1. Archiving: key component or secondary topic?
In most projects, efforts are focused on:
- choosing the AP (Approved Provider) and the formats (Factur-X, UBL, CII, etc.);
- integrating the flows into the ERP or accounting software;
- meeting regulatory deadlines.
Archiving, on the other hand, often appears:
- at the end of the specifications, in the form of a simple line such as “10-year storage”;
- or is implicitly equated with a cloud backup, a DMS, or the storage offered by the AP.
Yet this marginal treatment overlooks a simple fact: an invoice that is perfectly issued, received and recorded but poorly archived is legally fragile. This is where the document’s evidential value, the ability to produce it during an audit, and the overall robustness of your compliance framework truly come into play.
2. The main mistakes and blind spots observed
2.1. Confusing storage, backup and evidential archiving
A fundamental mistake is assuming that a file stored somewhere (server, cloud, DMS, OneDrive, etc.) is automatically “archived”.
In reality, evidential archiving requires:
- integrity (impossibility of untracked modification)
- traceability (reliable audit trail, logs, access history)
- durability (readability over 6 to 10 years, controlled formats and media)
- control over retention and destruction periods
A simple backup or unmanaged storage does not meet these requirements.
2.2. Thinking that “the AP handles everything”
Many companies and accounting firms assume:
“Since invoices go through a AP, archiving is taken care of.”
This is false in most cases.
The primary role of the AP is to:
- transmit invoices (issuing/receiving)
- check minimal data compliance
- send information to the administration (e-reporting)
Archiving, when offered, is an additional contractual service with a scope and level of guarantee that must be carefully assessed. The legal responsibility for retention remains with the company.
2.3. Overlooking the original format and the evidence file
Another common blind spot is:
- keeping only the “readable” PDF version of the invoice, or
- conversely, keeping only the structured XML without ensuring consistency between the two
However, it is essential to:
- keep the original format used for issuance (XML/Factur-X, UBL, etc.)
- maintain consistency between the different representations (PDF, XML)
- associate an evidence file with the invoice: timestamp, signature/seal, ingestion logs in the archiving system, etc.
Without this evidence file, the invoice’s evidential value is significantly weakened.
2.4. Forgetting migrations and reversibility
Projects tend to focus on the initial rollout and rarely anticipate:
- switching to a new AP in 3 or 5 years
- ending a contract with a third-party archiver
- retrieving archives to integrate them into a new solution
Without clear contractual clauses (export formats, preservation of evidence, timelines, costs) and a proven migration process, there is a real risk of losing part of the chain of trust when changing providers.
2.5. Unclear governance and responsibilities
It is also common to observe:
- no clearly designated “owner” of archiving within the organization
- poorly defined or undefined roles between Finance, IT, business teams, accounting firms, software vendors
Result: in case of an issue, no one really knows who must provide what or for which scope.
3. APs, archiving solutions and trusted third parties: who does what?
3.1. The company: the ultimate responsible party
Regardless of the ecosystem of service providers, the company remains responsible for:
- retaining invoices for the legally required period
- ensuring their integrity and readability
- being able to produce them in the event of an audit or dispute
Outsourcing archiving does not transfer this responsibility; it only delegates some of the technical means.
3.2. The AP (Approved Provider)
Its main role covers:
- managing invoicing flows (issuing, receiving, transforming formats)
- performing basic compliance checks
- transmitting data to the tax authority
It may additionally offer:
- an archiving service (often with an EAS partner)
- historical consultation features
But its regulatory obligations primarily relate to flows, not to evidential preservation over 10 years. Archiving depends on the contract, not on the AP certification itself.
3.3. The archiving solution/platform (EAS)
The EAS, whether operated by the AP or by a dedicated third-party archiver, is responsible for:
- ensuring integrity (sealing, timestamping, access control)
- tracing all operations (ingestion, consultation, migration, destruction)
- guaranteeing durability (formats, media, continuity plan)
- administering retention periods and destruction processes
A certified EAS (NF 461, ISO 14641, future qualified electronic archiving service under eIDAS 2) provides a robust technical and organizational framework, but always within the limits of what is defined in the contract.
