutability

The archived file must not be modifiable after storage. This means:

No saving on a regular file system where employees can delete or overwrite files
Ideally a document management system (DMS) with versioning and deletion protection
Alternatively: WORM storage (Write Once Read Many) or a cloud service with appropriate configuration

3. Traceability (procedural documentation)

You must document how e-invoices are received, processed, and archived. This document is called procedural documentation (Verfahrensdokumentation) and is requested during tax audits.

4. Access for tax audits

The tax office must have access to archived e-invoices during an audit — in the original format and machine-readable. This means the XML data (not just the PDF view) must be available.

Which archiving solutions are suitable?

Document management systems (DMS)

Professional DMS solutions such as d.velop, ELO, DocuWare, or ecoDMS offer:

Automatic import of e-invoices via email
Versioning and deletion protection
Full-text search in XML data
GoBD certification

Cloud storage with access controls

For smaller companies, cloud storage can be sufficient if:

Servers are located in the EU (Google Cloud Frankfurt, AWS Frankfurt, Azure Germany)
Access permissions are configured so files cannot be deleted
Procedural documentation exists

Accounting software with archive function

Many programs like DATEV, Lexware, and sevDesk offer integrated archiving:

E-invoice is automatically saved in original form upon import
Linked to the posting record
Export for tax audits

What mistakes should I avoid?

Mistake	Why it's problematic	Solution
Print e-invoice and file paper copy	Not original format, violates GoBD	Save digitally in original format
"Print to PDF" instead of "Save as"	Removes embedded XML from ZUGFeRD	Always use "Save as"
Convert XRechnung XML to PDF and archive only the PDF	Original is lost	Always retain the XML file
Store on local desktop without backup	Risk of data loss, no deletion protection	Use cloud or DMS with backup
No procedural documentation	Tax office can challenge bookkeeping	Create procedural documentation

Do I need to archive both the XML and the PDF?

For ZUGFeRD, this is not an issue — the XML is embedded in the PDF. When you save the ZUGFeRD PDF file, you automatically have the XML as well.

For XRechnung, there is no PDF. Only the original XML file is subject to archiving. A visual copy (PDF visualization) can be stored additionally but is not required.

Tip: Check received e-invoices before archiving with the free TaxLayer Validator for completeness. This way you can identify missing mandatory fields immediately and ask the sender for a correction.

What happens with improper archiving?

During a tax audit, the tax office can:

Reject your bookkeeping and estimate profit (§ 162 AO)
Deny input tax deduction if the original invoice cannot be produced
Impose delay penalties (§ 146 para. 2c AO: €2,500 per commenced day)

Checklist: GoBD-compliant e-invoice archiving

Save e-invoices in the original format (ZUGFeRD PDF or XRechnung XML)
Ensure immutability (DMS, WORM storage, or cloud with deletion protection)
Create and maintain procedural documentation
Ensure access for tax audits (export function, machine-readable)
Comply with retention period of 10 years
Document your backup strategy

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