On 1 January 2025 something changes in the way invoices arrive, whether or not you prepared for it. Companies based in Germany must be able to receive and process electronic invoices in a structured format when they do business with other companies. Receive. Not necessarily send, since longer transition periods apply to sending. That distinction is the first thing lost in almost every conversation about this.
The duty to receive is the actual news
From January your customer may send you a structured e-invoice, and you have to be able to take it. You cannot object and politely ask for a PDF instead. In practice this means more than keeping a mailbox that accepts the file. You need a way to read it, check it, approve it and store it in its original format. Improvise that in January and, in my experience, you will still be improvising years later.
Why a PDF invoice is not an e-invoice
This is the point where most people stop and blink. A PDF sent by email is not an electronic invoice under the rules, because it is not structured and machine readable. A person can read it. To software it is a picture with text in it, from which numbers can at best be guessed. For a long time the PDF counted as progress over the fax machine. That era is ending, and honestly it is no great loss.
XRechnung and ZUGFeRD
Two formats matter in Germany. XRechnung is a pure XML data set with no visual layer. Open the file without the right program and you see code and wonder what went wrong. ZUGFeRD takes a hybrid route: a PDF file with a structured data set embedded inside it. A person sees the invoice they are used to, the software reads the data behind it. For companies whose customers are at different stages of readiness, that is often the more pragmatic path, because nobody has to change what they are used to looking at.
What to check in accounting
Ask your software vendor, but ask precisely. Can the system read XRechnung and ZUGFeRD and map the fields correctly? Is the original file archived in an audit-proof way, or does the system only store a PDF generated from it? The second case is a problem, because what has to be kept is the original. How do checking and approval work once no paper moves through anyone hands and the old process depended on a rubber stamp? And what happens to invoices that are formally perfect but factually wrong?
These sound like accounting questions. They are process questions. Ask them too late and you build workarounds, and workarounds have a habit of staying.
The obligation is also an opportunity
You can tick this off by doing the minimum. Accept the format, check the box, carry on as before. I think that wastes the moment. If invoices arrive as a clean data set anyway, then matching them to the purchase order, comparing them with the delivery note and routing them to the right approver can happen automatically. That is where the benefit sits, not in the obligation itself. In our custom software work we regularly meet companies where somebody retypes invoice data that already exists in structured form. That was annoying before the rules. Now it is hard to defend.
One necessary note: this article is not tax or legal advice. Your tax adviser knows your case and the details that do not fit into a blog post.
Frequently asked questions
Do we have to send electronically from January as well?
No. Longer transition periods apply to sending. What is mandatory first is that you can receive and process structured invoices.
Is an email mailbox enough as a receiving channel?
A mailbox is an acceptable transmission channel. It does not answer the question of how the file is then read, checked and archived in its original form. That is where the real work sits.
What about invoices to private customers?
The rules cover business between companies based in Germany. For invoices to private customers you still need their consent before sending electronically.
If you are unsure whether your systems will be ready in January, we are glad to look at your invoice intake in detail. A first conversation is informal and free of sales pressure.
This article belongs to our knowledge hub Custom software development.