The Wachstumschancengesetz is making electronic invoicing in B2B transactions mandatory in stages. Learn which formats apply, what transitional periods exist, and how to convert your accounting in time.
Electronic Invoicing from 2025: What Businesses Need to Change Now
Electronic invoicing is coming -- not as a voluntary option, but as a legal requirement. With the Wachstumschancengesetz, the legislator has set the course for a fundamental change in German accounting. From 1 January 2025, all domestic B2B companies must be able to receive electronic invoices. The obligation to send them follows in stages. Those who fail to act now risk not only compliance problems but also miss the opportunity for more efficient processes.
This article explains the new requirements in detail and provides you with a practical roadmap for the transition.
What Is an E-Invoice in the New Sense?
Definition Under the Wachstumschancengesetz
The new definition differs fundamentally from what many businesses have previously understood as an "electronic invoice". An e-invoice within the meaning of the new § 14 UStG is an invoice that:
- Is issued in a structured electronic format
- Is machine-readable
- Complies with the European standard EN 16931
In concrete terms, this means: A PDF invoice sent by email is not an e-invoice in the new sense. A PDF is merely a digital image of an invoice that cannot be processed automatically. The previous distinction between paper invoices and electronic invoices no longer applies -- in future, there will only be e-invoices and other invoices (which include both PDF and paper).
The Approved Formats
Two formats meet the requirements of EN 16931:
XRechnung:
- A pure XML format containing exclusively structured data
- No visual layout -- display is handled by viewer software
- Already the standard in public procurement (B2G)
- Maintained by the KoSIT (Koordinierungsstelle für IT-Standards)
ZUGFeRD (from version 2.0):
- Hybrid format: Combination of a visually readable PDF/A-3 and an embedded XML file
- Advantage: Both human-readable and machine-readable
- The "XRECHNUNG" profile within ZUGFeRD fully complies with EN 16931
- Particularly suitable for the transition, as recipients can read the invoice without special software
The Timeline: What Applies When?
From 1 January 2025: Reception Obligation
All domestically established businesses (B2B) must be able to receive e-invoices. At a minimum, an email inbox suffices -- special software is not strictly required for mere reception, but it is for automated processing.
Transitional Periods for Sending
- 2025--2026: Businesses may continue to send paper invoices or other electronic formats (e.g., PDF) -- provided the recipient consents
- 2027--2028: Businesses with prior-year turnover exceeding 800,000 euros must send e-invoices in structured format. Smaller businesses may still use other formats with the recipient's consent
- From 2028: All domestic B2B transactions must be invoiced by e-invoice. EDI procedures (e.g., EDIFACT) remain permissible only if the relevant information can be extracted in EN 16931-compliant form
Exceptions
The e-invoicing obligation does not apply to:
- Small-amount invoices up to 250 euros (§ 33 UStDV)
- Tickets (§ 34 UStDV)
- Tax-exempt supplies under § 4 Nr. 8 to 29 UStG
- Invoices to end consumers (B2C)
Technical Requirements
Peppol Network
The Peppol network (Pan-European Public Procurement Online) is expected to play a central role in the exchange of e-invoices. It is a standardised network for the secure exchange of documents between businesses. Germany plans a national reporting system that is prospectively to be handled via Peppol. The precise design is still pending, but early preparation for Peppol is advisable.
