Electronic Invoicing in Germany: Challenges, Solutions, and Opportunities
This webinar, in collaboration with Deloitte Germany, is designed to equip you with the knowledge and tools needed to navigate Germany's electronic invoicing landscape effectively.
Electronic Invoicing in Germany: Challenges, Solutions, and Opportunities
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During this session, our speakers cover key aspects of electronic invoicing, including regulatory requirements, implementation strategies, and the benefits of digital transformation.
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Frequently asked questions
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EDICOM Platform
If we are already using EDICOM for electronic invoicing with the federal government, are we also set up for B2B transactions?
Technically, your solution can be easily adapted to meet B2B regulations.
There are companies that receive around 50 incoming invoices a year. These companies post invoices manually into the system. We do not use a tool to process incoming invoices, as the costs are far higher than the manual effort involved. The question now is whether we need a tool or if we can continue working without one.
To receive e-Invoices—whether via email or other networks—a solution that converts e-Invoices into a human-readable format is necessary. This solution can be semi-manual. Additionally, it is necessary to archive the machine-readable XML format in a GoBD-compliant manner for 11 years. Please contact EDICOM for further advice.
Does EDICOM archive invoices for the company?
Yes, EDICOM is a certified Trust Service Provider (eIDAS). The archiving module is GoBD-compliant.
Currently, we process incoming invoices in a DMS; invoice data is then entered and posted manually in the ERP. Can this workflow continue in the future?
Yes, there is no specific regulation against manual workflows. However, you need a solution that can receive, archive, and display e-Invoices in a readable format. EDICOM offers this solution.
When receiving an e-Invoice, does EDICOM apply any validations?
EDICOM validates incoming invoices, integrates the correct ones, and notifies customers about incorrect ones, so they can follow up with their suppliers.
Can you suggest any ERP-independent applications that can convert XML e-Invoices into a readable format?
EDICOM can adapt its solution to work independently, converting structured formats into readable PDFs.
How will clients know if an e-Invoice has been successfully sent?
EDICOM’s SaaS platform validates all incoming and outgoing invoices. Custom alerts can also be set up to notify customers about specific interactions, such as when an invoice is issued correctly.
Why is an invoice checked again at the point of receipt in EDICOM after being received via the Peppol network?
The EDICOM platform performs a syntactic check on all invoice types to ensure legal compliance and version accuracy.
Is the EDICOM solution certified by German authorities or Deloitte?
EDICOM holds all necessary certifications to ensure secure data transactions, authenticity, integrity, and confidentiality. In Germany, EDICOM is certified to connect with public administration portals for B2G transactions. Currently, no specific certification is required for B2B transactions.
Can the EDICOM platform manage approval processes like SAP Concur?
The EDICOM platform performs syntactic checks and data transfers, but specific approval processes are not managed within this platform.
For AR invoices, you mentioned CSV as a valid input format. Is there any possibility of using MS Word documents in the EDICOM solution?
No, as MS Word is not a structured format.
Are there ERP systems that are particularly successful in integrating with EDICOM?
Our non-intrusive ERP integration approach allows our solution to connect effectively with all common ERPs.
Is it possible to use the EDICOM platform for receiving and archiving invoices without connecting to an ERP?
Yes, it is possible to adapt our solution for semi-automated operation, receiving and converting electronic invoices to readable PDF formats, and archiving the original invoice.
Formats and communication
What formats are considered e-Invoicing?
In Germany, e-Invoicing formats include XRechnung, ZUGFeRD, or other EDI formats (e.g., EDIFACT, XML) based on the European Standard EN16931.
If a company's system cannot process the XML directly, can a PDF created from the XML still be posted manually?
Correct. According to the BMF's current regulations, this will remain possible from January 2025 until January 2027.
Does EDIFACT fall under EN 16931, and if so, am I required to receive it as a supplier, even if it has not been bilaterally agreed upon with the sender?
EDIFACT formats should always be agreed between the creator and recipient of the invoice. From 2027, EDIFACT must be an EN 16931-compliant version.
