Every company in Germany is legally obligated to retain business documents for a specified period. The retention periods for invoices, contracts, posting receipts and other business documents are clearly regulated in the German Fiscal Code (AO) and the German Commercial Code (HGB). Violations can have serious consequences – from fines to tax assessments. In this comprehensive guide, you will learn which retention periods apply to which documents, when the period begins, how to archive digitally in a GoBD-compliant manner and which special features apply specifically to car dealers.
At a glance: Invoices, annual financial statements and posting receipts must be retained for 10 years. Business correspondence and other commercial letters are subject to a 6-year retention period. The period begins in each case at the end of the calendar year in which the document was created or received. With AutoPult GoBD archiving, all your documents are automatically archived in an audit-proof and timely manner.
Legal Foundations of Retention Periods
The retention periods for business documents arise from two central legal sources: the German Fiscal Code (AO) and the German Commercial Code (HGB). Both laws regulate which documents must be retained for how long – with slightly different focuses.
§147 German Fiscal Code (AO) – Tax Law Obligation
§147 AO is the central tax law provision for retention obligations. It applies to all taxpayers who are obligated to keep books or who keep books voluntarily. The provision distinguishes between two periods:
- 10 years: Books and records, inventories, annual financial statements, management reports, opening balance sheets, posting receipts and invoices
- 6 years: Received and sent commercial letters and other documents, insofar as they are relevant for taxation
§257 German Commercial Code (HGB) – Commercial Law Obligation
§257 HGB regulates the retention obligations from a commercial law perspective. The periods largely correspond to those of the AO. Important: merchants as defined by the HGB – and this includes most car dealers – are also subject to these obligations. The commercial and tax law retention periods run in parallel in practice, so the longer period generally applies.
Other Relevant Provisions
In addition to §147 AO and §257 HGB, there are further provisions that may establish retention obligations:
- §14b UStG: Special retention obligation for invoices (10 years) – also applies to small business owners
- GoBD: The principles for the proper management and storage of books, records and documents in electronic form regulate the requirements for digital archiving in detail
- §25a UStG: Margin taxation – special documentation obligations for used car dealers
10 Years vs. 6 Years: Which Documents Fall Where?
Correctly assigning your documents to the right retention period is crucial. As a general rule: everything directly related to bookkeeping and financial statements must be retained for 10 years. Documents that are more attributable to general business correspondence are subject to the 6-year period.
Documents with a 10-Year Retention Period
- Incoming and outgoing invoices – including all attachments and supplements
- Annual financial statements – balance sheet and income statement
- Posting receipts – bank statements, receipts, cash receipts
- Inventories and inventory lists
- Opening balance sheets
- Management reports
- Journals, day books and account books
- Tax returns and tax assessments
- Work instructions and organizational documents related to bookkeeping
Documents with a 6-Year Retention Period
- Business correspondence – received and sent commercial letters
- Quotes and order confirmations (provided they are not posting receipts)
- Insurance policies (after expiry)
- Payment reminders (provided they are not posting receipts)
- Personnel files (after the employee’s departure)
- Contracts with business relevance (provided they are not posting receipts)
Retention Period Table: All Document Types at a Glance
The following retention period table gives you a quick reference for which documents must be retained for how long. The information is based on §147 AO and §257 HGB (as of 2026).
| Document Type | Retention Period | Legal Basis | Note |
|---|---|---|---|
| Incoming invoices | 10 years | §147 AO, §14b UStG | Incl. e-invoices (XRechnung, ZUGFeRD) |
| Outgoing invoices | 10 years | §147 AO, §14b UStG | Also duplicates and cancellations |
| Annual financial statements (balance sheet, P&L) | 10 years | §147 AO, §257 HGB | Incl. notes and explanations |
| Posting receipts / bank statements | 10 years | §147 AO | Also electronic bank statements |
| Cash receipts / cash book | 10 years | §147 AO | Daily cash reports for cash transactions |
| Inventories / inventory lists | 10 years | §147 AO, §257 HGB | Stock records as of the balance sheet date |
| Opening balance sheets | 10 years | §147 AO, §257 HGB | Also for new formations or conversions |
| Management reports | 10 years | §257 HGB | Mandatory for corporations |
| Tax returns / tax assessments | 10 years | §147 AO | Recommended until finality + period |
| Payroll and salary statements | 10 years | §147 AO | Classified as posting receipts |
| Mileage logs | 10 years | §147 AO | Tax-relevant records |
| Business correspondence (received/sent) | 6 years | §147 AO, §257 HGB | Also emails with business content |
| Quotes / order confirmations | 6 years | §257 HGB | Provided they are not posting receipts |
| Payment reminders | 6 years | §257 HGB | Also court orders for payment |
| Contracts (general) | 6 years | §257 HGB | After end of contract term |
| Insurance policies | 6 years | §257 HGB | After expiry of the insurance relationship |
| Personnel files | 6 years | §257 HGB | After employee departure |
| Purchase contracts (automotive trade) | 10 years | §147 AO | As posting receipts for vehicle sales |
| §25a documentation (margin taxation) | 10 years | §25a UStG, §147 AO | Purchase and sales documentation mandatory |
| EU import documents (vehicles) | 10 years | §147 AO, §14b UStG | CMR, customs documents, transport proof |
When Does the Retention Period Begin?
