E-Invoice

An e-invoice is not simply a PDF file — it is a structured, machine-readable invoice transmitted electronically. Under the new mandate, plain PDFs are explicitly not considered e-invoices, as the data they contain cannot be processed automatically.

E-invoices contain invoice data in a standardised XML format (e.g. XRechnung or ZUGFeRD) that can be read and processed directly by ERP systems, accounting software, and tax authorities.

The European standard EN 16931 defines the semantic data model on which all permissible formats must be based, ensuring that an e-invoice can be processed in every EU member state.

The e-invoicing obligation in Germany was introduced by the Wachstumschancengesetz (Federal Law Gazette 2024 I No. 108), which entered into force on 27 March 2024. It fundamentally amends § 14 UStG (German VAT Act): from the legally defined cut-off dates, the structured e-invoice becomes the standard format for transactions between domestic businesses.

At European level, the ViDA (VAT in the Digital Age) initiative is advancing a uniform digital VAT reporting system that will also affect cross-border B2B invoices in the medium term.

The obligation applies to all VAT-registered businesses (§ 2 UStG) supplying services to other businesses established in Germany (B2B). Both parties must have their registered office, place of management, or a VAT-relevant permanent establishment in Germany.

Not affected:

• Invoices to consumers (B2C)
• Low-value invoices up to €250 gross (§ 33 UStDV)
• Travel tickets / transport documents
• Transactions exempt under § 4 No. 8–29 UStG
• Small businesses under § 19 UStG are exempt from the sending obligation, but must still be able to receive

The reception obligation has applied since 1 January 2025 to all affected businesses. The legislator has deliberately kept the technical requirements low: there is no obligation to use a specific portal, software, or EDI system.

E-invoices in ZUGFeRD format are sent as an ordinary PDF file with embedded XML via email. The recipient simply needs to:

• Provide an email address to which invoices can be sent
• Be able to open the email attachment and save it in a readable format
• Archive the invoice for 10 years as required by tax law (unaltered, readable)

For the pure reception obligation, no investment in new software is required. However, businesses that wish to automatically process, verify, or transfer incoming invoices into their accounting system will benefit from a suitable solution such as Facturado.

For sending e-invoices, suitable software is required that can generate invoice data in a compliant format (XRechnung, ZUGFeRD, or Peppol BIS). A manually created XML file or a regular PDF is not sufficient.

The software must ensure that:

• All mandatory fields under § 14(4) UStG are correctly embedded
• The generated file meets the requirements of the EN 16931 standard
• The chosen format can be processed by the recipient (ZUGFeRD is the most widely used)

Depending on company size and turnover, the sending obligation applies from 1 January 2027 or at the latest from 1 January 2028. Early adoption is recommended to allow sufficient time for testing processes.

All three formats are based on the European standard EN 16931 and are legally equivalent in Germany. For most businesses, ZUGFeRD is the easiest starting point.

Facturado supports you on both sides of the e-invoicing obligation — from simple reception through to fully automated creation and dispatch of compliant e-invoices.