Will B2B e-Invoicing be implemented using Peppol?
Peppol is an accepted option for B2B e-Invoicing in Germany, but it is not the only possible transmission method.
Must German companies be able to process non-German e-Invoice formats as of January 2025?
You are only required to process XRechnung, ZUGFeRD, or other EDI formats based on EN16931 (the European standard).
What are the options besides Peppol for B2B e-Invoicing?
An e-Invoice can be received in three main ways:
- Peppol Network
- E-Mail (as attachment)
- EDI or other Networks
Is there an equivalent to the routing ID for using XRechnung in the B2B context? Or how is the unique identifier of the invoice issuer and recipient regulated for B2B XRechnung invoices?
For B2B transactions, there are currently no regulations regarding a routing ID, as invoices are not yet sent to a BMF portal.
ZUGFeRD is PDF + embedded XML. Does the XML have to conform to EN 16931, or is it limited to XRechnung/UBL 2.1?
The ZUGFeRD version must comply with EN 16931.
If a German company is registered on the Peppol network to receive XRechnung, is it compliant with the law for 2025?
Yes, if all suppliers send e-Invoices exclusively via Peppol.
Could you confirm that Peppol BIS Billing 3.0 must be used for B2B processes?
XRechnung and the latest versions of ZUGFeRD that comply with the EN16931 Standard are the main formats for B2B transactions (as for B2G).
Can a supplier determine the type of document they send? For example, can they send XRechnung even if we would prefer to receive ZUGFeRD?
Yes, suppliers can decide on the format they would like to use.
My company is not connected to Peppol, and I must accept any incoming EN 16931 invoice by January 2025. How will the supplier (without my consent) reach me with their EN 16931 invoice?
The transmission methods for e-Invoices (XRechnung and ZUGFeRD) include: email, Peppol, or EDI.
If we receive an EN 16931-compliant invoice after January 2025, can we contact the supplier to request a format change to PDF until January 2027? Can the supplier refuse to provide the PDF?
Yes, the supplier can refuse to send invoices in PDF format.
We are currently sending EDIFACT invoices to our customers. Will this format still be valid from 2028?
Current regulations indicate that EDIFACT invoices will remain valid through 2028, provided they are EN 16931-compliant.
Do I need an account with 'ZRE' to receive passive invoices via Peppol?
No, the ZRE portal is used for B2G; you do not need an account with government portals to receive B2B invoices.
B2B and B2G invoices can typically be routed via Peppol. What about transport tickets and similar items? Are these sent via email? If so, does this mean we are legally required to be able to receive e-Invoices by email?
The obligation only applies to domestic B2B transactions with invoice amounts over 250 EUR. e-Invoices can also be received by email.
Are there any specific requirements regarding the distribution of e-Invoices, or are they still accepted via any “protocol”?
Outgoing invoices can be sent via email, Peppol, or other value-added networks.
If we are already sending PDF invoices, do we need new consent from the recipient to send them during 2025-2026? Can the recipient withdraw their consent during that time? Are paper invoices allowed without additional consent? Do I understand correctly that EDI, as currently used, will meet all legal requirements in 2025 and 2026, or are there new legal requirements for EDI?
PDF invoices can be sent without additional consent until December 2026. Starting in 2027, recipients can reject PDF invoices if no consent is in place. EDI (EDIFACT following EN 16931 standards) remains compliant in the coming years. EDI (EDIFACT following EN16931 standard) can be used during the next years.
Regarding the transport protocol, invoices can be sent through Peppol, email, or SFTP, correct? Does the receiver communicate the preferred transport channel to the issuer for invoice delivery?
Yes, Peppol, email, or SFTP are valid transmission methods. Typically, the issuer informs the receiver about the invoice format and transmission method.
Is a routing ID (Leitweg-ID) required for the transmission path? If so, where should this be applied for?
No routing ID (Leitweg-ID) is currently required for B2B transactions.
Is it possible to stipulate in purchasing terms and conditions that only XRechnung and PDF formats are accepted, for example?
