E-Invoice Archiving Requirements in the EU: Article 247 by Country

What it is

Archiving requirements are the rules that determine how, where, and for how long a business must retain its invoices after issuing or receiving them. For paper invoices this used to mean a filing cabinet. For e-invoices it means an electronic storage system that preserves the original structured file (the XML, in EU e-invoicing) in its original form, with cryptographic or procedural guarantees that it has not been altered since issue.

In the EU the baseline obligation is set by Article 247 of the VAT Directive (2006/112/EC), which leaves the actual retention period to each Member State. The corresponding integrity and audit obligations are in Article 233, which requires the authenticity of origin, the integrity of the content, and the legibility of the invoice to be ensured from issuance until the end of the storage period.

For ERP vendors and their customers, archiving requirements are the part of EN 16931 compliance that often gets discovered too late — after the integration is built, after the first audit notice arrives, after a regulator asks for the original XML and the system can only produce a PDF rendering.

The three pillars: authenticity, integrity, legibility

Article 233 of the VAT Directive imposes three requirements on every stored invoice:

Authenticity of origin — the recipient can prove who the invoice came from. Achievable through qualified electronic signatures (eIDAS), EDI agreements, or "any business controls which create a reliable audit trail between an invoice and a supply of goods or services." The audit-trail route is the one most ERPs use.

Integrity of content — the invoice has not been altered since issue. Hash-and-seal, qualified signatures, append-only archive systems, or controlled audit trails all qualify.

Legibility — the invoice can still be read at any point during the storage period. For structured XML this means the receiving system must be able to render it back into something human-readable on demand — typically via an XSLT viewer (KoSIT's stylesheets, or a vendor-built equivalent).

The three pillars apply equally to issued and received invoices, and equally to paper and electronic. The standard is the same; the implementation differs.

Retention periods by country

Member States set the storage period themselves under Article 247(1). The numbers below are the periods specifically relevant to issued and received invoices; longer periods may apply to related documents (contracts, real estate, etc.).

Germany. 10 years under § 147 of the Abgabenordnung (Tax Code), reinforced by the GoBD (principles of proper bookkeeping in electronic form). The July 2025 GoBD amendment clarified that for hybrid invoices (ZUGFeRD, Factur-X) the XML is the leading document; the PDF rendering alone is not sufficient. Conversion of the XML to other formats (PDF, TIFF) for internal use is permitted only if the original XML remains intact and accessible.

France. 6 years for tax purposes (Livre des Procédures Fiscales, Article L102B) and 10 years for accounting purposes (Code de Commerce, Article L123-22). Under the PPF e-invoicing regime, certified Plateformes de Dématérialisation Partenaires (PDPs) are required to archive invoices on behalf of their users for the full 10-year commercial-code period.

Italy. 10 years under Article 2220 of the Civil Code. The Sistema di Interscambio (SdI) provides centralised conservazione sostitutiva (substitute archiving) when the taxpayer opts in; otherwise, the taxpayer is responsible for digital archiving following the AgID rules (the "Linee Guida sulla formazione, gestione e conservazione dei documenti informatici").

Netherlands. 7 years under Article 52 of the Algemene Wet inzake Rijksbelastingen (general tax law), extended to 10 years for documents relating to immovable property.

Belgium. 10 years for invoices under Article 60 of the Belgian VAT Code (since 2019, harmonised from 7 years).

Spain. 4 years under Article 66 of the Ley General Tributaria, though the General Accounting Plan requires 6 years for accounting records. Verifactu adds a parallel real-time reporting trail.

Denmark, Sweden, Finland. 5–7 years depending on the document class; Denmark moved most invoice retention to 5 years under the 2024 Bookkeeping Act revision.

The asymmetry matters in cross-border B2B: the seller's archiving period is set by the Member State of the supply (usually the seller's establishment), and the buyer's archiving period is set by their own Member State. A French seller and a German buyer face different statutory periods over the same invoice.

What must actually be stored

The modern consensus, reinforced by the 2025 GoBD amendment in Germany and by the French PDP archiving rules, is that the original structured XML must be retained in its original form for the full retention period. Storing only a PDF rendering is not compliant — the PDF has lost the structured data that the original XML carried, and a regulator's request for "the original invoice" cannot be answered by handing over a derived rendering.

For hybrid invoices (ZUGFeRD, Factur-X) the XML is embedded inside a PDF/A-3 container, which means the container as issued is itself a valid archive copy provided no embedded element is stripped or replaced. For pure UBL or pure CII invoices, the XML must be archived separately; rendering for human viewing is the responsibility of a viewer (typically an XSLT stylesheet) at retrieval time.

In practice this means an archiving system needs:

1. The original XML, byte-for-byte as issued, indexed and retrievable by invoice number and date.
2. A demonstrable integrity guarantee — a hash, a signature, a WORM-storage attestation, or a controlled audit trail.
3. A viewer toolchain — XSLT stylesheets and a renderer — that can produce a human-readable rendering on demand throughout the retention period, including in 9 years' time when the staff that built the original integration are long gone.
4. An export interface — most tax authorities can request invoices for inspection in bulk, and "call our DBA" is not an answer that survives an audit.

Why ERP vendors get this wrong

The most common archiving failures we see in EU e-invoicing implementations are not about retention periods — those numbers are easy to look up. They are about format and integrity:

The system archives a PDF rendering and discards the original XML. Discovered when the customer's first VAT audit asks for "the original invoice in its issued format."

The system archives the XML but the schema files (UBL 2.1, CII D16B) are not archived alongside. The XML is unparseable in 8 years when the schema URLs return 404.

The system archives the XML but the codelist data (UN/CEFACT Recommendation 20, 21, 1001) referenced by attribute codes is gone. The numeric codes survive but the human meaning is lost.

The system relies on cloud-vendor-managed retention that defaults to 6 years globally, missing the 10-year obligations in DE/IT/BE.

The system stores the XML in a database that allows updates. "Append-only" is a property of the storage architecture, not a flag in a config file.

Relation to EN 16931

EN 16931 does not impose archiving requirements directly — it is a syntax-and-semantics standard, not a storage standard. But the moment an EN 16931 invoice has been issued or received under VAT law, the VAT Directive's Article 233 and 247 obligations attach to it. From the regulator's point of view, the EN 16931 invoice and the archiving obligation are one continuous compliance surface. An ERP that ships UBL 2.1 invoices but cannot produce them again in their original form 9 years later has solved half the problem.

Archiving requirements (e-invoice)

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