e-invoicing

Everything you need to know about e-invoicing: Electronic invoicing will be mandatory from 2025

The e-invoicing obligation is intended to significantly advance digitalization in Germany. From 2025, companies must be able to process e-invoices received. What does this mean for you? We have summarized everything you need to know about e-invoices below – legal requirements, benefits and tips for the changeover.

TL;DR (too long, didn’t read)

  • As part of the “Growth Opportunities Act”, it will be mandatory to be able to technically receive and process e-invoices from 1 January 2025.
  • To date, there has been a statutory transitional period for issuing e-invoices until 2028 at the latest.
  • The obligation to issue e-invoices applies to all B2B invoices that exceed a small amount of 250 euros.
  • Definition of an e-invoice: Electronic invoices are not PDFs, but invoices issued in accordance with EU standards.
  • Formats such as XRechnung and ZUGFeRD fulfill the legal requirements.
  • E-invoices enable automatic, electronic processing without media disruptions and thus create more flexibility in accounting as well as faster payment and thus improved cash flow.
  • Tip for switching to e-invoicing in your company: start early! Establish and analyse the status quo of processes, communicate clearly with suppliers and customers and train employees internally.

Electronic invoices will become mandatory in 2025

The introduction of mandatory electronic invoicing was discussed long in advance. With the passing of the “Growth Opportunities Act” on 22 March 2024, it is now clear that the federal government’s new legal regulation on electronic invoicing (e-invoicing) will come into force on 1 January 2025. The decision is intended to drive digitalization in the financial sector and make processes more efficient – we couldn’t have dreamed up a better way!

With the e-invoicing obligation, companies must be technically capable of exchanging invoices electronically from 1 January 2025 – and no, that doesn’t mean sending a PDF by email. However, there is no need to worry: the federal government has defined generous transition periods for sending electronic invoices. Companies only need to be prepared for the receipt and subsequent processing of such e-invoices by the turn of the year 2024/2025.

What is an e-invoice?

Let’s start from the beginning: what exactly is an e-invoice? With the decision of the Federal Ministry of Finance (BMF), companies must adopt the vocabulary for two new categories. Whereas previously an invoice was simply an invoice, regardless of the format, in future there will be “electronic invoices” and “other invoices”.

An electronic invoice is an invoice “issued and received in an electronic format” according to Section 14 (1) sentence 3 UStG. new version. This implies that the format enables electronic processing. The format of the e-invoice must comply with the European standard for electronic invoicing (Directive 2014/55/EU) and thus the CEN standard EN 16931.

The legal format requirements are met by the XRechnung (XML data format) and the ZUGFeRD invoice (hybrid of PDF and XML file). However, other invoice formats that have not been explicitly mentioned by the BMF can also fulfil the requirements in principle.

Other invoices are those that are still issued on paper, as a PDF or in another electronic format.

So what does this mean in concrete terms?

  • A PDF invoice sent by email will no longer be considered an electronic invoice from 1 January 2025.
  • Even if the definitions apply from 2025, the obligation to issue invoices electronically will not take effect until later (more on this in the FAQs below).
  • However, companies must already enable the processing of electronic incoming invoices at the turn of the year.
    Agreement between invoice issuer and service recipient: Both sides must agree to the use of e-invoicing. This can be agreed in writing or simply by paying the invoice.
Attention

The e-invoice is not a PDF: What’s the difference?

A PDF invoice is issued in electronic format and can therefore also be transmitted and received in this way. From a purely technical point of view, however, it is a digital and image-based invoice that does not enable electronic processing in the sense of an e-invoice.

This means that the invoice information must be transferred manually or via OCR to the accounting software for further electronic processing.

The PDF invoice (as well as the .tif, .jpeg, .docx formats) does not form the basis for the electronic invoice as defined by the new EU directive.

What does an e-invoice look like?

Compared to a PDF, an e-invoice is an invoice issued in a structured format in accordance with EU standards, which is transmitted and received electronically and enables automatic, electronic processing without the usual media disruptions. It contains the same information as an invoice on paper or as a PDF, but in digital format.

COMPARISON BETWEEN A PDF INVOICE AND AN E-INVOICE:

PDF-Rechnung vs. E-Rechnung

 

This means that the e-invoice is either designed as a “pure semantic data format” (PDF file in the sense of ZUGFeRD) or is based on an XML format that is primarily used for machine processing and is not suitable for visual inspection (see visualisation). This structured data makes it possible for invoices to be automatically read into accounting software and processed there.

The federal government defines various standards and specifications for electronic invoicing, including the XRechnung standard, on its dedicated e-invoicing website.

