E-Invoicing: We answer the most frequently asked questions

Whether freelancers, self-employed professionals or KMUs and large companies – e-invoices are becoming increasingly important in day-to-day business. While e-invoices have long been mandatory for public contracts, electronic invoices will soon also become standard in the B2B sector. This makes it all the more important to familiarise yourself with the most important information now.

Our overview of the most frequently asked questions about e-invoices will prepare you for the creation, processing and archiving of e-invoices!

What is an e-invoice?

Legally compliant e-invoices are based on EU Directive 2014/55/EU and the resulting EU standard EN 16931. They must use a structured format for electronic, machine-readable invoices in which invoice-relevant documents can be embedded. The electronic invoice format is used for the creation, transmission, receipt and further processing of all invoice information. The structured metadata can be automatically extracted and processed for greater efficiency in accounting.

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Legally compliant e-invoices

Legally compliant invoices must fulfil all the requirements of EN 16931, the E-Invoicing Ordinance and the planned Growth Opportunities Act of the Federal Ministry of Finance. Structured XML formats or the more complex EDI formats are generally used for this purpose. In public invoicing, XML formats such as XRechnungen serve as an established, officially recognised standard. Hybrid PDF and XML formats such as ZUGFeRD are also accepted.

Non-compliant e-invoices

Visual formats such as PDF invoices do not enable machine-readable processing and do not fulfil the legal requirements. Other electronic invoice formats without structured data records in accordance with the legal requirements are also not accepted. They therefore fall under the category of ‘other invoices’. In the B2B sector, ‘other invoices’ are still possible with the consent of the invoice recipient. Since 2020, only electronic invoices may be issued and received in the public sector.

What formats are available for e-invoices?

As long as they fulfil the legal requirements, various standards or formats can be used for e-invoices. The two most common forms of e-invoices as defined by the e-invoicing regulation, EN 16931 and the Growth Opportunities Act include:

• XRechnung: As a structured XML data record with all the necessary invoice information, the XRechnung format fulfils all the requirements for e-invoices. For this reason, XRechnung has established itself as the official standard for public clients and invoice issuers in the public sector. The standard is operated by KoSIT, the coordination centre for IT standards.
• ZUGFeRD: The ZUGFeRD format is a hybrid e-invoice that combines the visual PDF format with an additional XML data record. While the PDF version of the invoice guarantees easy readability, the XML version of the e-invoice ensures legal compliance.

Other possible variants for e-invoices are EDI invoices. This is also an electronic invoice format that enables automatic, electronic processing. Compared to XInvoices and ZUGFeRD, however, EDI requires more effort. The reason for this is that the format requires individually agreed exchange agreements and technical expertise during implementation. XRechnung and ZUGFeRD, on the other hand, offer only minor hurdles for implementation.

What are the advantages of e-invoices?

Recognised electronic invoice formats simplify accounting through automated workflows, transparent invoice creation and processing as well as standardised business processes. From invoice creation to invoice verification and archiving, they save time and costs, as recording, indexing and classification are highly automated. In addition, compliance with legal frameworks, space-saving, secure archiving and a high level of data protection are ensured.

How can I create an e-invoice?

In order to create legally compliant invoices, it is advisable to use reliable accounting or invoicing software such as Accountable. This also applies to recognised e-invoice formats. Digital solutions for document management or ERP systems such as SAP also generally offer the option of creating official e-invoices.

Although it is theoretically possible to create e-invoices manually, it is advisable to use suitable tools for e-invoices to ensure correctness. In addition, federal internet platforms such as the ‘Zentrale Rechnungseingangplattform’ (ZRE) and ‘Onlinezugangsgesetz-konforme Rechnungseingangsplattform’ (OZG-RE) can be used to exchange invoices with public authorities. Both enable suppliers and service providers to send official e-invoices to public clients.

How can e-invoices be verified?

Software solutions with an integrated e-invoice validator are used to check e-invoices in a similar way to how they are created. Here, the automatic extraction and validation of e-invoices is rule-based. During automatic validation, the syntax schema and XML tags of the data record are checked. If the content and structures are correct, the invoice is automatically forwarded to the accounting department or archive or, in the event of errors, is placed on resubmission, for example.

Who must send e-invoices?

All public authorities and invoice issuers on behalf of public authorities must use recognised formats for e-invoices. The B2B sector is not yet required to use e-invoices.

This will change with the Federal Ministry of Finance’s planned Growth Opportunities Act. E-invoicing will become mandatory for invoice exchange in the B2B sector from 1 January 2025 in staggered stages until January 2028 at the latest. From January 2025, companies must be prepared in principle to process official e-invoices, as their use does not require the consent of the invoice recipient.

What legal requirements apply to e-invoices?

The most important legal, technical and formal requirements for e-invoices include:

• Authenticity of origin
• Integrity of the invoice content
• Structured, machine-readable file format for automatic, machine-readable processing
• Fulfilment of all invoice requirements in accordance with the Value Added Tax Act, Commercial Code, Fiscal Code and GoBD.

The most important legal regulations for e-invoices are the EU invoicing standard EN16931, the German Value Added Tax Act (Umsatzsteuergesetz), the Abgabenordnung, the GoBD and the so-called Wachstumschancengesetz.

What information must be included on an e-invoice?

Just as with traditional invoices, there are mandatory details that are part of every e-invoice. There is also additional information, such as the Leitweg-ID (routing ID) for public clients, which you need specifically for e-invoices. The most important contents include:

• Invoice recipient’s Leitweg-ID
• Applicable terms of payment
• Payment details (bank details of the invoice issuer)
• Name, address and contact details (invoice issuer and invoice recipient)
• Order number
• Supplier number
• Invoice number
• Tax number (or VAT-ID)
• Invoice date
• Legal form
• Details of delivery/service
• Payment amount

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How are e-invoices archived?

E-invoices are legally equivalent to paper invoices and are subject to a ten-year retention obligation in accordance with the German Value Added Tax Act, the German Commercial Code and the German Fiscal Code. They must be archived in the original electronic format, readable at any time, analysable by machine and audit-proof.