One of the most common questions about retention periods concerns the start of the period. The rule is clear but is often applied incorrectly:
Start of period: The retention period begins at the end of the calendar year in which the last entry was made in the book, the inventory or balance sheet was prepared, the commercial letter was received or sent, or the posting receipt was created (§147 para. 4 AO).
Practical Example for Period Calculation
An invoice dated March 15, 2026 is subject to the 10-year retention period. The period begins on December 31, 2026 (end of the calendar year) and ends on December 31, 2036. The invoice may only be destroyed from January 1, 2037.
For contracts, the period only begins at the end of the calendar year in which the contract expires or is terminated. A lease ending on June 30, 2026, with a 6-year period, may be destroyed at the earliest on January 1, 2033.
Special Case: Ongoing Tax Audit
If a tax audit is initiated by the tax office, the retention periods are automatically extended until the audit is concluded and all tax assessments have become final. This applies even if the regular retention period has actually already expired. In case of doubt, you should never prematurely destroy documents that could be the subject of an ongoing audit.
Digital vs. Paper: Archiving in the Digital Age
The good news: since the revised GoBD (Principles for the Proper Management and Storage of Books), virtually all business documents may be archived digitally. Paper documents may be digitized and the original subsequently destroyed – provided the digital archiving meets certain requirements.
Paper Archiving: Traditional but Labor-Intensive
Retention in paper form is still permissible but brings significant disadvantages:
- High space requirements for file folders and archives
- Risk from water, fire or fading (especially with thermal receipts)
- Time-consuming search for individual documents
- No automatic deadline monitoring
Digital Archiving: Efficient and GoBD-Compliant
Digital archiving is the most efficient way for modern companies to comply with retention periods. Especially for car dealerships that work daily with dozens of invoices, purchase contracts and vehicle documents, a digital document management system (DMS) offers enormous advantages.
GoBD Requirements for Digital Retention
The GoBD (BMF letter of November 28, 2019) define clear requirements for the electronic retention of business-relevant documents. Anyone archiving digitally must observe the following principles:
The 7 GoBD Principles
- Traceability and verifiability: A knowledgeable third party must be able to obtain an overview within a reasonable time
- Completeness: All documents subject to retention must be archived without gaps
- Accuracy: Documents must be stored correctly in content and consistent with the original
- Timely recording and documentation: Documents must be recorded and archived promptly
- Order: A systematic filing system with a traceable structure is required
- Immutability: Once archived, documents may not be subsequently altered or deleted
- Machine readability: Electronic data must remain available in the original format and be machine-readable
Procedural Documentation as a Requirement
A frequently underestimated aspect of the GoBD is procedural documentation. Every company that archives digitally must document how the archiving process works: from scanning through indexing to storage and deletion. If the procedural documentation is missing, the entire bookkeeping can be rejected during a tax audit.
AutoPult advantage: AutoPult GoBD archiving meets all GoBD requirements out of the box. The system automatically generates procedural documentation, stores all documents in an audit-proof manner with timestamps and hash values, and ensures machine readability.
What Happens After the Retention Period Expires?
Once the retention period for a document has expired, the question arises: may – or must – you destroy the documents?
May You Delete?
After the retention period expires, you may generally destroy documents. There is no legal obligation to retain documents beyond the period – provided no special case exists (e.g. ongoing tax audit, open legal disputes or non-final tax assessments).
Should You Delete?
From a data protection perspective (GDPR), it may even be required to delete personal data after the retention period expires. This particularly affects personnel files, customer data and business correspondence with personal content. A clearly defined deletion process protects you from GDPR fines.
Recommended Approach
- Annual review: Check at the beginning of each year which documents can be deleted from the archive
- Observe the blocked list: Documents still subject to open proceedings may not be deleted
- Destroy in a data protection-compliant manner: Shred paper documents (protection class 3), irrevocably delete digital data
- Create a deletion log: Document which documents were destroyed and when
Special Retention Periods for Car Dealers
For car dealerships and automotive dealers, in addition to the general retention periods, there are some industry-specific special features that you must know.
Vehicle Files and Purchase Contracts
Purchase contracts for vehicles are generally classified as posting receipts and are therefore subject to the 10-year retention period. This applies to both purchase and sales contracts. A complete vehicle file should also bundle all associated documents: purchase contract, invoice, registration documents, expert reports, handover protocol and any warranty agreements.
