The German e-invoicing mandate: what agencies need to know

Which dates apply?

Until each date, paper and PDF invoices may still be issued; a PDF by email counts as an “other invoice” and needs the recipient's agreement. Invoices to consumers, and small invoices up to €250, are not covered.

What counts as an e-invoice?

An e-invoice is issued, transmitted and received in a structured electronic format that allows automatic processing and follows the European standard EN 16931. A PDF is not an e-invoice, even when sent by email.

The two common German formats are XRechnung, pure XML, and ZUGFeRD, a PDF with the XML embedded (from version 2.0.1, except the MINIMUM and BASIC-WL profiles).

What changes for an agency?

• Every client invoice must be produced as XRechnung or ZUGFeRD, not exported from Word or as a PDF.
• The mandatory details must be in the data, not just on the page: service period, VAT rate or exemption reason, consecutive number, the client's details.
• Public-sector clients also need their Leitweg-ID as the buyer reference.
• Corrections are linked correction invoices — in German a Rechnungskorrektur or Stornorechnung. A “Gutschrift” is, for VAT, a self-billed invoice issued by the customer (§ 14 (2) UStG) and the wrong word for a correction.

How does Valtor issue e-invoices?

Valtor prepares each invoice from the approved contract terms and issues it as XRechnung or ZUGFeRD through its e-invoicing provider, a Peppol access point.

Valtor allocates the invoice number, consecutive for each billing entity, at the moment of sending. VAT follows the recipient — including reverse charge for business clients in the EU, whose VAT ID is checked against the EU's VIES service — and the figures for the VAT return (UStVA) and the EC sales list (ZM) are ready.

This page is general information, not tax advice.

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