Archiving E-Invoices the GoBD-Compliant Way
An e-invoice is more than its printout – the structured data behind it is what has to be preserved, in its original format, unchanged and retrievable. This guide walks through what the GoBD principles and the term “audit-proof” mean in concrete terms for XRechnung and ZUGFeRD.
June 5, 2026
In short
An e-invoice is an invoice in a structured format per EN 16931 – not the PDF you see of it. What you retain is the received original in its original format: for XRechnung the XML file, for ZUGFeRD the PDF together with its embedded XML. The GoBD require these records to stay complete, unalterable (audit-proof) and retrievable and to be stored throughout the statutory retention period. A printout alone is not enough for that.
Why a printout isn’t enough
It’s tempting to print an incoming e-invoice or save it as a PDF and consider the matter closed. With an e-invoice, though, that falls short.
By definition, an e-invoice is an invoice in a structured electronic format per the European norm EN 16931. The actual content sits in machine-readable data fields. A plain PDF is not an e-invoice in this sense – and a printout or image copy does not reproduce the structured data layer. Yet that very layer is the original that has to be retained.
Worth noting: what you retain is the received original in its structured form, not a view of it generated afterwards. A paper printout of an XRechnung does not replace the XML file.
The GoBD principles in four terms
Behind the abbreviation GoBD sit the German principles for the proper keeping and retention of books, records and documents in electronic form. For archiving e-invoices, four requirements stand out:
Completeness
Every invoice is captured and retained in full – with all of its structured data, not just a part or a view of it.
Unalterability (audit-proof)
Once filed, an invoice can no longer be changed or deleted unnoticed. Changes are logged in a traceable way.
Retrievability
Each invoice can be found again specifically and evaluated by machine – filed in an orderly way, not in a cluttered catch-all folder.
Retention period
Invoices are stored throughout the statutory retention period and stay legible and accessible during that time.
These principles aren’t new – they apply to digital bookkeeping in general. With the e-invoice they simply take on a concrete form, because the original here is a structured file.
“Audit-proof” doesn’t mean an invoice may never be touched again. It means every change stays traceable – you can later show what happened, when and by whom.
What that means for XRechnung and ZUGFeRD
The two formats common in Germany differ in structure – and so in what exactly is retained.
XRechnung
A purely structured XML format. Here the XML file is the original – and it is exactly this file that is retained unchanged. A PDF view generated from it is only a representation, not a substitute.
ZUGFeRD
A hybrid format: a PDF with embedded XML. PDF and XML form a unit and belong together. Both parts are kept together and unchanged so that the structured data is preserved.
In both cases the same principle applies: the received original is secured in its original format. Anyone who keeps only the visible PDF of a ZUGFeRD invoice and loses the embedded XML no longer has the structured part of the e-invoice – and therefore not the complete original.
The process documentation
Part of the GoBD is that it is traceable how documents are received, processed and retained. This description is called the process documentation (Verfahrensdokumentation).
For e-invoices, it typically records by which route invoices arrive (by email, through a portal, via a transport network such as Peppol), in which format they are stored, how unalterability is ensured and how long they are retained. It makes your own process traceable for third parties and for a tax audit.
Worth knowing: The process documentation is not a one-off document for the drawer. It describes the process as actually practised – and should therefore stay up to date whenever the process changes.
In short
Archiving an e-invoice in a GoBD-compliant way comes down to retaining the structured original in its original format – for XRechnung the XML file, for ZUGFeRD the PDF together with its embedded XML. A printout or a plain PDF view is not enough for that.
The four GoBD principles set the frame: complete, unalterable (audit-proof), retrievable and stored throughout the statutory retention period. A process documentation records what this process looks like in concrete terms in your own organisation.
Sources
- Bundesministerium der Finanzen – FAQ on the introduction of the mandatory e-invoice
- Bundesministerium der Finanzen – Principles for the proper keeping and retention of records (GoBD)
Related articles
With Orcha: The documents agent takes in e-invoices and files them in an orderly way together with their structured original data – the XML of an XRechnung as well as the PDF and embedded XML of a ZUGFeRD – so that the original stays retrievable.
FAQ
Is it enough to print an e-invoice as a PDF and file it away?
No. An e-invoice is an invoice in a structured electronic format per the EN 16931 norm. What counts are the structured data – not a printout or a PDF view of them. Under the GoBD, the received original must be retained, meaning the structured file itself. A paper printout or a plain image file does not reproduce that data layer and therefore does not count as proper retention of the e-invoice.
What does audit-proof mean in archiving?
Audit-proof (revisionssicher) means that once an invoice has been filed, it can no longer be changed or deleted unnoticed (unalterability). Subsequent changes must be logged in a traceable way. This is one of the central GoBD principles: records should be complete, unalterable, orderly, and at all times retrievable and machine-evaluable throughout the statutory retention period.
How do you archive XRechnung and ZUGFeRD correctly?
With XRechnung, the structured XML file is the original and is retained in exactly that form. With ZUGFeRD, the PDF and the XML embedded in it form a unit – both parts belong together and are kept together and unchanged so that the structured data is preserved. In both cases, the goal is to secure the received original in its original format and keep it retrievable throughout the retention period.
Do I need a process documentation for e-invoice archiving?
The GoBD require that it is traceable how documents are received, processed and retained – this is the so-called process documentation (Verfahrensdokumentation). For e-invoices, it describes, for example, by which route they arrive, in which format they are stored, how unalterability is ensured and how long they are retained. It makes your own archiving process traceable for third parties and for a tax audit.
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