Receiving and keeping e-invoices in Germany

Since 1 January 2025, according to the German Federal Ministry of Finance, a business must make sure it can receive e-invoices. An email inbox is already enough for that ^[1].

Under § 14 UStG, an e-invoice is an invoice issued, sent and received in a structured electronic format that allows electronic processing ^[2]. According to the ministry this creates no further obligations: the recipient is not obliged to actually carry out any further electronic processing than the record-keeping rules already require ^[1].

Paper and PDF continue for now

For sales made in 2025 and 2026, § 27(38) UStG allows an invoice to be sent until 31 December 2026 on paper or, subject to the recipient's consent, in another electronic format ^[3]. For sales made in 2027 this applies until the end of 2027 if the issuing business's total turnover in the previous calendar year was not more than 800,000 euros ^[3]. Until then, paper and PDF invoices may still arrive.

Making an XRechnung readable

Unlike ZUGFeRD invoices, an XRechnung contains no additional PDF rendering. According to the ministry, businesses therefore need software to display it, a so-called viewer. Many free ones are available, and the tax administration offers its own e-invoice viewer through the ELSTER portal ^[1].

Our viewer is one of these free options. It shows XRechnung, ZUGFeRD and Factur-X as an ordinary invoice, with no account.

With ZUGFeRD, the data counts, not the picture

For hybrid e-invoices such as ZUGFeRD, the ministry says the invoice data in the structured part, for example the XML, is the leading part ^[1]. Our viewer reads the invoice from that structured part.

Keeping it

• Under § 14b(1) UStG, a business has to keep a copy of every incoming and outgoing invoice for eight years ^{[1] [4]}.
• For an e-invoice, the ministry says at least the structured part must be kept so that it is intact in its original form ^[1].
• According to the ministry, storing and archiving e-invoices outside a GoBD-compliant data processing system is not, on that ground alone, regularly a breach of § 14b(1) UStG for VAT purposes ^[1].

This article does not cover record-keeping questions beyond VAT. If in doubt, settle them with your tax adviser.