The use of E-invoice is an invoice that is issued, transmitted and received in a structured electronic format and allows for electronic processing. Since 1 January 2025, a simple PDF file is no longer considered an e-invoice for VAT purposes.
What is an e-invoice?
An e-invoice contains its invoice information in a structured, machine-readable data format. This allows the included details to be processed electronically.
In terms of VAT law, paper invoices or invoices in an unstructured electronic format, such as a simple PDF file, are referred to as other invoices.
Which formats qualify as electronic invoices?
The format used must comply with the legal requirements for a structured electronic invoicing format.
In Germany, the following common formats in particular generally meet these requirements:
- XRechnung
- ZUGFeRD from version 2.0.1, with the exception of the MINIMUM and BASIC-WL profiles
In hybrid formats like ZUGFeRD, the structured data part is decisive for the e-invoice.
What regulations have applied since 2025?
Since 1 January 2025, electronic invoices are generally required for certain transactions between domestic businesses. However, transitional arrangements exist for their issuance.
- Reception Domestic companies have fundamentally been required to be able to receive electronic invoices since 1 January 2025.
- By the end of 2026: Under the statutory transitional arrangement, invoice issuers may still use other invoices.
- By the end of 2027: There is a further transitional arrangement for invoice issuers with a previous year's turnover of at most 800,000 euros.
In addition, there are statutory exceptions, meaning that not every invoicing process is subject to the obligation to issue an e-invoice.
E-invoice and PDF – what is the difference?
A simple PDF invoice contains no structured invoice data and therefore, as of 2025, is not considered an e-invoice for VAT purposes.
A hybrid format such as ZUGFeRD, on the other hand, can contain both a human-readable PDF component and structured invoice data. For the e-invoice, the structured part is decisive in this regard.
How long must e-invoices be retained?
For invoices, the VAT retention period is generally Retention period eight years. In the case of an e-invoice, at least the structured invoice part must be stored in such a way that it remains intact in its original form.
Further basics are explained in the glossary entries on Retention periods and to digital archiving.
