TL;DR
Since 1.1.2025: booking vouchers eight years (§ 147(3) AO, § 257(4) HGB), invoices eight years (§ 14b(1) UStG). Unchanged at ten years: commercial books, inventories, opening balance sheets, annual accounts — and the records under § 22(1) UStG, which the Federal Ministry of Finance expressly confirmed on 8 July 2025. Commercial letters received and sent remain at six.
What the BEG IV changed, and what it did not
The Fourth Bureaucracy Relief Act came into force on 1 January 2025 and cut the retention period for booking vouchers from ten years to eight. The same cut applies for VAT purposes to invoices. The shortened period applies first to vouchers whose period under the old law had not yet expired on 31 December 2024 — vouchers from 2014 and earlier were free in any case.
What the statute did not touch sits in the same paragraph one line above: commercial books, inventories, opening balance sheets, annual accounts, individual and consolidated accounts all stay at ten years. Commercial letters received and sent stay at six. Three periods where there used to be two, on documents that live in the same filing system.
The exception the legislator skipped
The reduction in § 14b UStG covers invoices. It does not cover the records under § 22(1) UStG — the VAT records on which those invoices rest. The Federal Ministry of Finance put this in writing in its letter of 8 July 2025: those records must still be kept for ten years.
The result is a configuration no deletion schedule written in 2023 knows about: the invoice may be deleted after eight years, the record it derives from only after ten. Keeping both on the same line of the deletion matrix means choosing one of the two errors.
- Keeping data two years too long is not a harmless surplus: it breaches Art. 5(1)(e) GDPR, and it hits the archive holding the most personal data on customers, suppliers and staff.
- Deleting two years early breaches the retention duty, and only becomes visible at the next audit — by which point it cannot be repaired.
- § 147(3) sentence 5 AO suspends the period anyway for as long as the documents matter for taxes not yet time-barred. A routine that looks only at the document date destroys, mid-audit, papers that would have to be produced.
- For e-invoices, the structured part must be kept unchanged in its original form. An archived PDF of the human-readable rendering does not discharge the duty, however complete it looks.
What to do about it now
Split the deletion schedule into the three groups — eight, ten, six — instead of one blanket period. Insert a check on audit and appeal status before every automated deletion. And date the change: a statutory amendment that obliges the controller to act should be implemented demonstrably, not silently.
The quick test on your own record is a single question: does the retention column hold a number, or does it say which document type follows which provision? If it holds only a number, the record does not describe the law but a simplification that has been wrong in both directions since 1 January 2025.
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