Keeping invoices in the Netherlands: 7 years, and how a digital invoice stays provably genuine

In the Netherlands you keep invoices for 7 years, and invoices concerning immovable property for 10 years. A digital invoice is kept digitally, in the form in which you sent or received it. And for the whole period you must be able to show that the invoice is genuine and has not been changed.

Nobody doubts the first part. The last part asks the most. This article sets out the rules, and shows how to keep a digital invoice so that seven years from now it still proves what it has to prove.

How long do you keep invoices in the Netherlands?

The retention period for invoices in the Netherlands is 7 years. That is what the General State Taxes Act says (Algemene wet inzake rijksbelastingen, article 52, paragraph 4), and the Dutch Civil Code (article 2:10, paragraph 3) sets the same period for the accounts.

Invoices concerning immovable property are kept for 10 years. If you take part in the One Stop Shop (OSS) for sales to consumers in other EU countries, the supplies and services under that scheme are kept for 10 years as well.

In which form do you keep them?

The Dutch tax authority, the Belastingdienst, is clear about it: you keep invoices in the form in which you sent or received them. Digital invoices are not printed, they are stored digitally.

If you receive an e-invoice as a UBL or XML file, keep that file. A printout or a PDF rendering does not replace it. If you receive a PDF, keep that PDF.

May you scan paper invoices and throw them away?

Yes, under conditions. According to the Belastingdienst the scan must be a correct and complete representation of the original, and the features that show the invoice is genuine must be stored as well. If you meet those conditions, you do not need to keep the paper originals.

The digital records themselves are then kept just as long, 7 or 10 years, and must be verifiable within a reasonable time.

Genuine, unchanged and legible, for seven years

This is the core. The EU VAT Directive (2006/112/EC, article 233) requires three things of every invoice, on paper or digital, from the moment it is issued until the end of the retention period:

• Authenticity of origin: you can show who the invoice comes from.
• Integrity of content: you can show that nothing in it has changed.
• Legibility: seven years from now the invoice can still be opened and read.

How you ensure that is up to you. The directive gives a reliable audit trail between the invoice and the supply as an example. But a file in a folder proves nothing on its own. Anyone can open it, edit it and save it again, and it looks exactly the same.

How to make a digital invoice provable

Three building blocks turn a file into evidence:

1. An archival format. PDF/A-3 is the ISO standard for documents that must stay readable for decades. Fonts and everything else needed to display the invoice are inside the file. PDF/A-3 can also carry the XML of the e-invoice, so people and software read the same file.
2. A fingerprint. A cryptographic hash, such as SHA-384, is a unique fingerprint of the file. Change one byte and the fingerprint changes. Record every step in a hash chain, and the history of the document can be checked too.
3. A timestamp. An RFC 3161 timestamp from an independent timestamp authority binds that fingerprint to a point in time. It shows that the file existed in exactly this form at that moment.

Together they answer the question an auditor asks: is this the invoice that was sent back then, and has it stayed unchanged since?

How SealDoc does this for every invoice

With SealDoc, every invoice is evidence from the very first moment:

• PDF/A-3 with the e-invoice inside. Every invoice you create with SealDoc is a PDF/A-3 with the XML embedded, validated against the European standard EN 16931 before SealDoc seals it.
• A fingerprint and a hash chain. SealDoc computes the hash of the document and records every step in a hash chain.
• A timestamp. SealDoc requests an RFC 3161 timestamp for every invoice from an independent timestamp authority.
• An evidence pack. From the Starter plan you download a Legal Evidence Pack per document: a ZIP with the document, its evidence records and a manifest with the hash of every file, verifiable without SealDoc.
• European storage. SealDoc runs in a European data centre, on infrastructure we manage ourselves.

You download the invoice, the XML and the evidence pack for your own records. At an audit you then have everything in hand: the original, the proof that it is genuine and the proof that it is unchanged. Create your invoices with SealDoc.

Frequently asked questions

How long do I have to keep invoices in the Netherlands?

7 years. Invoices concerning immovable property are kept for 10 years.

May I print digital invoices and keep only the paper?

No. An invoice you received or sent digitally is kept digitally, in the form in which you received or sent it.

May I scan paper invoices and throw away the original?

Yes, if the scan is a correct and complete representation of the original and the features that show it is genuine are stored too. Then you do not need to keep the paper original.

Is an ordinary PDF good enough as an archive?

An ordinary PDF can depend on fonts or software that will not be around in years to come. PDF/A-3 is built to stay readable on its own, and can keep the e-invoice XML in the same file.

How do I prove that a digital invoice has not been changed?

With a fingerprint (hash) of the file, recorded at the moment of issue and anchored with an RFC 3161 timestamp. Any later change produces a different fingerprint. For the retention periods in other European countries, see legal document retention periods in the EU.