EDI invoicing: what happens to EDIFACT under the e-invoicing mandate
Choose the year of supply, consent and whether the data is extractable: the calculator says whether your EDI invoice is allowed and what the set-up needs from 2028.
EDI invoice allowed?
Yes
Existing EDI set-ups remain allowed with consent until 31 December 2027 (section 27(38) no. 3 UStG).
| Transition ends | 31 December 2027 |
| Needed afterwards | Interoperability with EN 16931 |
Basis: section 14(1) sentence 6, section 27(38) no. 3 UStG; Finance Ministry letter of 15 October 2025.
Prepared by Radif Partners · Method · VAT Act, ministry letters and XRechnung 3.0.2 checked on 25 October 2026
Many businesses in retail, manufacturing and logistics have exchanged invoices by EDI for years, mostly as EDIFACT INVOIC messages or in an industry XML format. The German e-invoicing mandate does not abolish these set-ups, but it attaches conditions to them. Until 31 December 2027 invoices may continue to be sent in an EDI procedure under section 27(38) no. 3 of the VAT Act (UStG) if the recipient agrees, even where the format does not match the European standard EN 16931. After that an agreed format only counts as an e-invoice if the VAT details can be transferred correctly and completely into an EN 16931 format, or if the format is interoperable with it; this is laid down in section 14(1) sentence 6 no. 2 UStG. For EDI partners that means: by the end of 2027, check whether every mandatory element of the standard exists in their own message profile and can be mapped unambiguously, or switch to XRechnung or ZUGFeRD. The recipient's consent remains necessary either way.
Why EDI gets a rule of its own
Electronic data interchange is older than the e-invoice. Retailers and suppliers have linked their merchandise systems for decades through standards such as EDIFACT, with order, despatch advice and invoice flowing as messages. These invoices are structured and machine-processable, but they do not follow the data model of the European standard EN 16931, which only dates back to Directive 2014/55/EU. Had the legislator admitted only the standard, established set-ups would have lost their footing overnight.
That is why section 14(1) sentence 6 UStG offers two routes to an e-invoice: a format under EN 16931 (number 1), or another format agreed between the partners (number 2) if it allows the correct and complete extraction of the required details into a compliant format or is interoperable with it. For the transition period a third, more generous rule is added.
The transitional rule until the end of 2027
Section 27(38) no. 3 UStG allows invoices for supplies up to 31 December 2027 in an EDI procedure under Article 2 of Commission Recommendation 94/820/EC if the recipient agrees. Whether the data can be transferred into the standard does not matter until then. Unlike the PDF, there is no turnover limit in 2027 either: a group with billions in turnover may keep its existing EDI invoices just as a small supplier may.
Consent is not a mere formality here. EDI requires an agreement between partners anyway, usually a framework contract with technical annexes. Whoever has such an agreement normally meets the condition. New partners who only want to process standard e-invoices may refuse consent, though; the issuer must then deliver an XRechnung or ZUGFeRD invoice.
This invoice form is
This invoice form is
Only with the customer’s consent
| 2025 | Only with the customer’s consent |
| 2026 | Only with the customer’s consent |
| 2027 | Only with the customer’s consent |
| 2028 on | No longer allowed |
What counts from 2028: extraction without loss
From 1 January 2028 an EDI invoice too must meet the condition of number 2. In practice that means a check, field by field: for every mandatory element of EN 16931, such as invoice number, date, addresses, tax numbers, lines, VAT categories and totals, there must be a counterpart in your own message profile, and the values must transfer unambiguously and completely. If an element is missing or only present as free text, that is not enough.
Standards bodies and industries have described mappings from EDIFACT to the standard. Whether your specific profile meets them depends on the segments you actually fill. A good test is to convert a typical invoice into an XRechnung on a trial basis and run it through a validator: whatever is missing there is missing in the EDI profile too. The fields the standard requires are listed on EN 16931: the mandatory fields.
Three routes for EDI partners
- Extend the profile: enlarge your EDI format so it holds every detail of the standard, and record that in the contract with your partner.
- Output in parallel: produce an XRechnung or ZUGFeRD file next to the EDI message. Many systems can generate both from the same data.
- Switch: move entirely to an EN 16931 format, for instance XRechnung over the Peppol network. For partners with few invoices this is usually the simplest route.
The Finance Ministry letter of 15 October 2025 names EDI procedures expressly as an admissible alternative, as long as the conditions are met. The administration keeps no list of recognised profiles; responsibility for transferability lies with the partners. So document how you checked it. An overview of the other formats is on e-invoice formats compared.