Mandatory e-invoicing from 2025: A guide

Victoria Waba

Content Marketing Manager

11/18/20243 min read

At fiskaly, Victoria specializes in the German market, digital receipts, and employer branding. With a deep understanding of the digital landscape, she simplifies fiscalization, enhancing transparency and compliance.

From January 1, 2025, e-invoicing will become mandatory for domestic B2B transactions in Germany. This initiative aims to combat VAT fraud while enhancing efficiency and digitalization in book-keeping.

The mandatory e-invoicing requirement in Germany was established under the “Act to Strengthen Growth Opportunities, Investments, and Innovation as well as Simplification and Fairness in Taxation”, known as the Growth Opportunities Act (Wachstumschancengesetz), in March 2024.

Invoices and electronic invoices: what’s the difference?

The distinction between invoices and electronic invoices is defined in § 2 of the German E-Invoicing Regulation (E-Rech-V).

What is an invoice?

The E-Invoicing Regulation defines invoices as "documents that settle a delivery or service, regardless of how this document is labeled in business transactions."

Invoices are categorized into the following formats:

Structured data (XML, e.g., XRechnung)
Unstructured data (e.g., PDF, TIF, JPEG, or Word formats)
Hybrid data formats (e.g., ZUGFeRD)

What is an e-invoice?

A valid e-invoice, according to the E-Invoicing Regulation, exists only if:

The invoice is issued, transmitted, and received in a structured format
The format allows for automatic and electronic processing of the document

For a valid e-invoice, it’s crucial that both data creation, transmission by the sender, and receipt by the recipient occur digitally.

What data must an e-invoice include?

In addition to VAT-related invoice components, an e-invoice must additionally include:

Routing identification number
Bank details
Payment terms
The issuer’s email address
Supplier and order number, if previously provided to the issuer

When does e-invoicing become mandatory?

Starting January 1, 2025, all companies in Germany are required to receive e-invoices in B2B transactions. Previously, this obligation applied only to transactions with public-sector clients (B2G, e.g., government agencies, public institutions).

Receiving e-invoices

As of January 1, 2025, the requirement to receive e-invoices takes effect, eliminating the precedence of paper invoices and the consent requirement for receiving them. This means that from this date, your business partners can send you e-invoices without needing your explicit agreement. VAT deductions must then be based on the received e-invoice, with no entitlement to an alternative invoice format, like a paper invoice.

What are the transition periods for e-invoicing?

To allow companies time to adapt, transition periods for issuing e-invoices in B2B transactions have been established by the legislator:

Until December 31, 2026: Companies may continue to send paper invoices or e-invoices in unstructured formats (e.g., PDF) if the recipient agrees.
From January 1, 2027: Companies with a previous year’s revenue of more than €800,000 must issue e-invoices.
From January 1, 2028: All companies, regardless of revenue, must issue e-invoices.

Which formats are acceptable for a valid e-invoice?

From January 1, 2025, an e-invoice will be recognized as valid only if the required invoice data is in a structured electronic dataset within an XML file.

At that point, only structured electronic formats in compliance with the European standard EN 16931 will be considered valid e-invoices, allowing for further electronic processing. Unstructured formats like PDF are insufficient since they do not permit processing. Currently, formats such as XRechnung and the hybrid ZUGFeRD format meet the standard’s requirements.

Invoicing with the ZUGFeRD format

ZUGFeRD (Central User Guide of the Forum for Electronic Invoicing Germany) is a hybrid invoicing format specifically designed for electronic invoicing in Germany. It combines a PDF document with an embedded XML file containing structured invoice data, providing both a readable and machine-processable invoice. This format complies with the European standard EN 16931, making it suitable for e-invoicing in B2B and B2G transactions throughout the EU.

Invoicing with the XRechnung format

Unlike ZUGFeRD, the XRechnung format contains only structured XML data and is thus designed exclusively for electronic processing. Unlike hybrid formats, XRechnung does not include a readable PDF component.

Does a PDF invoice fulfill the e-invoicing requirement?

Invoices in PDF format or other unstructured electronic formats like Word (DOCX), Excel (XLSX), or image files (e.g., JPEG) will not meet e-invoicing requirements as of January 1, 2025.

While they can be created, sent, and received electronically, they are merely digital representations of invoices and do not allow for electronic processing. Unstructured digital formats, like paper invoices, will be considered "other invoices" by law and, after the transition period, may only be used in exceptional cases.

What is the importance of the GoBD for e-invoices?

The legal retention period of 10 years also applies to e-invoicing. As before, companies must adhere to the “Principles for Proper Record Keeping and Retention of Books, Records, and Documents in Electronic Form” (GoBD). It’s crucial to store e-invoices in their original, structured electronic format, ensuring they meet the requirements for immutability upon storage.

What are the benefits of electronic invoicing?

Implementing e-invoicing offers numerous benefits, helping companies and authorities operate more efficiently and cost-effectively. Key advantages include:

Automation: Through digital transmission and processing, companies can further automate processes, such as automatic booking, reminders, and payment matching.
Cost savings: By eliminating paper, printing, postage, and manual handling, invoicing costs are significantly reduced.
Time savings: E-invoices can be sent and received instantly, shortening payment cycles by reaching the recipient faster.
Error reduction: E-invoices use structured data formats that integrate directly into existing systems, minimizing manual input errors and reducing the need for corrections.
Sustainability: Transitioning to digital invoices reduces paper consumption and associated environmental impacts, like CO₂ emissions from production and shipping.
Improved transparency and tracking: E-invoicing provides clearer oversight and simplifies payment tracking. Data can be archived and searched more easily, streamlining invoice management.
Enhanced compliance: E-invoices meet legal requirements for invoicing and archiving, with structured data transfer ensuring all legal requirements are met.

Companies should update their internal processes and IT systems in advance to meet these new requirements and ensure a smooth transition to e-invoicing.

fiskaly supports companies in adhering to fiscal regulations and digitizing receipts.