Electronic archiving with probative value: requirements and retention periods in France

Quick answer. Accounting records must be retained for 10 years (Article L123-22 Commercial Code), tax/VAT documents for 6 years, payroll records for 5 years by employer. Electronic archiving must comply with NF Z42-013 standards (EAS) and guarantee document integrity, authenticity and readability to have probative value in case of audit.

Since 2024, electronic invoicing is mandatory for all B2B transactions in France (except micro-entrepreneurs with exemptions). Simultaneously, digital tax audits are increasing. The tax authority now requires not only that documents be retained, but that they be retained reliably, traceable and defensible.

Storing invoices in PDF in a personal Cloud folder is not compliant electronic archiving. Proper archiving meets strict standards and demonstrates, in the event of dispute or tax audit, that the document has not been altered.

Retention periods vary by document type. No exemption exists for digital files: the legal duration applies regardless of whether the original is paper or digital.

Most documents must therefore remain accessible and readable for a minimum of 5 to 10 years. This is one reason why simple storage solutions (internal server, personal Cloud) are insufficient.

Robust electronic archiving relies on four pillars: integrity, authenticity, readability and traceability.

1. Integrity: the document must not be alterable without detectable trace. An archived invoice must not be modifiable retrospectively.

2. Authenticity: the document's signature or seal must verify who issued it and when. For an electronic invoice, this is typically a qualified electronic signature (eIDAS) or timestamp.

3. Readability: the archival format must remain readable within 10 years. PDF or signed XML can remain readable. A proprietary format risks becoming unreadable.

4. Traceability: every access, modification, or deletion must be logged. In an audit, you must prove when and by whom the document was accessed.

The French tax authority and auditors accept the following approaches as probative:

• Qualified electronic signature (eIDAS): the invoice bears the issuer's signature with document hash (fingerprint) recorded
• Timestamp: proof the document existed on a specific date
• Digital safe deposit box: third-party trusted service that seals and timestamps documents
• Reliable audit trail (PAF): for electronic invoices, the IT system guarantees continuous tracking (references, dates, flows, statuses)

Step 1: Select an Electronic Archiving System (EAS)#

An EAS (Electronic Archiving System) is software or a third-party service managing the lifecycle of digital documents. It must meet at minimum the AFNOR standard NF Z42-013:2011 (Electronic Archiving Systems).

Two options:

Option A: Internal EAS

• Software installed on your servers or hosted locally
• You are responsible for backup, security, compliance
• Suitable for large organizations or highly sensitive structures
• Requires rigorous IT maintenance

Option B: Third-party trusted service (outsourced solution)

• Certified provider manages archiving for you
• Simpler and more secure for SMEs
• Examples: HubDoc, Cegid, Indy (certified EAS for electronic invoices)
• You retain access and consultation rights

Step 2: Structure metadata#

Each archived document must include metadata: issuer, recipient, date, amount, accounting references, nature. This data makes the document retrievable and verifiable within 10 years.

Minimum metadata for an invoice:

• Invoice number
• Issue date
• Issuer (SIRET, legal name)
• Recipient
• Amount including tax
• Payment date
• Link to supporting document (purchase order, delivery note)

Step 3: Timestamp and sign critical documents#

Invoices must be electronically signed (advanced signature minimum) or timestamped by a recognized provider. Timestamping proves the document existed at a specific moment and has not been altered since.

For PAF (Reliable Audit Trail), the tax authority accepts system-side timestamping: the e-invoicing software automatically records each issue with its date and status.

Step 4: Define retention and destruction policies#

You must document:

• What document types are archived and for how long
• Where they are stored (local, Cloud, third-party service)
• Who accesses them and why
• How documents are destroyed after expiration (secure destruction)

This policy protects against regulatory risk and litigation (you prove you comply with legal obligations).

Certified EAS providers explicitly display their NF Z42-013 compliance. Ask for this when selecting a provider.

Micro-entrepreneurs: partial exemption, mandatory retention#

You are a micro-entrepreneur? You are exempt from issuing electronic invoices but you must still retain accounting documents for 10 years. These may remain paper or migrate to digital, provided digitization is compliant (reliable copy).

Digitized paper invoices#

If you issued a paper invoice and digitized it, the copy must be a "reliable copy" per Article L102-10 French Tax Code. It must:

• Exactly reproduce the original
• Be created through controlled optical reading or certified photocopying
• Bear a creation timestamp
• Enable integrity verification (hash/fingerprint)

A simple scan without integrity control is not a reliable copy.

Documents from third parties / subcontractors#

If a provider invoices and you store their invoice, you are responsible for compliant archiving. An outsourced provider may commit to archiving for you, but require written agreement and EAS certification.

Personal data and GDPR compliance#

Archiving must respect GDPR. You cannot retain personal data (names, addresses, customer numbers) indefinitely beyond legal duration. Example: an invoice can be archived 10 years, but the customer's address can be masked after 6 years if no longer needed for invoicing.

Mistake 1: confusing storage with archiving

Having invoices in Google Drive is not electronic archiving. You have no proof of non-alteration, no timestamp, no standards compliance. In a tax audit, you risk a 25% penalty on amounts in question.

Mistake 2: choosing a non-permanent format

Archiving in proprietary format (Excel files, Access, closed software) risks obsolescence. In 10 years the format may become unreadable. Prefer PDF/A (for finished documents) or XML (for structured data).

Mistake 3: failing to document retention policy

Lack of written policy is interpreted by authorities as intentional non-compliance. Document in writing: durations, locations, responsible parties, destruction methods.

Mistake 4: forgetting continuity when changing systems

When you change accounting software, old archives must remain accessible in original format. Ask your new provider how it handles import from the old system. Poor import = loss of traceability.

Mistake 5: archiving without redundancy

Single server, single backup = total risk on failure or disaster. Prefer a third-party service or request duplication from your provider.

Recently, an SME director contacted us after a tax audit covering two years of archives. The tax authority noted that invoices "lacked qualified electronic signature and no audit trail was documented." The case settled amicably but could have cost heavily in adjustments plus penalties.

This case reminded us that companies often confuse basic retention (storing a file) with probative retention (proving you stored an unalterable document). Probative archiving is a technical and legal investment, not a cost center to minimize.

We have long recommended to audit firms to strengthen requirements during accounting reviews. In 2026, authorities expect companies to have real documented policy. Those implementing it before audit save compliance costs.

Hayot Expertise advice. Ask yourself now: if audited tomorrow, could you provide tax authorities an invoice from 2016 proving it was unaltered? If not, your archiving is not probative. Invest in a certified EAS before audit, not after. An SME can implement an outsourced EAS solution for EUR 2,000-5,000 annually. This is far cheaper than a 25% penalty from adjustment.