PDF: Until the end of the calendar year 2026, an invoice for sales made up to that point can be issued and sent as a regular invoice (e.g., PDF).
If the total sales of the invoicing party in the previous calendar year did not exceed EUR 800,000, an invoice for sales made up to that point can also be issued and sent as a regular invoice (e.g., PDF) until the end of the calendar year 2027.
The recipient’s consent to receiving an invoice in an electronic format that deviates from EN 16931 does not require any specific form. Consent may be given, for example, via a framework agreement (terms and conditions) or implicitly.
The invoicing party may use these transitional provisions but is not obligated to do so.
XRechnung: The XRechnung standard is recognized as the national implementation of the EN 16931 standard. The format requirements for e-invoicing are met by issuing an XRechnung.
To what extent terms and conditions can define the format used is a question of civil law.PDF: Until the end of the calendar year 2026, an invoice for sales made up to that point can be issued and sent as a regular invoice (e.g., PDF).
If the total sales of the invoicing party in the previous calendar year did not exceed EUR 800,000, an invoice for sales made up to that point can also be issued and sent as a regular invoice (e.g., PDF) until the end of the calendar year 2027.
The recipient’s consent to receiving an invoice in an electronic format that deviates from EN 16931 does not require any specific form. Consent may be given, for example, via a framework agreement (terms and conditions) or implicitly.
The invoicing party may use these transitional provisions but is not obligated to do so.
XRechnung: The XRechnung standard is recognized as the national implementation of the EN 16931 standard. The format requirements for e-invoicing are met by issuing an XRechnung.
To what extent terms and conditions can define the format used is a question of civil law.
Legal considerations
A non-resident is not required to send e-invoices. Are they also not required to receive e-invoices?
That’s right, the upcoming mandate is for local transactions.
Does a sole trader or freelancer with less than €800,000 in sales also need to be able to receive e-invoices?
Yes, the obligation to receive electronic invoices applies to all companies, regardless of their annual turnover.
If a customer requests an e-Invoice after January 2025, are we as the supplier required to issue one?
In principle, the mandate only requires companies to issue electronic invoices starting in 2027. Before that, issuing them is optional.
Do companies need to prepare their systems even if they are still allowed to use paper invoices?
Yes, as your supplier may choose to send e-Invoices (following the EN16931 Standard), which they are permitted to do after January 1, 2025.
Is the electronically received data the legally binding document that must be saved for 10 years by a company?
Yes, the XML data is the legally binding information and needs to be electronically archived according to GoBD regulations for 10+1 years.
Can our customers require companies to receive invoices in electronic format, or can we wait until 2026?
According to the regulations, starting January 1, 2025, you should be able to receive e-Invoices that follow the EN16931 Standard. Suppliers may decide to send electronic invoices without needing agreement from the receiver.
If, for example, PDF invoices are to continue being sent to German B2B service recipients from January 2025, must we obtain the recipient's consent by then to confirm they will continue accepting these?
No, from January 1, 2025, until January 1, 2027, PDF invoices are considered compliant formats, along with XRechnung and ZUGFeRD, so recipients must accept PDFs.
Although the Act states that it is mandatory to guarantee authenticity of origin, it does not specifically mention a qualified electronic signature or seal. Could you clarify if signing e-Invoices will be mandatory, as it is in some EU countries?
Outbound invoices (AR) are signed electronically to ensure authenticity, integrity, and confidentiality.
If a service recipient (client) wishes to receive an e-Invoice before January 1, 2027, the service provider must supply it in e-Invoice format (XML). This interpretation seems inconsistent with legal commentaries, so could you please confirm? This would imply that the transition phase is conditional upon the recipient’s request.
The issuer of invoices is not required to generate and send e-Invoices between January 1, 2025, and December 31, 2026.
From January 1, 2025, this obligation applies only if we already have or plan to have automated communication with suppliers via EDI or an equivalent, and if the supplier plans to change the message format. If the supplier is not required to change, it is unlikely we will need to take any action from January 1, correct?
