E-invoicing: the questions that come up in practice.

No — at least not once the issuing obligation applies. A PDF is a picture of an invoice, not a structured data record. In law it counts as an other invoice. The same goes for TIF and JPEG files or scanned paper.

Until your issuing deadline (2027 or 2028) you may carry on sending PDFs — but only with the recipient's agreement, as before.

What governs is the European standard EN 16931. In Germany it is met in particular by:

• XRechnung — pure XML, established in public procurement
• ZUGFeRD from version 2.0.1 — a PDF with embedded XML; version 2.1 is recommended for issuing

With ZUGFeRD the XML part binds, not the visible PDF page. Where the two differ, the data record governs.

Then the structured XML part governs. Beyond that, the diverging visual part may count as a separate other invoice and trigger an incorrect VAT statement under § 14c UStG. The VAT shown is then owed on top.

This is the most expensive of the silent errors in this area, because the invoice on screen looks entirely correct. The discrepancy may only surface in a tax audit.

We check your outgoing invoices for exactly this discrepancy, before it goes out in series.

EDI invoices have a transitional period until the end of 2027. After that these arrangements too have to meet the requirements of EN 16931. Anyone invoicing through EDI today should settle the changeover with their provider early — the deadline coincides with the first issuing stage.

No. A qualified electronic signature is not required for an e-invoice. What is required is authenticity of origin, integrity of content and legibility — which can equally be secured through an internal control procedure.

Since 1 January 2025. This obligation already applies and has no transitional period. Every company established in Germany has to be able to accept and process an e-invoice — even where it will not have to issue one for a long time yet.

In practice an email inbox is enough to begin with. It becomes more demanding at the processing and archiving stage.

We set up the invoice intake in your bookkeeping — including the connection to your ERP or invoicing system.

• From 1 January 2027, where total turnover in the previous year exceeded 800,000 euros.
• From 1 January 2028 for everyone else — apart from small businesses under § 19 UStG.

What counts is the previous year's turnover. Anyone crossing the threshold in 2026 is caught from 2027.

Invoices between businesses established in Germany, where the supply is not exempt under § 4 Nr. 8 bis 29 UStG. It also covers self-billed invoices and cases under § 13b UStG (domestic reverse charge), and legal persons in so far as they have a business sphere.

Who owes the tax is irrelevant here. The margin scheme for travel services under § 25 UStG and the differential taxation scheme under § 25a UStG are caught as well, once the other conditions are met.

Both sides have to be established in Germany. Cross-border invoices fall outside this rule — there the requirements of the country concerned apply.

For continuing obligations, a single e-invoice for the first part-performance period is often sufficient. The condition is that the underlying contract is attached, or that the content makes clear this is a recurring invoice.

If a mandatory detail changes, the amount after an index adjustment for instance, a new invoice may become necessary. It is worth going through your existing recurring invoices once before the issuing obligation takes effect.

The general deadline is unchanged: six months after the supply is made. The e-invoicing obligation does not affect that — it concerns the form, not the timing.

Yes. Exempt from the issuing obligation are:

• Small-amount invoices up to 250 euros gross under § 33 UStDV
• Travel tickets
• Invoices to private individuals
• Invoices to legal persons without a business sphere

Note: these are exceptions from issuing. You still have to be able to receive.

The small-amount exception then no longer applies, and you need an e-invoice. In practice the threshold is crossed more often than the invoice run suggests: hotel stays, fuel for construction machinery, larger purchases from builders' merchants or wholesalers.

A small dedicated process with three clear roles pays off here:

• Who requests the e-invoice from the supplier?
• Who checks it against the mandatory details?
• Who archives the data record?

Without that allocation you are left with a till receipt, and the input VAT deduction becomes arguable.

Half of it does. Small businesses under § 19 UStG are permanently exempt from the issuing obligation. They are not exempt from receiving: you too have had to be able to accept e-invoices since 1 January 2025.

What is retained is the structured data record itself — electronically, unaltered and in its original form. It has to stay machine-readable for the whole retention period.

A printout of the readable version, or a saved PDF of the visualisation, is not enough. Accompanying documents such as transmission logs are subject to the same requirements.

The retention period for invoices has been eight years since 2025.

We work out with you what your archiving has to meet — together with your software provider where needed.

Yes, where the original invoice had to be one. The correction follows the fate of the original and has to take the same form.

It is different for mere changes to the taxable amount under § 17 UStG, a cash discount, rebate or return for instance. Those require no invoice correction: they are accounted for in the return for the relevant period.

Then they count as not given. All the details required by § 14 Abs. 4 and § 14a UStG have to be present in the data record in structured form. A note in an unstructured remarks field is not enough.

This is the most common silent error in the changeover: the invoice looks right, but the machine cannot find the detail.

We check incoming invoices against the mandatory details — which is where something like this surfaces, before a tax audit does it instead.

Refusal does not create a right to an other invoice. Where the issuer has demonstrably tried to transmit it, their VAT obligation is met — even if the recipient refuses to accept it.

The recipient thereby creates a problem of their own: without the e-invoice they lack the document supporting their input VAT deduction.

Yes. An other invoice can be corrected afterwards by an e-invoice. In some circumstances the input VAT deduction survives even without a correction, where the other invoice is complete and correct in substance — but that is the exception, not the plan.

With intake, not with output — because that is where the obligation already applies:

• Fix a defined intake channel and make it known internally
• Establish whether your accounting system can read XRechnung and ZUGFeRD
• Move the archiving onto the data record, not the readable version
• Only then plan the output side — there you have until 2027 or 2028

We take on those three steps: set up the intake, check the formats, move the archiving. How that works with your running bookkeeping is under German Accounting & Reporting; the tax filing obligations under German Tax & Compliance.

They are technically harder to produce than standard invoices in many software packages, because the advance payment and the final invoice have to be set off against each other and the data record has to reflect that correctly.

So test them early and separately, not once the changeover is under way. The same goes for credit notes, cancellations and corrections. Test only the standard case and you will meet the exception at the worst possible moment.

The German entity is a business established in Germany and is therefore fully caught — wherever the parent sits. Intra-group invoices between German companies fall under the obligation; invoices across the border do not.

In practice that often means the group ERP can already handle e-invoicing while the local setup cannot — or the other way round. In our experience that gap only comes to light when the first XRechnung arrives.

We look at both sides and find the gap before it finds you.