Two important formats for the future: XRechnung + ZUGFeRD

While the XRechnung format is based on an XML format and the data is therefore not readable by the human eye but can only be read by machine, the ZUGFeRD invoice can be used with the attached PDF – the hybrid format delivers the visual invoice as a PDF as usual and also the XML format.

At finway, we are already in the process of converting our software to e-invoices so that you will be able to visualize and read incoming invoices at one click.

What must an e-invoice contain?

In principle, an e-invoice must contain the same data as a conventional invoice. The BMF defines the content requirements for creating an e-invoice as follows:

In accordance with Section 5 of the Federal E-Invoicing Ordinance, an e-invoice must contain at least the following information in addition to the VAT-related invoice components (see Section 14 UStG):

  • Routing identification number: The routing ID is communicated when the order is placed
  • Payment terms (due date or text description of the terms)
  • Bank details of the payee
  • E-mail or De-Mail address of the invoicing party

Mandatory information according to § 5 E-RechV of the Federal Government as well as elements / BT (Business Term) fields in which these are to be entered in an XRechnung:

  • Routing ID: BT-10
  • Bank details: for bank transfer: BG-17 (BT-84 to 86) ; for direct debit: BG-19 (BT-89 to 91)
  • Terms of payment: BT-9 or BT-20
  • E-mail or De-Mail address: BT-43
  • Supplier number*: BT-29
  • Order number*: BT-13

* Mandatory information, if transmitted with order

E-invoicing: Effects on accounting

What does this push towards digitalization mean for accounting?

Well, those who have already dealt with the digitalization of their financial processes in the past now have a pleasant head start and can look forward to the change in the law with confidence. But there is still plenty of time for all those who have not yet digitalized their processes. Nevertheless, we recommend that you take a timely look at the upcoming accounting processes.

E-Rechnung

And, of course, the change has advantages above all. The introduction of e-invoicing means a simplification and acceleration of the invoicing process, as manual input of incoming invoices is no longer necessary – not to mention the tedious scanning, reading and typing of paper invoices. By automating invoice processing, accounting becomes more efficient and less error-prone overall. Digitization also enables better tracking of invoices, faster payments and a good overview of due dates and budgets.

The e-invoice therefore already has the finway seal of approval.

Please note: With the replacement of paper invoices, the archive naturally also becomes digital. This is because digital documents must always be archived digitally. Printing and filing electronic invoices would not be GoBD-compliant.

In the long term, the accounting department must therefore acquire a digital, audit-proof archive and would also be well advised to digitize today’s paper invoices. But please don’t just scan them in and dispose of them. Digitized (i.e. scanned) paper invoices require GoBD process documentation. The original paper invoices can only be destroyed if this process has been carried out correctly.

E-invoices and digitised paper invoices must be stored for 10 years, just like conventional invoices.

By the way: finway is also currently in the final stages of GoBD certification.

Smart

Effects on your accounting software

From 2025, all accounting software must offer the option of processing and archiving e-invoices. The software must be able to read the structured data of an e-invoice and automatically transfer it to the accounting system. Companies should therefore ensure that their accounting software is compatible and fulfills the legal requirements. Many providers are already adapting their programs accordingly.

The 3 major advantages of e-invoicing

  1. E-invoices give the accounting department more flexibility. The administrative effort involved in manual entry is reduced and invoices can be processed more quickly.
  2. Better cash flow: Payment deadlines for e-invoices usually become effective upon receipt of the invoice – if the invoice arrives faster thanks to digital transmission, the money also arrives faster.
  3. E-invoice security through digital storage: Where the integrity of paper invoices in folders is still threatened by risks such as water damage or UV light, electronic invoices are stored securely on servers or in the cloud and can therefore be stored professionally for 10 years.

Does e-invoicing also have disadvantages?

Like any change in the law that requires a change to established processes, the e-invoicing obligation initially seems to have (perceived) disadvantages because it requires additional work. The following processes form the basis for your future electronic invoice processing and prepare your accounting for the future:

  1. Invoice receipt: The invoice recipient undertakes to ensure that the invoice arrives intact and legible. Clear structures are required here to prove delivery.
  2. Legal requirements: Every e-invoice must fulfill the legal requirements – so an internal control procedure is needed to ensure the correctness and authenticity of the invoice.
  3. Declaration of consent: Customers and business partners must agree to the use of digital invoices, for example by written notification or simply by paying the e-invoices. In the transition phase, in which e-invoices must already be received but are not yet widespread, companies need to coordinate with suppliers and the like on a larger scale.

