How long to keep e-invoices: HMRC retention and archiving rules

HMRC says you must normally keep copies of all the invoices you issue and receive for 6 years, and that applies to e-invoices in exactly the same way as paper. That is the rule in HMRC's electronic invoicing notice (VAT Notice 700/63), and it is not expected to change because of the 2029 mandate. What does change is what you store: a structured e-invoice is data, and HMRC expects you to be able to reproduce that data as it was.

The core rules

From HMRC's record-keeping and electronic invoicing notices:

• Retention period: "Generally, you must keep all your business records for VAT purposes for at least 6 years." For invoices: "You must normally keep copies of all the invoices you issue and all the invoices you receive for 6 years."
• Same rules, any format: "The same rules apply to storage of electronic invoices as to paper invoices."
• Shorter periods by agreement only: if 6 years causes serious storage problems or undue expense, contact HMRC; it "may be able to allow you to keep some of the records for a shorter period."
• Penalty: failing to preserve required records can lead to a £500 penalty under section 69 of the VAT Act 1994.

What HMRC expects you to store

Notice 700/63 section 5 sets the standard for electronic storage. You must:

1. Guarantee authenticity and integrity of the invoice content throughout the storage period, by electronic or procedural means.
2. Store all the data related to your invoices, including the evidence that shows authenticity and integrity were ensured.
3. Be able to recreate the invoice data as at the time it was originally sent or received, and present it in a readable format.
4. Keep history files, so that you can find details from any point in the past if HMRC asks.

You must also be able to give HMRC access. It may ask for access to systems that produce or receive invoices, documentation of your file structures and controls, and copies of data.

A practical e-invoice archive checklist

Store this	Why
The original e-invoice file (for example the UBL XML) as sent or received	It is the invoice. You need to recreate the data "as at the time of its original transmission or receipt".
Any attachments embedded in the e-invoice	They form part of the document you exchanged.
A readable rendering, or the ability to produce one	HMRC requires a "readable format".
Transmission evidence such as timestamps, sender and receiver IDs and delivery status	Supports authenticity and integrity.
Validation results and any rejection or response messages	Shows what happened to the invoice.
Credit notes and corrections linked to the original	Credit notes must identify the original invoice.
Self-billing agreements, if relevant	HMRC can ask to see them.
Your ERP posting and audit trail	Notice 700/63 requires an audit trail between the e-invoicing system and your accounting systems.

Do not rely only on a PDF. A PDF generated from an e-invoice is a useful view, but if the structured data is the legal invoice, the PDF is not a full substitute. Keep both if you can.

Where you can store e-invoices

HMRC's notice allows storage outside the UK:

• In an EU member state: HMRC recommends maintaining online access, and you must be able to produce records in a readable form, within a reasonable time, at a mutually agreed place.
• Elsewhere: allowed if the country respects UK data protection principles and you can produce records in the same way. Again, HMRC recommends online access.

Cloud storage is therefore possible, but check your provider's data location and export options.

Who is responsible if you outsource?

You are. HMRC's notice says that if you outsource issuing e-invoices to a third party, "all the legal obligations with regard to the contents, storage and production of the invoices issued remain with you." The same applies to outsourced processing and storage of purchase invoices.

Under the UK's Peppol model, your Access Point delivers invoices but is not necessarily your archive. Check:

• how long your provider keeps sent and received documents
• whether you can bulk-export the original files
• what happens to your archive if you change provider

When 6 years isn't long enough

VAT is not the only rule. Invoices are also accounting records for other taxes:

• Limited companies: GOV.UK says records must be kept for 6 years from the end of the last company financial year they relate to, or longer in some cases. Examples include transactions spanning more than one accounting period, assets expected to last more than 6 years, a late Company Tax Return, or an HMRC compliance check that has started.
• Sole traders: at least 5 years after the 31 January submission deadline of the relevant tax year. That can run past 6 years from the invoice date, so check which rule ends later.

In practice, many businesses set a single retention period that meets the longest rule that applies to them.

Scanned and converted invoices

If you scan paper invoices and keep them electronically, HMRC accepts that "as long as you can meet the requirements … for ensuring authenticity, integrity and legibility". Under MTD, if your software scans an invoice and keeps an image with all the VAT details, you need not keep the paper original unless you need it for another purpose.

What the 2029 mandate may add

The government has not announced new retention rules for the mandate. Points to watch in the roadmap and later guidance:

• whether HMRC will specify formats for stored e-invoices
• whether access points will have any archiving duties
• how long transmission and validation evidence must be kept

What to do now

1. Confirm your retention policy covers at least 6 years for VAT and any longer periods for other taxes.
2. Ask your software or Access Point provider how it stores the original e-invoice files and how you can export them.
3. Test retrieval. Can you produce an invoice from five years ago, in a readable form, quickly?
4. Document your controls for authenticity and integrity.

See also does a PDF invoice count as an e-invoice? and e-invoicing penalties.