With e-invoicing becoming increasingly mandatory in Germany, especially for transactions with public authorities and soon in the B2B sector, many companies are asking questions about the required formats and compliance. Below, We've answered some of the most common questions about e-invoicing obligations in Germany.
1. Are EDI files accepted as e-invoices?
Yes, but only for now.
Currently, EDI files are accepted as e-invoices, but specific formats are required when invoicing public authorities, where XRechnung is mandatory. For the B2B sector starting January 1, 2025, no specific format is required, as long as paper or purely PDF invoices are no longer used. You can use XML-based, hybrid, or EDI formats, based on agreements between the customer and supplier. However, pure XML formats like XRechnung are recommended, as these can be transmitted via Peppol.
2. Can PDF files be considered e-invoices?
Only if the PDF includes a ZUGFeRD XML format.
A standard PDF does not qualify as an e-invoice unless it contains a ZUGFeRD XML embedded within it.
3. How can I send ZUGFeRD invoices?
You can send ZUGFeRD invoices via email or upload them to your partner’s portal.
ZUGFeRD is essentially a PDF file with an embedded XML, so it’s simple to send electronically. However, it’s important to note that ZUGFeRD cannot be transmitted via Peppol because of its PDF format.
4. We have EDI integration with our partners. Should we change it?
EDI is accepted as an e-invoice for now, but by 2028, you’ll need to switch to the XRechnung format for full compliance.
5. Our software produces XRechnung (UBL). Do we need anything else?
Yes, to create and send a valid XRechnung UBL invoice, you need a Peppol ID (Leitweg-ID). Invoices are transferred via the Peppol network, and sending an XRechnung UBL by email is not valid. You’ll either need to obtain a Peppol ID license or work with a licensed provider.
6. We don’t want to register with a Peppol provider. Is that a problem?
While it’s theoretically possible to stick with ZUGFeRD or EDI formats, in practice, if a vendor or supplier wants to send you an XRechnung, you will need a Peppol ID. Even if you only receive a few XRechnung invoices in 2025, the number is expected to grow over time, making it essential to eventually register with a Peppol provider.
7. Do I have to work with a Peppol service provider based in Germany?
No, but for compliance with GDPR and local data security regulations, it’s advisable to work with a provider that operates within the EU and has EU-based data centers.
8. As a company using ERP software, do we need to integrate with a Peppol provider?
You don’t need to send XRechnung UBL invoices, but you will need to be able to receive them. This can be done by partnering with a Peppol provider and viewing the invoices through their web interface if needed.
9. Do freelancers or small business owners need to use Peppol?
If a supplier wants to send you an XRechnung invoice, then yes, you will need to sign up with a Peppol provider to receive it.
If you can communicate with the party sending the invoice and reach an agreement, that’s perfectly fine. For example, if Microsoft wants to send you an XRechnung for your email account, you will need to receive it and provide a Leitweg-ID (Peppol ID).
By preparing now, companies can ensure they remain compliant with evolving e-invoicing regulations in Germany. If you have further questions or need assistance with integration, feel free to reach out!
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