Sounds like a lot at first, but ultimately it’s all a question of habit. After the initial effort involved in the changeover, the advantages of e-invoicing outweigh the disadvantages: less manual effort, less susceptibility to errors, faster payment and therefore more room for scope and time in the finance team for the really important tasks.

Tips for switching to e-invoicing in your company

The e-invoicing obligation is a major step towards digitalization in Germany. It therefore makes sense to digitalize your accounting now at the latest. The sooner you start, the better. After all, you will then have enough time to improve and convert processes along the way if necessary.

The implementation of electronic invoices requires careful preparation and planning. The transition period agreed by the federal government almost makes it more complicated here, as it makes the process a two-stage process:

By the end of the year, you must ensure that you can process incoming e-invoices in your accounting department. By 2028 at the latest, you will then also have to issue your outgoing invoices as e-invoices.

You may therefore need two different pieces of software for this.

Your to-do list for receiving electronic invoices

Start with a comprehensive analysis of your existing invoice processes and record your status quo.

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  • How many invoices do you receive and in which format – on paper or as a PDF?
  • Think ahead: How do you currently send invoices and when do you want to switch to e-invoices yourself?
  • Which software and tools do you already use for your accounting? What updates do the respective providers envisage for e-invoicing in the future?

Adapting internal processes and training your employees will ensure a smooth transition to receiving e-invoices: what do they need to know about the new invoice format and what responsibilities do they have as individuals?

Early and clear communication with suppliers and customers is also important to facilitate collaboration.

You also need to implement appropriate security measures to ensure the confidentiality and integrity of digital data. Your software provider, who ideally offers an audit-proof archive, can help you with this. Continuous monitoring and evaluation of the implementation process enables improvements and maximizes the benefits of e-invoicing.

FAQs on the topic of e-invoices

Is a PDF an e-invoice?

No. Just because invoices are digitised and sent by e-mail, they do not meet the standards for the future e-invoice.

Who has to issue e-invoices?

The e-invoice obligation only applies to services between companies (B2B) where both the invoicing party and the recipient of the service are domiciled in Germany (registered office, management, permanent establishment, but also domicile or habitual residence in Germany, in accordance with the German VAT Act).

New: Under the new legislation, the obligation to issue e-invoices also affects landlords who rent to other entrepreneurs for tax purposes (Section 9 UStG). Previously, the rental agreement could be used as an invoice.

Exceptions to the obligation are small-value invoices of up to 250 Euro (Section 33 UStDV) or travel tickets (Section 34 UStDV), which can still be sent as other invoices, e.g. in paper form.

Do I have to convert my existing invoicing systems?

Yes, all systems must be able to process e-invoices from 2025. Companies should therefore ensure that their accounting software is compatible and fulfils the legal requirements.

When will e-invoicing become mandatory?

From 2025, all companies must be able to receive and process e-invoices. From 2028 at the latest, the issuing of e-invoices will be mandatory for all companies that issue invoices above the low-value threshold of 250 Euro.

However, in view of the expected high implementation costs for companies, the legislator has provided for a transitional arrangement for the years 2025 to 2027.

Until the end of 2026 … paper invoices may continue to be sent for B2B transactions carried out in 2025 and 2026, just like electronic invoices that do not yet comply with the new format.

Until the end of 2027 … paper invoices may continue to be sent for B2B transactions carried out in 2027, just like electronic invoices that do not yet comply with the new format. Please note: The prerequisite for this regulation is that the invoice issuer has a turnover in the previous year (total turnover 2026) of no more than 800,000 euros. Companies whose turnover exceeds this limit can continue to use electronic data interchange (EDI procedure), even if the format of the electronic invoice does not yet comply with the European standard (94/820/EC).

From 2028 … all e-invoicing requirements must be met.

How do I receive an e-invoice?

You can receive e-invoices as usual by e-mail or the service provider can upload them directly to various portals. The way in which you receive e-invoices therefore depends on your internal processes.

Regardless of how e-invoices reach you, the authenticity of the origin, integrity of the content and legibility must be guaranteed.

What advantages does the e-invoice offer?

It saves resources and manual labour and is also more environmentally friendly. The automation of invoice processing makes bookkeeping more efficient and less prone to errors.

DISCLAIMER:

We have researched this article with great care and have written down all information to the best of our knowledge and belief. Nevertheless, we assume no liability for the accuracy and completeness of the information provided. We are not providing legal advice – this information is not a substitute for qualified advice from a tax advisor.

Status: 25.04.2024. All information without guarantee.