3.4. Trusted third parties (accountants, notaries, qualified archivers, etc.)
These actors can:
- advise on the choice of solutions
- offer safes or archiving services on behalf of clients
- operate part of the chain (signature, timestamping, retention)
They assume professional responsibility for their services, but:
- they do not replace the company’s fiscal responsibility
- they only cover what is explicitly included in their engagement letter or contract
4. Where do the real risks lie in the event of an audit or dispute?
4.1. Tax audit
The major risks are:
- Inability to produce invoices
Invoices that are missing, poorly organized or lost during a system change can lead to fines (per missing document) and even a rejection of the accounting records. - Loss of evidential value
If the tax authority shows that an invoice could have been modified, or that the evidence trail is insufficient (missing logs, unreliable timestamping, inconsistencies between PDF and XML), it may refuse the VAT deduction or challenge the taxable result. - Non-compliance with retention periods
Retention that is too short makes it impossible to produce documents for the audited period.
Unlimited retention without a legal basis can create GDPR issues.
4.2. Commercial or corporate disputes
In case of a dispute:
- with a customer or supplier (amount, conditions, performance)
- or during due diligence (sale, fundraising, acquisition audit)
the company must be able to quickly and reliably prove:
- the existence of the invoice
- its integrity
- the exact version that was authoritative at the time of the events
Poorly designed archiving can result in:
- a weakened legal position
- a loss of value during an M&A transaction
- additional costs (expert assessments, lengthy litigation, unfavorable settlements)
5. The five key challenges of electronic archiving in 2026
5.1. Position archiving as a strategic component of e‑invoicing
In 2026, archiving must no longer be treated as an “IT topic” or an optional add‑on. It must be:
- included in the RFE roadmap from the framing phase onward
- given the same level of priority as choosing the AP and integrating the ERP
- jointly overseen by business and IT teams (for example Finance and IT)
The objective is to build a complete evidence system that covers the entire invoice lifecycle, not only its issuance.
5.2. Clarify the allocation of roles and responsibilities
A key challenge is to:
- define in contracts what the AP does, what the EAS or third‑party archiver does and what the accounting firm does
- restate in internal policies that legal responsibility toward tax authorities and courts remains with the company
- formalize governance: who leads, who arbitrates, who validates technical and contractual choices
This clarification prevents blind spots and grey areas in the event of an incident.
5.3. Address the blind spots of companies and accounting firms
Successful projects are those that explicitly deal with the following:
- a clear distinction between storage, backup and evidential archiving
- retention of the original format and consistency between PDF and XML
- a documented Reliable Audit Trail
- anticipation of migrations (AP change, archiver change, entity merger)
- active management of retention and destruction periods (tax compliance and GDPR)
5.4. Take audit and litigation risks seriously
The challenge is very concrete. It is about reducing risks such as:
- tax reassessment risks (VAT, corporate tax, penalties) during a tax audit
- loss or weakening of evidence in a commercial dispute
- reservations or value reductions during financing or M&A operations
A well‑selected and well‑integrated AES is an asset for compliance and value creation, not just a cost.
5.5. Choose an appropriate technical architecture: SaaS or On‑Premise
The choice between SaaS and On‑Premise is a structural decision:
SaaS (hosted archiving solution):
- regulatory updates handled by the provider
- scalability, availability, lower upfront costs
- dependency on the vendor, challenges related to reversibility and data location
On‑Premise (internal archiving solution):
- full control of the infrastructure and maximum sovereignty
- close integration with the existing information system
- higher implementation and compliance maintenance costs (standards, security, continuity plans)
The right choice depends on:
- the size of the organization
- data sensitivity and sovereignty requirements
- internal capabilities (IT, security, compliance teams)
- the project time horizon (short‑term project vs multi‑year strategy)
Conclusion
In 2026, electronic archiving is no longer a “nice to have” but a central pillar of e‑invoicing compliance. The organizations that will successfully navigate this transition will be those that:
- integrate the archiving system (EAS) into the design of their e‑invoicing framework from the start
- clarify the roles of the AP, the archiver, trusted third parties and internal teams
- proactively address the technical, organizational and contractual blind spots
Put simply, the question is no longer “Do we need a robust electronic archiving system?” but “How much will a poorly designed archiving cost the company the day it is put to the test?”
Contact us now to secure your electronic archiving in full compliance.
