#20260818001_EN2 min readUpdated: Category: Compliance & Regulations
What Must Be Retained
The structured data component is decisive. For XRechnung, this is the XML file; for ZUGFeRD, it is the embedded XML inside the PDF. This part must be preserved in its original form — unaltered, complete, and machine-readable throughout the entire retention period. A printout, a screenshot, or a regenerated PDF is insufficient because machine readability is lost.
The statutory retention period for invoices is eight years. It begins at the end of the calendar year in which the invoice was issued. For records that are part of ongoing matters — such as active tax audits or legal disputes — the retention period may effectively run longer.
Implementing Immutability in Practice
GoBD requirements dictate that once an entry or document is captured, it can no longer be modified unnoticed. Technically, this can be achieved in several ways: immutable storage in an archive system, checksums across the original dataset, versioning with change logs, or a combination of these. The decisive factor is not the specific method chosen, but that it is documented and actively enforced in operational practice.
A frequent weak point in projects is intermediate staging: file shares, email inboxes, or integration directories where invoice data resides prior to archiving and can be modified or deleted. This intermediate path must be included in the procedural documentation and requires the same diligence as the archive itself.
Audit Trail and Process Documentation
A robust audit trail answers four questions: where did the document originate, what validations were performed, who processed or approved it and when, and where is it stored today. In SAP landscapes, this information is typically distributed — across the integration layer, the accounting document, and the archive system. These elements must be linkable; otherwise, the trail cannot be demonstrated during an audit.
Procedural documentation is not a mere formality. It describes the actual workflow, including responsibilities, error handling, and system changes over time. Keeping it up to date significantly reduces audit durations.
Aligning Deletion and Data Privacy
Tax retention requirements and data protection deletion mandates are not mutually exclusive, but they must be harmonised. Invoice data may and must be retained for the statutory period; personal data extending beyond this — such as contact details in free-text fields — requires a dedicated deletion concept.
In practice, an automated deletion routine that executes after retention expires, maintains logs, and accounts for audit-related legal holds proves most effective. An archive without a deletion concept turns into a compliance liability over time rather than a safeguard.
Our Approach
OXORY assesses your archiving pipeline alongside the e-invoicing solution: where the original dataset originates, where it is immutably stored, which metadata accompanies it, and how access controls are governed. The result is a concise evaluation with actionable measures — not a theoretical study.
If you want to validate your existing storage setup against GoBD requirements, reach out to us; an initial assessment typically takes less than a week.
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