E-Invoice
An e-invoice is not an invoice that happens to be sent electronically — it is an invoice a machine can read. From 2027 onwards, that distinction decides whether an invoice meets German legal requirements at all.
What German VAT law accepts as an e-invoice
An e-invoice is issued, transmitted and received in a structured electronic format that allows automatic processing. What matters is the format, not the delivery channel.
This is where most misunderstandings start: a PDF sent by email is explicitly not an e-invoice under German VAT law. A scanned paper document does not qualify either. Neither contains a machine-readable data model — only a representation.
Only structured formats compliant with the European standard EN 16931 are permitted. In Germany that effectively means XRechnung and the EN 16931 profiles of ZUGFeRD.
The deadlines, and who they apply to
The transition runs in two separate waves that are frequently confused.
Receiving has been mandatory for all domestic German B2B companies since 1 January 2025 — no revenue threshold, no transition period. Since then a supplier may send an XRechnung without asking first.
Issuing becomes mandatory on 1 January 2027 for companies with prior-year revenue above 800,000 euros, and on 1 January 2028 for all remaining domestic B2B companies.
A company that still cannot receive an e-invoice today is not ahead of schedule — it is already past a deadline.
Why the format is the smaller half of the project
XRechnung and ZUGFeRD are both EN 16931 compliant and available in any serious ERP system. Choosing between them is rarely the hard part.
The real effort sits elsewhere: master data quality, the transmission route, validation before sending, and audit-proof archiving of the XML. A technically valid file with the wrong tax category or an incomplete recipient identifier gets rejected — automatically, with nobody calling to explain why.
Frequently asked
Is a PDF sent by email an e-invoice?
No. Under German VAT law a PDF sent by email is explicitly not an e-invoice, because it contains no structured, machine-readable data model.
When does my company have to issue e-invoices?
From 1 January 2027 if prior-year revenue exceeds 800,000 euros, and from 1 January 2028 for all other domestic B2B companies. The obligation to receive them has applied to everyone since 1 January 2025.
Do I have to choose between XRechnung and ZUGFeRD?
Both satisfy EN 16931. XRechnung is the required standard towards public sector clients; ZUGFeRD is more convenient in B2B because the recipient also sees a human-readable PDF.