The supplier is not required to use e-Invoices starting in 2025. However, if they choose to do so, the recipient must be prepared to process them.
Can invoices or credit notes be rejected if they do not meet your business rules (e.g., incorrect or invalid order number)?
If there are discrepancies in content, the current invoice rejection process will remain applicable.
Does an X-Invoice (XRechnung) also need to be electronically signed with a qualified signature?
Outgoing e-Invoices should be electronically signed with a qualified signature to ensure their integrity, authenticity, and confidentiality.
When we receive an e-Invoice from a supplier, do we need to formally accept or reject it? If so, within what timeframe should this be done?
There is no need to formally accept or reject the invoice.
Does the e-Invoicing mandate apply to foreign entities that are only VAT-registered in Germany (e.g., a UK-registered company with no permanent establishment, employees, or office in Germany, just VAT registration for collecting German VAT)?
No. A mere VAT registration without a fixed establishment in Germany involved in domestic B2B supply of goods or services does not trigger the German e-Invoicing rules.
What about companies in other EU countries that credit the revenue from intra-community supplies to the local entity in Germany?
Generally, the new e-Invoicing rules apply only to domestic B2B supplies of goods or services. The nature of the transaction, the establishment of the parties, and the existence of any fixed establishment in Germany involved in the supply must be assessed.
What about credit/debit and self-billing procedures?
The rules on the mandatory use of e-invoices also apply to invoice issuance through credit notes (§ 14 para. 2 sentence 5 of the German VAT Act). In the area of invoicing, it may be necessary to display different forms of credit notes or invoice corrections. Electronic invoicing facilitates the interpretation of the invoicing data through the evaluation of the invoice type in field BT-3.
Invoice corrections that are subject to an obligation to issue a document are also covered by the e-invoicing requirement. Furthermore, civil law or practical considerations may necessitate that invoice corrections are carried out electronically as well.
Travel expenses are listed separately from XRechnung and ZUGFeRD: does this mean that restaurants and hotels do not have to issue e-invoices for amounts over 250 euros?
Invoices with a total amount not exceeding 250 euros (small amount invoices) can always be issued as regular invoices (e.g., paper, PDF). The decisive factor is the total invoice amount. If the total amount of the invoice exceeds 250 euros, an e-invoice must be issued under the further conditions of the e-invoicing requirement, unless it concerns tickets.
How does the e-Invoice obligation apply to foreign companies registered for VAT purposes as non-residents? Is there a date set for when they will also have to issue or receive e-Invoices?
It must be assessed whether the supplier is established in Germany or has a fixed establishment in Germany involved in the supply, as the new mandatory e-Invoicing rules for B2B supplies apply to suppliers and recipients established in Germany.
Does it apply to credit notes?
The rules on the mandatory use of e-invoices also apply to invoicing through credit notes (§ 14 para. 2 sentence 5 of the German VAT Act). In the area of invoicing, it may be necessary to display different forms of credit notes or invoice corrections. Electronic invoicing facilitates the interpretation of the invoicing data by evaluating the invoice type in field BT-3.
Invoice corrections that are subject to an obligation to issue a document are also covered by the e-invoicing requirement. Furthermore, civil law or practical considerations may necessitate that invoice corrections are carried out electronically as well.
What is the penalty or sanction applied as of January 1, 2025, if a company is unable to receive e-Invoices from its vendors?
There is a risk of input tax denial, as the taxable person claiming input tax deduction must possess a proper VAT invoice. However, even if a non-EN 16931-compliant invoice is not corrected, the German tax authorities will allow input tax deduction if the necessary information is provided to assess the substantive input tax requirements. Input tax deduction is also allowed for recipients who rely in good faith on the invoice issuer's use of transitional rules, provided all other general input tax deduction requirements are met.
What is the regulation? Are suppliers required to send a PDF invoice in addition to the e-Invoice during the transition period starting January 1, 2025?
In cases of e-Invoicing, the creation of an additional human-readable document is not necessary. The additional transmission of a human-readable document is optional.
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