§25a UStG – Documenting Margin Taxation
Margin taxation under §25a UStG is of central importance for used car dealers. To apply margin taxation correctly, you must be able to provide seamless documentation for each vehicle:
- That the vehicle was acquired from a private individual or a non-input-tax-eligible entrepreneur
- The exact purchase price (individual proof per vehicle)
- The selling price and the resulting margin
This documentation obligation requires careful documentation over 10 years. If documents are missing during a tax audit, the tax office can retroactively revoke the margin taxation and apply full standard taxation – with considerable tax back payments.
EU Import Documents
When importing vehicles from EU countries, additional documents are generated that are also subject to the 10-year retention period:
- CMR consignment notes as proof of transport
- Transport proofs pursuant to §6a UStG (intra-Community supply)
- Foreign registration documents and deregistration certificates
- Invoices from the foreign seller
- Customs documents for imports from third countries
- Vehicle identification data (VIN matching, COC documents)
Consequences of Violating Retention Periods
Anyone who fails to comply with the statutory retention periods risks serious consequences. The tax office shows little leniency when documents are missing.
Tax Consequences
- Estimation of tax bases (§162 AO): If documents or bookkeeping records are missing, the tax office can estimate the tax liability – generally to the disadvantage of the entrepreneur
- Rejection of bookkeeping: In cases of serious deficiencies, the entire bookkeeping can be rejected as not properly conducted
- Denial of input tax deduction: Without proper invoices in the archive, the input tax deduction can be retroactively denied
- Revocation of margin taxation: Particularly relevant for car dealers – missing §25a documentation leads to standard taxation
Administrative Offenses and Fines
Under §379 AO, violation of retention obligations constitutes an administrative offense that can be punished with a fine of up to 25,000 euros. In cases of deliberate destruction of bookkeeping records, criminal consequences for tax evasion (§370 AO) may also follow.
Good to know: The tax office systematically checks compliance with retention periods during tax audits. Particularly in the automotive trade – with its combination of high individual values, margin taxation and EU trade – auditors look very closely.
How AutoPult Archives All Documents in a GoBD-Compliant Manner
As specialized software for car dealerships, AutoPult offers a fully integrated, GoBD-compliant archiving solution that automatically manages all retention periods.
- Automatic period calculation: AutoPult recognizes the document type and automatically calculates the correct retention period
- Audit-proof storage: All documents are immutably archived with timestamps and cryptographic hash values
- Digital vehicle files: Purchase contract, invoice, §25a documentation, registration documents and all other records bundled per vehicle
- Native e-invoice processing: XRechnung and ZUGFeRD are archived directly in the XML original format – for full machine readability
- DATEV integration: Seamless export to DATEV with automatic receipt linking
- Deadline warning and deletion assistant: You are informed when documents may be destroyed – including an automatic deletion log
- Procedural documentation included: AutoPult automatically generates GoBD-compliant procedural documentation
Frequently Asked Questions About Retention Periods
How long must invoices be retained?
Incoming and outgoing invoices must be retained for 10 years. The period begins at the end of the calendar year in which the invoice was issued or received. The legal basis is §147 para. 1 no. 4 AO in conjunction with §14b UStG.
When does the retention period begin?
The retention period always begins at the end of the calendar year in which the document was created, received or the last entry was made. An invoice from January 2026 therefore has a period start date of December 31, 2026.
May paper documents be destroyed after scanning?
Yes, under the current GoBD, paper documents may generally be destroyed after proper scanning. Prerequisite: the scan must be visually identical, complete and stored in a common format. Procedural documentation for the scanning process is mandatory.
What retention periods apply to emails?
Emails are subject to the same retention periods as their physical counterparts. An email with an attached invoice must be retained for 10 years. Business email correspondence without a posting connection falls under the 6-year period. Important: the email must be archived in its original format.
What happens if I prematurely destroy documents?
Premature destruction of documents subject to retention can lead to a tax assessment under §162 AO, a fine of up to 25,000 euros under §379 AO or – in cases of intent – charges of tax evasion. In the automotive trade, revocation of margin taxation is an additional risk.
As a car dealer, must I retain vehicle files?
Yes. Vehicle files generally contain posting-relevant documents (purchase contract, invoice, §25a documentation) and are therefore subject to the 10-year retention period. A structured digital vehicle file per vehicle is the best solution to comply with all deadlines.
How do I archive e-invoices in a GoBD-compliant manner?
E-invoices (XRechnung, ZUGFeRD) must be archived in the original electronic format – i.e. as XML or as PDF with embedded XML. A printout alone is not sufficient. The archiving system must ensure machine readability throughout the entire retention period.
Conclusion: Comply with Retention Periods Systematically
Complying with retention periods is not an optional exercise in diligence but a legal obligation with real consequences for violations. With the right system and a GoBD-compliant archiving solution, retention becomes routine rather than a burden.
For car dealers, particular care applies: the combination of margin taxation, EU imports and high vehicle values makes seamless documentation indispensable. Anyone who archives their documents digitally, systematically and in an audit-proof manner is well prepared for the next tax audit.
Get started: With AutoPult GoBD archiving and the integrated document management, you automatically comply with all retention periods – audit-proof, on time and without manual effort.
