The E-Invoicing Myth: Misconceptions and Preparation
E-invoicing will be gradually introduced starting in 2025, but what exactly is an e-invoice, and what deadlines and requirements need to be met?
Myth 1: A PDF is an E-Invoice.
No, it is not. An electronic invoice must be issued, transmitted, and received in a structured electronic format that can be processed automatically. Simple PDFs or image files (JPEG, etc.) do not qualify as e-invoices, as they are not structured or machine-readable. Instead, specific XML-based formats are used, making them suitable for automated processing. In Germany, XRechnung and ZUGFeRD (version 2.0.1 or higher) will be the approved formats. Other formats can also be used if they are interoperable with the CEN standard EN 16931 through individual agreements.
Myth 2: E-Invoicing Will Be Mandatory for Everyone from January 2025.
Yes and no. Starting January 1, 2025, all companies must be able to receive and archive e-invoices. However, there will be a transitional period until December 31, 2026, during which companies can still issue paper invoices or, if agreed, invoices in other electronic formats (e.g., PDF). Companies with annual turnover under €800,000 will have an extended transition period until December 31, 2027. From January 1, 2028, the new requirements will be mandatory for all B2B transactions. There is no obligation to send e-invoices for private customer transactions.
There are also exceptions: VAT-exempt items, transactions with foreign companies, invoices under €250, and travel tickets are not subject to the e-invoicing requirement.
Myth 3: E-Invoices Can Be Sent via Email.
Yes, but only if the attached electronic invoice meets all legal requirements. To clarify, a simple PDF attached to an email is not considered an e-invoice. Furthermore, email is not a secure delivery channel, and there is no proof of receipt for the sender. More secure options include using specialised digital delivery services, such as d.velop postbox, which offer GDPR-compliant, secure delivery for e-invoices and other documents. Another alternative is providing a secure download link on your company’s website.
Myth 4: Special Software Is Required for Receiving and Sending E-Invoices.
Not necessarily. While specialised software is not mandatory, digital receipts in e-invoice format must be archived in a GoBD-compliant manner. Traditional email inboxes can often fulfill this requirement, but specialised software simplifies implementation and ensures legal compliance. Document management systems (DMS) offer features for displaying, processing, archiving, and securely deleting electronic documents, making e-invoice management more efficient. These systems can automatically read and process various e-invoice formats, archiving them in a searchable digital archive that complies with GoBD standards.
Myth 5: E-Invoices Are Less Secure Than Paper Invoices.
No, e-invoices can be securely archived according to GoBD standards, making them easy to trace and retrieve. Access controls protect against unauthorized use, while versioning prevents loss and tampering. Additionally, qualified electronic signatures or seals can be used in sensitive areas to guarantee the authenticity of invoices and provide maximum protection against forgery.
Nico Bäumer is Chief Technology Officer at d.velop.