E-Invoice Retention 2027: Legal Deadlines, Formats and What the Tax Authority Requires

Issuing an electronic invoice is only half of your fiscal obligation. The other half is retaining it correctly for as long as the law requires. When VeriFactu comes into full force in 2027, failures in document retention will be directly enforceable: the AEAT (Spanish Tax Agency) will cross-reference invoicing records against what you have stored.

How long must invoices be kept?

Spanish law sets different retention periods depending on the legal basis:

Legal basis	Period	Applies to
Art. 29.2.e) LGT (tax obligations)	4 years	Invoices related to self-assessments (VAT, CIT, PIT)
Art. 30 Spanish Commercial Code	6 years	Accounting books and supporting documentation
Arts. 25–26 LSC (Capital Companies Act)	10 years	Accounting documentation for registered companies
Art. 19 Invoicing Regulation (RD 1619/2012)	4 years minimum	All invoices issued and received

Practical rule: If you are a registered company, always retain for 10 years. This single criterion satisfies all deadlines and avoids classification errors by invoice type.

In what format must invoices be retained?

Article 19 of the Invoicing Regulation requires invoices to be retained in the original format in which they were issued or received. This has important practical consequences:

• Paper invoice: may be digitised if the process in art. 7 of the Invoicing Regulation is followed (minimum resolution, approved process). Once digitised, the paper original is no longer required.
• Electronic invoice (XML, signed PDF, etc.): must be retained in electronic format. You cannot print and destroy the original digital file.
• VeriFactu invoices: the XML invoicing record file (LRFC) and the visual representation must be retained together. The QR code is a verification access point only — it does not replace the original file.

Integrity and immutability

The law does not only require storing the file — it requires the ability to prove it has not been altered since issuance. For digitally signed electronic invoices this is covered by the signature itself: the verifier can confirm the file was not modified. For unsigned invoices (e.g. unsigned PDF), integrity depends on the archive system.

In the VeriFactu context, the hash chain (SHA-256 of each record chained to the previous one) guarantees the immutability of the LRFC. The AEAT can verify it at any time using the VERI*FACTU data it holds.

What happens during a tax audit

In an inspection or information request concerning VAT or corporate income tax, the AEAT may require:

1. The invoice register books for issued and received invoices (arts. 63 and 64 of the VAT Regulation).
2. The original invoices that support the register entries (to verify deducted or charged VAT).
3. For VeriFactu, the LRFC file or, alternatively, the chain of records sent to the AEAT as part of the system.

If you cannot produce the original invoices supporting a deducted VAT amount, the Administration may disallow that deduction and apply a penalty under art. 170 LIVA (penalty of 100% of the unjustified amount, minimum €300).

Cloud storage: is it valid?

Yes. The Invoicing Regulation does not require any specific physical medium. Cloud storage — including servers outside Spain — is valid if:

• Invoices are accessible online at any time during the retention period.
• The taxpayer can provide invoices in readable format upon request.
• Access does not depend on the software provider remaining active — this is the most critical point: if your invoicing software shuts down, can you still recover your invoices?

InvoSeal allows you to export your complete invoice archive in XML and PDF format at any time, regardless of whether you remain a customer.

B2B electronic invoicing from 2027

When the B2B electronic invoicing obligation extends to all businesses (under the Ley Crea y Crece and pending implementing regulations), the invoice recipient will also be required to acknowledge receipt and retain the invoice in electronic format. A self-employed professional or company that receives a paper invoice from a supplier will not be able to digitise it without a compliant process.

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