Frequently asked questions
Is a PDF invoice already an e-invoice?
No, since 2025 a plain PDF or scanned paper invoice no longer counts as an e-invoice, because its contents cannot be processed in a structured, machine-readable way. A genuine e-invoice must use a structured format compliant with the European standard EN 16931 – in Germany that means XRechnung as pure XML or ZUGFeRD as a hybrid PDF with embedded XML. A mere image of a document is explicitly classified by the law as an 'other invoice' rather than an e-invoice. What matters is therefore not visual readability but the structured data layer that an ERP or accounting system can read without a media break.
What transition periods apply to the e-invoicing mandate in Germany?
Since 1 January 2025, all domestic B2B recipients must be able to receive e-invoices; this receiving obligation applies immediately and without any transition period. The obligation to issue e-invoices is phased in: until the end of 2026, paper invoices may still be sent, and PDF invoices with the recipient's consent, and from 1 January 2027 companies with prior-year turnover above 800,000 euros must send e-invoices. For smaller companies with prior-year turnover of no more than 800,000 euros, the grace period extends until the end of 2027. From 1 January 2028, all domestic B2B invoices must be issued as structured e-invoices unless a permanent exemption applies (for example small-amount invoices up to 250 euros or small businesses), and EDI procedures remain permitted if all mandatory invoice details can be extracted.
What is the difference between XRechnung and ZUGFeRD?
Both formats comply with the European standard EN 16931 but differ technically. XRechnung is a pure XML file with no visual representation and, as the national specification (CIUS), is the mandatory standard for invoices to public-sector clients in the B2G segment, where among other things it requires the Leitweg-ID as a mandatory field. ZUGFeRD, by contrast, is a hybrid format in which a human-readable PDF/A-3 embeds structured XML, so the same file can be both displayed and processed automatically. In B2B, ZUGFeRD is often regarded as a pragmatic entry point because recipients see the PDF view directly; it is permitted from version 2.0.1 in all profiles except MINIMUM and BASIC-WL, and from the EN 16931 profile upwards both formats cover the full data model of the standard.
Do small businesses (Kleinunternehmer) have to issue and receive e-invoices?
Small businesses under Section 19 UStG are exempt from the active obligation to issue e-invoices (regulated in Section 34a UStDV), but like all other companies they have had to be able to receive e-invoices since 1 January 2025. This receiving obligation applies indefinitely and without any transition arrangement as soon as a supplier transmits a structured B2B invoice. Also exempt from the e-invoicing mandate are small-value invoices up to 250 euros gross and invoices to private individuals in the B2C segment. In practice, even a small company should therefore set up a solution early on for opening and archiving incoming XRechnung or ZUGFeRD files.
How is an e-invoice archived?
E-invoices must be retained in their structured original format (XML or PDF/A-3 with embedded XML) in an audit-proof, immutable and machine-readable manner. The retention period for invoices was shortened from ten to eight years by the Fourth Bureaucracy Relief Act with effect from 1 January 2025, although ten years may still apply to older periods still running on 31 December 2024 and to certain records. The legal basis is Section 14b UStG and the GoBD, which require a traceable procedure and preservation of the original file; a subsequently generated PDF view is not sufficient, since the structured data itself forms part of the record. In ERP systems, the practical implementation usually runs through an integrated or connected document management system (DMS) and should be agreed with the respective vendor.
How is an e-invoice transmitted?
The law does not prescribe a fixed transmission channel as long as the invoice is in a permitted structured format; in practice, email, supplier portals and the Peppol network are common. Invoices to German federal authorities require central addressing via the Leitweg-ID, which is included in the XRechnung as a mandatory field. According to the federal administration, Peppol is the only transmission channel that supports fully automated machine-to-machine communication and bulk dispatch, and it is therefore preferred for higher volumes. However, since the recipient is not obliged to process every channel, the transmission route should be agreed in advance between the business partners or with the public-sector client.