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Keep or delete website enquiries: deadlines at year end

Which website enquiry stays six years as a business letter and which must go: the 31 December cut-off, suspended periods, mailbox and CSV export at year end.

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The end of the year is time to tidy up: stock room, filing cabinet, desk. The website form inbox belongs on that list, because two obligations meet there. One requires business letters to be kept for six years. The other requires personal data not to be stored for longer than its purpose demands. For the turn of the year 2026/2027 this means: commercial and business letters received or sent in 2020 may usually be destroyed from 1 January 2027, unless the period has been suspended. And enquiries that did not turn into business usually have no place in the files any more. This article shows how to tell the two apart, where the copies of an enquiry actually sit, and what a year-end routine looks like that you can plan as a fixed date in December. It is not tax advice; it sorts the rules so that you can ask your tax adviser the right questions.

Enquiries at year end: file or deleteBusiness letters 6 years from year end, enquiries without an order deleted once their purpose is servedRetention period for business letters from 202031 Dec 2026: period ends6 years from the end of calendar year 202020202021202220232024202520262027Letter 2020Destruction usually from 1 Jan 2027 unless suspended (AO § 147(3))RequestsAllNewReadArchivedExport CSVReceivedSubjectStatusYear-end decision2026-12-03Question about opening hoursNewno order – deleted after 180 days2026-11-18Quote: replace gutterArchivedbecame an order – file for 6 years2026-10-02Callback about a site visitReadno order – deleted after 180 days2026-08-21Quote: seal flat roofArchivedbecame an order – file for 6 years2026-07-09Price question: roof windowReadno order – deleted after 180 daysSources: HGB § 257, AO § 147, XICflow documentation (requests and team)

The sentence that is not quite right

“Everything from 2020 can go” is too broad. What holds is this: commercial and business letters from 2020 may usually be destroyed from 1 January 2027, provided they are not relevant for a tax whose assessment period is still open. Invoices and other accounting vouchers have their own, longer period of eight years in any case and are not part of this review.

How the Regulation imagines this in practice is set out in its recitals: to ensure that personal data are not kept longer than necessary, the controller should establish time limits for erasure or for a periodic review (Recital 39 GDPR). A fixed review at year end is exactly such a periodic review. Recording it with date and outcome also provides evidence for the accountability duty in Article 5(2) GDPR, under which the controller must be able to demonstrate compliance with the principles. Under Article 30(1)(f) GDPR, the record of processing activities should contain, where possible, the envisaged time limits for erasure of the different categories of data. For website enquiries that means at least two lines: enquiries with an order and enquiries without one.

When an enquiry becomes a business letter

The Commercial Code requires every merchant to keep the commercial letters received and copies of those sent in an orderly manner (Section 257(1) HGB, items 2 and 3).

Subsection 2 defines the term narrowly: commercial letters are only documents that concern a commercial transaction. The word “only” is the most important limit for website enquiries. A message asking about opening hours, offering advertising or simply sent to the wrong address does not concern a commercial transaction of the business. An enquiry followed by a quote and an order, on the other hand, is part of that transaction’s correspondence. It is often the first letter in the file, because it states what the customer wanted.

The Commercial Code applies only to merchants. A merchant within the meaning of the Code is anyone who carries on a commercial business (Section 1(1) HGB). There is no commercial business if, by its nature or size, the enterprise does not require a commercially organised business operation (Section 1(2) HGB). Small trades of this kind therefore usually do not fall under Section 257 HGB, and neither do freelancers in the liberal professions who do not run a trade. A GmbH is different: it is deemed a commercial company (Section 13(3) GmbHG), and the provisions on merchants also apply to commercial companies (Section 6(1) HGB), regardless of size.

Falling outside the Commercial Code does not automatically mean being off the hook. Section 147 AO requires commercial or business letters received and sent to be kept for tax purposes, and according to the principles issued by the Federal Ministry of Finance, tax record-keeping duties arise not only from commercial law but also from individual tax acts such as Section 22 of the VAT Act or Section 4(3), sentence 5 of the Income Tax Act (GoBD, margin number 4). For everyday practice the tax authorities’ view of e-mails helps, because in most businesses a form enquiry arrives as an e-mail. The GoBD look at content and function rather than the label: e-mails that function as a commercial or business letter or as an accounting voucher must be kept in electronic form (GoBD, margin number 121). An e-mail that serves only as a “means of transport” and contains nothing else that has to be kept is not subject to retention. For a website enquiry, then, what counts is not the route by which it arrived but the role it plays in a transaction.

