Receiving e-invoices: how to organise incoming invoices since 2025

Since 1 January 2025, the new definition of an invoice in § 14 UStG has applied. Under it, an electronic invoice is now only an invoice that is issued, transmitted and received in a structured electronic format and can be processed electronically. A PDF file sent by email does not qualify. Like a paper invoice, it counts as an "other invoice".

Most businesses will only have to issue e-invoices later. However, every business must already be able to receive them as soon as a domestic supplier sends them. This also applies to small businesses and to businesses with predominantly tax-exempt supplies. The sender does not need the recipient's consent for this.

What counts as an e-invoice

The format must comply with the European standard EN 16931. In Germany, this mainly means XRechnung and the hybrid format ZUGFeRD from version 2.0.1. In the BMF's view, the ZUGFeRD profiles MINIMUM and BASIC-WL do not meet the requirements. Low-value invoices up to 250 euros and travel tickets may still be sent as other invoices.

An email inbox is sufficient for receipt

The BMF considers it sufficient for you to provide an email inbox for receipt. A portal or a special transmission channel is not required. In practice, it is worth setting up a separate address just for invoices, so that attachments do not get stuck in personal inboxes.

Reading them is more difficult. An XRechnung is an XML file that hardly anyone can check without suitable software. If you do not yet use accounting software with an import function, you will at least need a viewer that displays the file in readable form. With ZUGFeRD you see an ordinary PDF, but the embedded XML part is what counts for tax purposes.

Checking, approving, retaining

• Check the mandatory information in the structured data and do not rely solely on the human-readable version.
• Decide who approves an invoice as factually correct and how it reaches the accounting department or tax firm.
• Keep the e-invoice electronically in the format in which it was received. A paper printout is not sufficient for the archive.

The transitional period runs until 2027

For supplies in 2025 and 2026, suppliers may still send paper invoices or, with your consent, PDF invoices (§ 27 Abs. 38 UStG). In 2027, this only applies to issuers whose total turnover in the previous year was no more than 800,000 euros, and from 2028 to no one at all. The proportion of structured invoices received will therefore increase gradually. A process that works today with a few individual cases should be able to handle large volumes by then.