What counts as an e-invoice under the law?
An e-invoice is an invoice in a structured electronic format under the EU standard EN 16931 and therefore machine-readable. PDFs and image scans are not e-invoices in the sense of the receiving obligation that applies from 2025; they count as "other invoices". The German Wachstumschancengesetz (Growth Opportunities Act) adopted this definition in § 14 UStG.
Two format families matter in practice in Germany:
- XRechnung, pure XML, and the default standard for invoices to the German federal government (ERechV); other formats compliant with EN 16931 are permitted. The federal states and municipalities set their own rules, where XRechnung is the widely used standard.
- ZUGFeRD, a hybrid of PDF/A-3 with embedded XML, widespread among mid-sized B2B companies.
Both formats are based on the European standard EN 16931.
Timeline of the mandate (§ 14 and § 27 (38) UStG)
The Wachstumschancengesetz set the B2B stages; the B2G obligation towards the federal government follows from the E-Rechnungsverordnung (ERechV).
- 27 November 2020: Suppliers to the German federal government must submit invoices electronically (ERechV). XRechnung is the default standard here; other formats compliant with EN 16931 are permitted. Direct awards up to €1,000 are exempt.
- 1 January 2025: Obligation to receive domestic B2B invoices: every company must be able to accept structured e-invoices.
- 1 January 2025 to 31 December 2026: Transition period. Paper invoices remain permitted; other electronic formats such as PDF only with the recipient's consent (§ 27 (38) no. 1 UStG).
- 1 January 2027: Obligation to issue for domestic B2B invoices where prior-year revenue is more than €800,000 (§ 27 (38) UStG).
- 1 January 2028: Obligation to issue for all remaining domestic B2B invoices, regardless of prior-year revenue. Permanently exempt are, among others, small businesses under § 19 UStG as issuers and small-value invoices up to €250. You still have to be able to receive e-invoices.
What companies should do now
- Define your receiving channel: settle on a dedicated e-mail address, upload, SFTP or PEPPOL connection, and tell people internally where invoices should be sent.
- Validate incoming invoices: check the format against EN 16931 and report errors back to the sender.
- Structured data into the workflow: supplier, amounts and accounts go straight into approval and accounting instead of being retyped.
- Keep the original: archive the XML (or the PDF/A-3 with XML) in a way aligned with GoBD, with an audit trail of every processing step.
What OXS.eco covers for e-invoicing
- Receiving and validation: the solution Receive, check and process e-invoices accepts XRechnung and ZUGFeRD and checks them technically against EN 16931.
- Free check: send us a specific file via Check an e-invoice free of charge. We reply with an assessment.
- Archiving: documents are retained aligned with GoBD, with an audit trail, see Audit-proof archiving.
E-invoicing solution XRechnung in detail ZUGFeRD in detail EN 16931 Glossary
As at September 2026. Note: this page gives orientation on the e-invoicing obligation under § 14 and § 27 (38) UStG (Wachstumschancengesetz), but it is not legal or tax advice for an individual case.