Scroll table sideways

How the enquiry developedUsual classificationPeriodAt year end
Question answered, no quote, no ordernot a business letter, purpose servedno retention dutydelete, including in the mailbox
Quote sent, no ordernot clearly regulatedagree a line with your tax adviserhandle according to that line
Enquiry leads to an orderpart of the transaction’s correspondencesix years from the end of the year of receiptfile in the order folder
Invoice for the orderaccounting vouchereight years from the end of the yearkept in accounting, not in the form inbox
Job application via the contact formseparate processown periods depending on the proceduremove into the recruiting process
Advertising, misdirected mail, spamnot a business letternonedelete straight away

The second row is the only one that calls for a decision. A quote that has been sent concerns a possible transaction; whether it counts as a business letter even without an order is not answered explicitly by the statutory text. Two lines are defensible: keeping such quotes as a precaution, or deleting them after a fixed grace period. What matters is that the business picks one line, applies it consistently and records it in its deletion policy. According to the GoBD, you certainly do not need to keep mere drafts of commercial or business letters that were not actually sent (GoBD, margin number 5). The half-finished quote in the drafts folder therefore does not belong in the six-year archive.

Three questions for your tax adviser

Are we a merchant within the meaning of the Commercial Code? Do quotes without an order count as business letters for us? Are there still taxes for 2020 whose assessment period has not expired? With these three answers, the deletion policy for website enquiries can be written as one line per case, and it then applies to every following year.

What XICflow deletes on its own and what it does not

If your website runs on XICflow, incoming requests appear in the “Requests” area with the statuses “New”, “Read” and “Archived”.

Retention there is deliberately short: by default, requests are kept for 180 days and are then deleted automatically and for good, the archived ones as well (XICflow documentation). The list shows the 500 most recent submissions; older ones are available through the CSV export, which covers up to 5,000 entries, starts with the most recent and includes archived entries (XICflow documentation). In the file, the status appears as “new”, “read” or “archived”, and the date as year-month-day with the time. How requests reach the dashboard and are managed per website is described in the documentation on requests and team.

This default is the data protection side of the equation. Article 25(2) GDPR requires default settings that process only what is necessary and explicitly includes the period of storage. On the retention side, it creates a task that is easily overlooked: 180 days are far shorter than the commercial and tax retention period for business letters. An enquiry from May is no longer in the list at the end of November, even if it turned into an order. Anyone who collects the year’s orders only in December will no longer find any enquiry there that arrived before June. The archive copy is therefore ideally made when the order comes in, and at the latest once a quarter by export. According to the documentation, anything you want to keep longer should be saved in good time using the CSV export (XICflow documentation).

The automatic deletion affects only the list in XICflow. As soon as notifications are switched on, a second collection builds up in the mailbox: so that you do not have to check regularly, XICflow forwards every new request by e-mail (XICflow documentation). The notification contains name, e-mail, phone, message and all custom fields. If no separate notification address is set, it goes to the e-mail address in the website’s company details. These e-mails remain until someone deletes them. The same applies to replies in the sent folder and to copies passed on to industry software via webhook; how that works securely is explained in the article Forwarding enquiries automatically to your industry software. The year-end routine therefore starts where the copies are, not just where the original arrived.

List in XICflow

Statuses New, Read and Archived. Deleted automatically 180 days after arrival by default, archived entries included.

Notification e-mail

One e-mail per request with all fields. It stays in the mailbox until deleted, including in distribution lists and colleagues’ inboxes.

Sent folder

Replies often quote the enquiry in full. For orders they are copies of business letters sent; otherwise they are copies without a purpose.

CSV files

Every export contains all stored requests, not only those with an order. Old exports on the desktop undermine the deletion.

Forwarded copies

Requests transferred via webhook sit in the receiving software and follow its deletion rules, not those of the website.

Account export

“Export my data” contains the requests of all websites in the account. Whoever downloads it is managing one more copy.

