What is an e-invoice, and what is not?

Pick what you received or sent: the check says whether it is an e-invoice in the legal sense and what follows from that.

E-invoice under section 14 UStG?

No

A PDF without embedded XML is a picture of the invoice, not structured data.

Usable for domestic B2B from 2027/2028No
Receipt since 2025Only with your consent
To read itOrdinary software

Basis: section 14(1) sentences 3 to 6 UStG; Finance Ministry FAQ (accepted formats).

How this is checked

Prepared by Radif Partners · Method · VAT Act, ministry letters and XRechnung 3.0.2 checked on 25 October 2026

Under section 14(1) of the German VAT Act (UStG), an e-invoice is an invoice that is issued, transmitted and received in a structured electronic format that allows electronic processing. The format must comply with the European standard EN 16931 or, if the parties agree on another one, allow the data to be converted correctly and completely into such a format. What matters is therefore not that the invoice arrives digitally but that its details exist as data in fixed fields. The Act calls everything else an ordinary invoice: the paper invoice as well as the PDF from Word or accounting software, the photo, the scan and the spreadsheet. Typical e-invoices are XRechnung, a pure XML file, and the ZUGFeRD invoice from version 2.0.1, a PDF with embedded XML, provided it uses at least the BASIC profile. Since 2025 every business in Germany must accept e-invoices from other domestic businesses; issuing becomes mandatory from 2027 or 2028 depending on turnover.

The legal definition

Since 2025 section 14(1) UStG distinguishes only two kinds of invoice. The electronic invoice is structured, machine-processable and standard-compliant. The ordinary invoice is everything else, whether on paper or in another electronic format. In the past any PDF sent by email counted as an electronic invoice; the Act has dropped that usage. Today, in the tax sense, an e-invoice means only files whose content software can read without text recognition.

The Finance Ministry letter of 15 October 2025 explains the terms. The format must comply with EN 16931; another format is also allowed if issuer and recipient agree on it and the details can be converted correctly and completely into a compliant format. This mainly concerns established EDI procedures.

Which files count

Classification of common invoice files under section 14(1) UStG.
FileClassificationReason
Paper invoiceOrdinary invoiceNot electronic
PDF from Word or accounting softwareOrdinary invoiceOnly a picture, no data fields
Scan or photoOrdinary invoicePicture, even with text recognition
Word or Excel fileOrdinary invoiceNot structured to EN 16931
XRechnung 3.0.2E-invoiceGerman specification of the standard
ZUGFeRD BASIC, EN 16931, EXTENDEDE-invoiceFrom version 2.0.1
ZUGFeRD MINIMUM, BASIC WLOrdinary invoiceNo invoice lines
ZUGFeRD 1.0Ordinary invoicePredates the standard
EDI messageTransition until 31 December 2027Afterwards only if convertible to the standard

The table also explains why two files that look the same can differ legally. A PDF with embedded ZUGFeRD XML in the EN 16931 profile and a PDF without an attachment look identical on screen. Only a look at the attachments, or the PDF check on this site, shows whether data is inside.

What the difference means for your business

For receiving, the distinction means: you have had to accept an e-invoice since 1 January 2025, an ordinary invoice only if you agree. For sending it means: once the duty to issue applies to you, an ordinary invoice is no longer enough for domestic supplies to businesses, except in the legal exceptions. The cut-off dates are on e-invoicing mandate and deadlines.

Whether your business is ready to receive is shown by this short list of four questions:

Ready to receive

Ready to receive

1 / 4

Set up an address such as invoices@Done
Use a viewer or accounting softwareOpen
Pre-check or KoSIT validator before payingOpen
Keep the original XML for eight yearsOpen
Set up receiving completely →

Reading e-invoices

A pure XML file is awkward for people. To read it you need a viewer. Besides the viewer on this site, which works in your browser, the tax administration offers its own tool, the e-invoice viewer on ELSTER. For your accounting the original file always counts; a view printed from it is a reading aid, not a replacement. Which exact format a file has is shown on e-invoice formats.

Common questions

Is a scanned paper invoice an e-invoice?

No. A scan is a picture of the invoice, even if text recognition makes the content searchable. The details are not held in fixed data fields under the standard, so the scan remains an ordinary invoice. For your accounting the document keeps its value, but it does affect whether the supplier has met its duty to issue an e-invoice.

What does an e-invoice look like when I open it?

In a text editor an XRechnung shows only XML code with element names such as Invoice or PayableAmount. It only becomes readable in a viewer that displays the fields as an invoice. A ZUGFeRD invoice, by contrast, opens like any PDF; the data sits inside it as an invisible attachment. The viewer on this site shows both kinds as an invoice without uploading the file.

Does an e-invoice need an electronic signature?

No. A qualified electronic signature is not required for e-invoices. You must ensure the authenticity of origin and the integrity of the content, but an internal control procedure that matches invoice and supply achieves this. In practice: order, delivery and invoice fit together, and the file is stored unchanged.

Is every XML file with invoice data automatically an e-invoice?

No. The XML must follow an EN 16931 format, recognisable by the identifier in field BT-24, and contain all mandatory details. A home-made XML export from a spreadsheet usually does not. You can check this with the format detector and the pre-check on this site, and run the full check with the KoSIT validator.

Keep going

E-invoicing mandate

Who must receive and issue e-invoices, and from when?

E-invoice formats

XRechnung, ZUGFeRD, Peppol, EDI: which format a file uses

EN 16931

The European standard behind every e-invoice: data model and required fields

Receiving e-invoices

Inbox, reading, checking, filing: what receiving requires

Open an e-invoice

Show XRechnung and ZUGFeRD as a readable invoice, print it, save it

ZUGFeRD

PDF with embedded XML: versions, profiles and what counts as an e-invoice

Official sources for this page

Prepared by

Publisher of a free German e-invoicing toolkit: obligation check under the VAT Act, viewer, checker and creator for XRechnung and ZUGFeRD in the browser

Updated on · Editorial policy · Contact

As of 2026, laws, ministry letters and standards checked on