E-Invoicing

E-Invoice

Definition

An e-invoice in the strict sense is an invoice that is issued and received in a structured, machine-readable format and enables automatic electronic processing. In the German context, particularly following the Growth Opportunities Act, e-invoice explicitly refers to structured formats (XRechnung, ZUGFeRD/Factur-X, Peppol BIS), while pure PDF invoices no longer qualify. Hybrid formats such as ZUGFeRD count as e-invoices because they contain the XML structured data.

Background & context

Since the Growth Opportunities Act (2024), the term e-invoice has acquired a precise legal meaning. From 2025, the German VAT Act distinguishes three categories: the e-invoice in the narrow sense (structured, EN 16931-compliant, machine-processable — e.g. XRechnung or ZUGFeRD from the EN 16931 profile), the 'other invoice' (all other electronic formats such as plain PDF, JPG, or paper invoice) and special cases. The key point: from 2025, an invoice sent as a PDF by email is no longer an e-invoice in the legal sense, but an 'other invoice'. A true e-invoice must be issued, transmitted and received in a structured electronic format and enable automatic electronic processing. Hybrid formats such as ZUGFeRD count as e-invoices because the structured XML part is legally authoritative — the PDF part is merely a viewing component. For input VAT deduction and GoBD-compliant archiving, the structured data set must be retained in its original form.

In practice — a worked example

From 2025, a craft business issues an invoice to a business customer. If it only sends a PDF by email, it formally fails to meet the new B2B requirement — this is an 'other invoice'. If instead it produces a ZUGFeRD invoice (EN 16931 profile) or an XRechnung, a true e-invoice exists. Important for the recipient: from 1 January 2025, every domestic business must be able to receive such structured e-invoices and archive them in a GoBD-compliant way — regardless of whether it issues e-invoices itself yet.

Common mistakes

  • •From 2025 a PDF no longer counts as an e-invoice — the structured data must be present in machine-readable form.
  • •Receiving obligation often underestimated: from 2025 every business must be able to receive e-invoices, even though the issuing obligation only takes effect later.
  • •Archive the e-invoice in its original form (XML), not just a printout — otherwise the input VAT deduction may be lost under GoBD.

Frequently asked questions

Is a PDF invoice an e-invoice?

No. From 2025, a plain PDF counts legally as an 'other invoice', not an e-invoice. Only structured, EN 16931-compliant formats (XRechnung, ZUGFeRD from the EN 16931 profile) are true e-invoices.

From when must I issue e-invoices?

In B2B, the issuing obligation applies in stages by company size from 2027/2028; the receiving obligation already applies from 2025. In B2G, the obligation has existed since 2020 depending on the authority.

Does ZUGFeRD count as an e-invoice?

Yes, provided the EN 16931 (or higher) profile is used. The embedded structured XML part is authoritative and machine-processable; the PDF serves only for viewing.

Switch to German:E-Rechnung (Elektronische Rechnung) (DE)

Related terms

XRechnungXRechnung is the German standard for structured electronic invoices in public sector procurement (B2G). It is based on the European standard EN 16931 and is available in two syntaxes: UBL 2.1 and UN/CEFACT CII. Since 27 November 2020, federal public buyers have been required to accept electronic invoices in XRechnung format, and state and municipal authorities have been progressively included.ZUGFeRDZUGFeRD (Zentraler User Guide des Forums elektronische Rechnung Deutschland) is a hybrid invoice format that combines a human-readable PDF/A-3 file with embedded machine-readable XML data. The format is maintained by the Forum elektronische Rechnung Deutschland (FeRD) and exists in several profiles (MINIMUM, BASIC, EN 16931, EXTENDED). It is technically identical to the European Factur-X standard.Factur-XFactur-X is the Franco-German standard for hybrid electronic invoices, jointly developed by the French association FNFE-MPE and the German FeRD. Technically, Factur-X is identical to ZUGFeRD from version 2.0 onwards and uses UN/CEFACT CII as its XML syntax. The format is recognised across the European Union as a de facto standard for hybrid B2B invoices.Growth Opportunities ActThe Growth Opportunities Act (officially: Gesetz zur Stärkung von Wachstumschancen, Investitionen und Innovation sowie Steuervereinfachung und Steuerfairness) was passed in March 2024 and regulates, among other things, the phased introduction of mandatory electronic invoicing in the B2B sector in Germany. From 2025, all domestic B2B invoices must be issued in a structured format and businesses must be capable of receiving them; transitional exemptions apply on a staggered basis until 2028.B2B (Business-to-Business)B2B refers to business relationships and invoicing between two companies. In Germany, the Growth Opportunities Act (2024) introduced a mandatory electronic invoicing obligation for domestic B2B transactions as well. From 2025, businesses must be capable of receiving e-invoices; the obligation to issue them will be phased in until 2028. ZUGFeRD and XRechnung are both permitted formats for B2B.B2G (Business-to-Government)B2G refers to business relationships and invoicing from companies to government entities (federal, state, municipal, and public bodies). In Germany, electronic invoicing in the B2G sector has been progressively mandatory for federal authorities since 2020 and increasingly for state and municipal authorities. The required format is XRechnung or another EN 16931-compliant format.GoBD (Principles for the Proper Keeping and Storage of Books, Records and Documents in Electronic Form)The GoBD are administrative guidelines issued by the German Federal Ministry of Finance for audit-compliant archiving and retention of tax-relevant documents in electronic form. They set requirements for immutability, completeness, orderliness, traceability, and machine readability. Electronic invoices must be retained in compliance with GoBD requirements — i.e., in their original electronic format, not as printouts.
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