E-invoice refers to an invoice that is issued, transmitted and received in a structured electronic format, enabling electronic processing. A plain PDF file has not been an e-invoice within the meaning of VAT law since 1 January 2025.
Basics
An e-invoice contains structured, machine-readable invoice data. This allows the data to be integrated into accounting and approval workflows without the need for manual re-entry.
Common formats are XML-based. The decisive factor is not electronic transmission alone, but the structured form of the invoice details required for VAT purposes.
Legal framework
Since 1 January 2025, electronic invoices are generally required for transactions between domestic businesses, unless a statutory exception applies. There are transitional periods for issuing them; however, the capability to receive an electronic invoice had to be in place as early as 1 January 2025.
Exceptions exist in particular for supplies to private final consumers, certain tax-exempt supplies, low-value invoices up to 250 euros, transport tickets and services provided by small businesses. Despite the exception to the obligation to issue invoices, small businesses must be able to receive e-invoices.
Obligation to receive and transitional periods
- Reception Domestic companies must be able to receive electronic invoices from 1 January 2025. An email inbox is generally sufficient as a reception channel.
- Exhibition until the end of 2026: All invoice issuers may still use paper invoices or – with the recipient's consent – other electronic invoices such as PDF files.
- Exhibition until the end of 2027: The transitional period applies for longer if the previous year's turnover of the invoice issuer is a maximum of 800,000 euros. Certain existing EDI procedures may also continue to be used until the end of 2027.
- Afterwards: Following the expiry of the respective transitional period, an electronic invoice must generally be issued for affected domestic B2B transactions.
Permitted formats
The formats commonly used in Germany XRechnung and ZUGFeRD from version 2.0.1 generally satisfy the requirements. In the case of ZUGFeRD, the MINIMUM and BASIC-WL profiles are not considered electronic invoices in terms of VAT law.
In hybrid formats, the structured data part is decisive. If the readable image part deviates from the structured data, the structured data takes precedence for the e-invoice.
Significance of digital accounting processes
- Automated processing of invoice data
- Fewer manual data entry steps and media disruptions
- Clear examination, authorisation, coding and posting
- Traceable storage of the structured original dataset
Typical process
- Receiving or creating the e-invoice
- Technical and formal check
- Technical approval
- Transfer to financial accounting
- Storage of the structured invoice part in its original form
Storage
Incoming and outgoing invoices must generally be kept for eight years. In the case of an e-invoice, at least the structured invoice part must be retained in such a way that it remains intact in its original form. A mere PDF view does not replace the structured original data set.
Typical sources of error
- Confusing a PDF invoice with a structured electronic invoice
- Lack of reception facility or unclear responsibility for incoming e-invoices
- Archiving only the visualisation instead of the structured original dataset
- Unverified or incomplete transfer of structured invoice data
FAQ
Is every electronic invoice automatically an e-invoice?
No. The crucial point is that the invoicing data must be in a structured, machine-readable format and be processable.
Is a PDF file an e-invoice?
No. Since 1 January 2025, a pure PDF file is classed as another type of invoice because it does not contain structured, machine-processable invoice data.
Do companies already need to be able to receive e-invoices?
Yes. Since 1 January 2025, domestic companies must be able to receive e-invoices. An email inbox is generally sufficient.
What formats are common?
Particularly common are XRechnung and ZUGFeRD from version 2.0.1 onwards; in the case of ZUGFeRD, the MINIMUM and BASIC-WL profiles are excluded.
How long must e-invoices be retained?
Incoming and outgoing invoices must generally be retained for eight years. The structured part of the invoice must remain intact in its original form.
Conclusion
The e-invoice has been part of the VAT invoicing framework since 2025. Businesses must be able to receive e-invoices, observe the staggered transition periods for issuance and properly store the structured original data set.
