Eight instead of ten — what changed in 2025
With the Fourth Bureaucracy Relief Act the retention period for accounting vouchers was reduced in principle from ten to eight years from 2025. An incoming invoice is such an accounting voucher.
That is no all-clear. Eight years of seamlessly retrievable, unchanged original are still a serious requirement — and for certain records ten years still apply.
When the period even starts
The period does not start with the invoice date but with the end of the calendar year in which the invoice arose or the last entry was made. An invoice from March 2026 is thus relevant well beyond 2034.
This late start is tricky: today's error surfaces only in a year in which nobody remembers the details anymore.
The XML is the obligation, not the PDF
The core: subject to retention is the structured original. For an XRechnung the XML, for ZUGFeRD the PDF including the embedded XML. A picture PDF generated from it is not enough.
Whoever saves only PDFs in year one has a problem without a solution in year seven. The original cannot be reconstructed later — it was from the start what you should have kept.
What else belongs in the archive
Beyond the pure original a clean archive secures traceability:
- The structured original, unchanged.
- A readable view (additionally, not as a substitute).
- The intake proof: when, via which channel.
- The approval/check log.
- An integrity proof (hash/timestamp).
Why “tidy up later” fails
Archiving is not a year-end project. Whoever pieces documents together from mailboxes afterwards can no longer credibly prove unalterability and completeness.
The only reliable method is to secure the original unalterably at the moment of intake — automatically, timestamped, for the whole period. Everything else is hope, not an archive.