Archiving e-invoices: who, how long and in what form

In short

• Electronic invoices are kept by the VAT payer, both issued and received, for ten years from the end of the calendar year to which the invoice relates.
• What is kept is the XML. A PDF is only an image document and does not replace an archive in XML.
• The digital postman has no legal duty to keep the XML files it has sent. The duty remains with you.
• A person not registered for VAT who only receives e-invoices is not covered by the duty to keep electronic invoices under § 85o. For some received invoices, however, § 76 applies (described below).
• Our Data archive keeps the originals in the EU for the duration of our cooperation. It is storage, not a takeover of your legal duty.

Who must keep e-invoices

The retention of invoices is governed by § 76 of Act No. 222/2004 Coll. on VAT. The Financial Administration (hereinafter FS) states that this section remains unchanged after 1 January 2027, so it applies as before (FS FAQ, part II, question 18). Under it, the VAT payer keeps copies of the invoices it issued (or that the customer or a third party issued on its behalf) and the invoices it received (§ 76(1)(a)).

A special rule has been added for electronic invoices. In the period from 1 January 2027, according to FS, the procedure under § 85o(15) of the VAT act in the wording effective until 30 June 2030 applies: the VAT payer is obliged to keep an electronic invoice for ten years from the end of the calendar year to which it relates (FS FAQ, part I, question 59). The FS guide for non-governmental organisations adds that this duty applies to VAT payers regardless of whether they are the supplier or the customer.

The government bill (print 1454), status on 30 September 2026 in first reading, proposes deleting paragraph 10 from § 85o and renumbering the following paragraphs, so the paragraph on retention would become paragraph 14. The bill does not change its wording. The bill is not yet law.

For how long

Ten years from the end of the calendar year to which the invoice relates. An invoice for a supply in March 2027 is therefore kept until the end of 2037. Section 76(1)(a) sets the same ten-year period for other invoices too. Received invoices relating to capital goods under § 54(2)(b) and (c) are treated differently: they are kept until the end of the period for adjusting the deducted tax (§ 76(1)(b)).

In what form: XML, not PDF

According to FS, a PDF invoice is only an image document, whereas an e-invoice is a structured XML file that is processed automatically (FS FAQ, part I, question 3). For archiving, FS starts from the definition of an electronic invoice and concludes that the VAT payer is obliged to archive electronic invoices in XML format (FS FAQ, part I, question 59). Storing a PDF instead of the XML is therefore not enough.

If the supplier also embedded its own PDF in the invoice as an attachment (field BT-125, which Peppol allows, FS FAQ, part II, question 8), it is part of the XML and you archive it together with it. The taxable person also ensures the authenticity of origin, integrity of content and legibility of the invoice from its issue until the end of the retention period (§ 71(3), as quoted in FS FAQ, part II, question 15). In practice: do not overwrite the original file, and if your software converts it into its own format on import, keep the original.

The digital postman does not take over archiving

To the question whether archiving passes to the digital postman, FS answers unambiguously: the provider of the delivery service has no legal duty to keep the XML files it has sent (FS FAQ, part II, question 18). The duty remains with you under § 76 and § 85o(15).

Under § 76a(2)(c) of the VAT act the postman ensures the authenticity of origin, integrity of content and legibility of the e-invoice from its sending until delivery to the addressee, that is, during the time the invoice is under its control (FS FAQ, part II, question 15). After delivery, retention is a matter for the supplier and the customer. When choosing a provider, therefore, clarify where the XML goes after delivery: into your accounting software, into your own storage, or into an archive the provider offers you as a service.

Persons not registered for VAT

In the FS FAQ, question 59 in part I asks about the difference between a VAT payer and a taxable person, but FS formulates the answer only for the VAT payer. The FS guide for non-governmental organisations addresses it expressly: the duty to keep electronic invoices under § 85o(15) applies only to VAT payers. If an organisation is not a VAT payer and is the recipient of an electronic invoice, the duty to keep electronic invoices under the VAT act does not apply to it. In the same answer the guide adds that paper invoices may continue to be kept in electronic form and electronic invoices also in paper form. For the VAT payer, however, the FS conclusion from question 59 applies: it archives in XML.

Section 76 itself also lists specific cases where other persons must keep invoices. A taxable person that is not a VAT payer keeps for ten years copies of the invoices it issued under § 72(2) and received invoices for goods and services for which it is the person liable to pay the tax (§ 76(2)). A legal person that is not a taxable person keeps received invoices for which it is the person liable to pay the tax (§ 76(3)).

A separate question is the retention of accounting records under the Accounting Act, which this article does not cover; if you keep accounts, check the period with your accountant.

The Data archive at Verteco

For new companies the Data archive is switched on by default: we keep the originals of received and issued invoices (XML) on servers in the EU for as long as you work with us, with 1 GB of storage included. It is switched on separately for received and for sent documents. The service with the archive costs €2 excluding VAT per month per IČO (company registration number); it is billed for a month in which the company sent at least one invoice or had the archive switched on at the end of the month. The price includes 1,000 invoices a month (sent and received together), each further invoice costs €0.01 excluding VAT. Before 1 January 2027 we bill nothing.

If you switch the archive off, receiving is free up to 1,000 invoices a month. You download the original in the portal or via the API right after delivery (by e-mail with the PDF and the original XML you receive it with the notification setting “For every invoice”; the webhook announces the receipt of the document and its identifier) and we irreversibly delete the content of the document after the chosen period: by default 14 days after delivery, configurable from 1 to 90 days. Only operational metadata and the delivery receipt remain. In that case you handle archiving entirely yourself. Details are on the page Data archive and the mode without an archive.

In the portal you download the original XML files as a ZIP (all, received only or sent only, for the chosen period) and separately a CSV overview of the documents. Your accounting software can also download them directly via the API, or you use the export to accounting programs described in the how-to guides. Accounting firms with several clients find an overview on the page for accountants.

The portal has no automatic synchronisation to OneDrive, SharePoint or Google Drive. If you want a copy in your own storage, download the ZIP with the originals regularly, for example once a month.

Remember that our archive lasts for the duration of our cooperation, while the statutory ten-year period continues to run after it ends. When you leave, you download all documents (the original XML files and the CSV overview); on request we hand them over to you, delete our copies, or both, as described on the page Service continuity. The context of the whole change from 2027 is summarised in the article e-invoicing in Slovakia from 1 January 2027.

Frequently asked questions