Mandatory Information on E-Invoices
An e-invoice must contain the same mandatory information as a conventional invoice under § 14 Abs. 4 UStG, supplemented by:
- Leitweg-Identifikationsnummer (routing ID -- mandatory in B2G, recommended in B2B)
- Bank details of the invoice issuer
- Payment terms in machine-readable form
- VAT identification number of both the issuer and recipient
Impact on Accounting
DATEV Integration
For businesses working with DATEV, interfaces are available:
- DATEV Unternehmen online supports the import and export of ZUGFeRD and XRechnung files
- Automated document processing recognises structured invoice data and transfers it to the bookkeeping system
- DATEV SmartTransfer enables direct invoice exchange via the Peppol network
Workflow Optimisation
The transition offers significant efficiency potential:
- Automated incoming invoice verification: Mandatory information is validated automatically
- Accelerated approval processes: Invoice data is immediately available in the accounting system
- Reduced error rates: No more manual data entry required
- Faster payment: Automated forwarding to payment systems
Archiving Under GoBD
The archiving of electronic invoices must comply with the Grundsätze zur ordnungsmäßigen Führung und Aufbereitung von Büchern, Aufzeichnungen und Unterlagen in elektronischer Form (GoBD):
- Immutability: The invoice must be archived so that subsequent changes are impossible or traceable
- Machine readability: The structured format (XML) must be preserved throughout the entire retention period -- conversion to PDF is not sufficient
- Retention period: 10 years pursuant to § 147 Abs. 1 Nr. 1 AO
- Process documentation: The archiving processes must be documented
Important: If you receive a ZUGFeRD invoice, you must archive both the PDF and the XML component. The authoritative file is the XML file.
Practical Implementation Checklist
Immediate Measures (now)
- Stocktake: What invoicing software do you currently use? Is it e-invoice-capable?
- Ensure reception capability: Set up at least one email inbox for invoice receipt
- Inform staff: Train the accounting team on the new requirements
- Involve your tax adviser: Coordinate processes and software with your tax adviser
Medium-Term Measures (2025--2026)
- Evaluate software: Check invoicing software for compliance or procure a new solution
- Archiving solution: Set up GoBD-compliant archiving for structured e-invoices
- Test runs: Create and send test e-invoices in XRechnung or ZUGFeRD format
- Inform business partners: Communicate e-invoicing capability to customers and suppliers
Strategic Measures (from 2027)
- Peppol connection: Evaluate registration in the Peppol network
- Full automation: Fully automate invoice receipt and dispatch
- Process optimisation: Optimise approval workflows and payment runs based on structured data
Common Mistakes During the Transition
In practice, we consistently observe the same stumbling blocks when introducing e-invoicing:
- Treating PDF as an e-invoice: Many businesses believe they are already sending e-invoices because they email PDFs. Under the new legal requirements, this is not sufficient
- Neglecting archiving: The XML file is not archived separately or the archiving system is not GoBD-compliant
- Missing process documentation: Without documented processes, objections during tax audits are likely
- Converting too late: Those who react only shortly before the transitional periods expire risk technical problems and compliance gaps
- Not training staff: The best software is useless if the accounting team does not understand the new processes
Differences from the Previous PDF Invoice
| Aspect | PDF Invoice | E-Invoice (XRechnung/ZUGFeRD) |
|---|---|---|
| Machine readability | No (only with OCR) | Yes (native) |
| Automated processing | Limited | Full |
| Error rate in capture | High | Minimal |
| GoBD archiving | As PDF | XML format authoritative |
| Legal status from 2028 | "Other invoice" | E-invoice |
| Validation | Manual | Automatic |
Costs and Benefits of the Transition
The investment in e-invoicing capability pays for itself quickly for most businesses. Studies estimate the average cost of a paper invoice at 11 to 15 euros (printing, postage, manual capture, filing). An electronic invoice costs on average only 1 to 3 euros. For a company processing 200 invoices per month, this yields a savings potential of 20,000 to 30,000 euros per year.
In addition, there are qualitative benefits: faster processing times, fewer reminders through timely processing, and better liquidity management through automated payment runs.
Conclusion
Electronic invoicing is no longer a topic for the future -- it is the present. The reception obligation already applies, and the sending obligation follows in clearly defined stages. Businesses that act proactively now benefit not only from compliance certainty but also from significant efficiency gains in their accounting.
At compleneo, we support you with our tax and digital expertise in transitioning to electronic invoicing -- from selecting the right software to GoBD-compliant archiving. Contact us so your business is prepared in time.