The year-end routine in seven steps

  1. Reconcile the year’s orders. Check that every enquiry that turned into an order in 2026 is in the order file. Retrieve anything missing from the mailbox or, as long as the 180 days are not over, from a current CSV export.
  2. Export and narrow down. Download the CSV export, transfer the rows for orders into your files and then delete the export. A complete export that sits on a computer for years is a collection without a purpose.
  3. Decide on the original. Determine which version counts as the business letter and put it in an archive folder that is not emptied automatically.
  4. Clean up the mailbox. Delete notifications and replies for enquiries without an order whose purpose has been served, including the sent folder, the deleted items and copies in distribution lists.
  5. Review the 2020 batch. Check with your tax adviser whether assessment periods for 2020 are still open. If not, the business letters of that year are usually destroyed from 1 January 2027.
  6. Include forwarded copies. Check industry software, account exports and working folders for enquiries without an order.
  7. Record the result. Note the date, scope and responsible person, and update the deletion periods in the record of processing activities if anything has changed.

The order matters: first secure what has to stay, then delete what may go. Doing it the other way round can, in the worst case, lose exactly the enquiry that belongs to an order. The second half of December, when the year is almost over, is a good date, and one named person is responsible. One detail from the permission settings belongs here: in XICflow every team member may view and export requests, including the “Viewer” role; changing the status or deleting is reserved for “Editor” and above (XICflow documentation). That is practical for daily work, but it means exports can be created in several places. Decide where exports are stored and include that location in the routine. For the annual plan, a template like the one below is enough; agree it once with your tax adviser and reuse it every year.

Deletion plan for website enquiries (template)
Category                Period                             Location              Owner
Enquiry without order   purpose served: delete             mailbox, XICflow      [name]
Quote without order     [line agreed with tax adviser]     mailbox, quotes       [name]
Enquiry with order      6 years from end of year received  order file            [name]
Invoice for the order   8 years from end of voucher year   accounting            [name]
CSV exports             delete after transfer              [storage location]    [name]

Review date:            annually, second half of December
Export of orders:       when the order comes in, at the latest quarterly
Evidence:               date, scope, person

The archive copy in the right format

Once an enquiry becomes a business letter, the rules on orderly record keeping apply to how it is kept.

Electronic storage is permitted if the reproduction matches the letter received visually and remains available at any time during the period, can be made readable without delay and can be evaluated by machine (Section 147(2) AO). The GoBD are more explicit: records subject to retention that arrived electronically must also be kept in that form and must not be deleted before the retention period expires (GoBD, margin number 119). A printout alone is then not enough, and neither is a conversion in which information is lost.

For website enquiries this suggests a practical division of labour. If the case is handled via the notification e-mail, that e-mail is the document the business actually worked with; it is therefore a natural candidate for the original and stays in its original format in the archive folder of the order file. The row from the CSV export serves as a searchable index: date, status, name and message in a table that can be sorted by year. When a batch becomes free can then be read from a single column. Decide once which version counts as the original in your business and record it in your process documentation. Backing up the archive folder belongs in the same plan as backing up the website, described in the article Website backup and restore: a plan for when things go wrong.

Erasure requests and access during the year

Not everything waits until December. If someone asks for their enquiry to be deleted, first check whether a retention duty applies.

Without an order that is usually not the case; in XICflow “Delete” on the entry is then enough, and the record is removed completely (XICflow documentation). Delete the notification e-mail and the replies in the mailbox at the same time, or the copy that lives longest will remain. If the enquiry led to an order, the business letter stays until the period ends; tell the person why and until when. How to answer a request for access to stored data completely and on time is covered in the article Responding to a GDPR subject access request. Job applications that come in through the same form move into the recruiting process and follow its own periods, explained in the article Online job applications: fields, deadlines, deletion. Seasonal group enquiries, such as for Christmas parties at a restaurant, on the other hand, often turn into orders within a short time. The same question applies to them as to any other enquiry: did it turn into business?

What counts on 1 January

Six years from the end of the year for enquiries that became orders. Delete as soon as the purpose is served for all others. And an archive copy made before the 180 days are up. With these three rules, the form inbox becomes a filing system that fits both obligations.
This article is based on data from: the German Commercial Code (Sections 1, 6 and 257), the Fiscal Code (Sections 147, 169 and 170) and the Limited Liability Companies Act (Section 13) in the version published on gesetze-im-internet.de, retrieved in October 2026; Regulation (EU) 2016/679 (General Data Protection Regulation, Articles 5, 17, 25 and 30 and Recital 39); Federal Ministry of Finance, principles for the proper keeping and retention of books, records and documents in electronic form and for data access (GoBD as amended on 14 July 2025, margin numbers 4, 5, 119 and 121, official AO handbook 2026); XICflow documentation (requests and team), as of October 2026.