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

*The content of this website is not binding and is subject to changes.

 

EDICOM Platform

Technically, your solution can be easily adapted to meet B2B regulations.

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.

Yes, EDICOM is a certified Trust Service Provider (eIDAS). The archiving module is GoBD-compliant.

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.

EDICOM validates incoming invoices, integrates the correct ones, and notifies customers about incorrect ones, so they can follow up with their suppliers.

EDICOM can adapt its solution to work independently, converting structured formats into readable PDFs.

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.

The EDICOM platform performs a syntactic check on all invoice types to ensure legal compliance and version accuracy.

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.

The EDICOM platform performs syntactic checks and data transfers, but specific approval processes are not managed within this platform.

No, as MS Word is not a structured format.

Our non-intrusive ERP integration approach allows our solution to connect effectively with all common ERPs.

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

In Germany, e-Invoicing formats include XRechnung, ZUGFeRD, or other EDI formats (e.g., EDIFACT, XML) based on the European Standard EN16931.

Correct. According to the BMF's current regulations, this will remain possible from January 2025 until January 2027.

EDIFACT formats should always be agreed between the creator and recipient of the invoice. From 2027, EDIFACT must be an EN 16931-compliant version.

Peppol is an accepted option for B2B e-Invoicing in Germany, but it is not the only possible transmission method.

You are only required to process XRechnung, ZUGFeRD, or other EDI formats based on EN16931 (the European standard).

An e-Invoice can be received in three main ways:

  1. Peppol Network
  2. E-Mail (as attachment)
  3. EDI or other Networks
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For B2B transactions, there are currently no regulations regarding a routing ID, as invoices are not yet sent to a BMF portal.

The ZUGFeRD version must comply with EN 16931.

Yes, if all suppliers send e-Invoices exclusively via Peppol.

XRechnung and the latest versions of ZUGFeRD that comply with the EN16931 Standard are the main formats for B2B transactions (as for B2G).

Yes, suppliers can decide on the format they would like to use.

The transmission methods for e-Invoices (XRechnung and ZUGFeRD) include: email, Peppol, or EDI.

Yes, the supplier can refuse to send invoices in PDF format.

Current regulations indicate that EDIFACT invoices will remain valid through 2028, provided they are EN 16931-compliant.

No, the ZRE portal is used for B2G; you do not need an account with government portals to receive B2B invoices.

The obligation only applies to domestic B2B transactions with invoice amounts over 250 EUR. e-Invoices can also be received by email.

Outgoing invoices can be sent via email, Peppol, or other value-added networks.

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.

Yes, Peppol, email, or SFTP are valid transmission methods. Typically, the issuer informs the receiver about the invoice format and transmission method.

No routing ID (Leitweg-ID) is currently required for B2B transactions.

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

That’s right, the upcoming mandate is for local transactions.

Yes, the obligation to receive electronic invoices applies to all companies, regardless of their annual turnover.

In principle, the mandate only requires companies to issue electronic invoices starting in 2027. Before that, issuing them is optional.

Yes, as your supplier may choose to send e-Invoices (following the EN16931 Standard), which they are permitted to do after January 1, 2025.

Yes, the XML data is the legally binding information and needs to be electronically archived according to GoBD regulations for 10+1 years.

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.

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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.

Outbound invoices (AR) are signed electronically to ensure authenticity, integrity, and confidentiality.

The issuer of invoices is not required to generate and send e-Invoices between January 1, 2025, and December 31, 2026.

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.

If there are discrepancies in content, the current invoice rejection process will remain applicable.

Outgoing e-Invoices should be electronically signed with a qualified signature to ensure their integrity, authenticity, and confidentiality.

There is no need to formally accept or reject the invoice.

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.

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.

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.

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.

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.

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.

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.

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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