E-invoicing 2026

Since 01/01/2025, e-invoicing in the German B2B environment is no longer a trend — it’s a compliance reality. And that’s exactly the point: many companies can send PDFs today, but they are not yet properly set up for structured e-invoices under EN 16931 (XML) — including receipt, processing, archiving, and audit-ready control processes.

Over the next months, you’ll see whether e-invoicing becomes a quiet process upgrade — or later a loud compliance case: questions in the invoice flow, stalled approvals, discussions around input VAT deduction, and avoidable effort during tax audits.

For FRADECO, the conclusion is clear: e-invoicing is not “just IT”. It is VAT compliance plus process design. And in a German-French context, there is an additional layer: if you operate cross-border (e.g., a French entity with German VAT registration, a German group with French entities, shared service centers, centralized ERP landscapes), you must orchestrate invoice logic, master data, and validation rules consistently across borders — otherwise you create friction, reconciliation effort, and tax risk.

The new definition: e-invoice means “structured”, not “PDF”

The key shift first: in Germany, an e-invoice is an invoice that is issued, transmitted, and received in a structured electronic format — in a way that enables machine processing. The benchmark is the European standard EN 16931. In practice, that means XML-based formats, such as XRechnung or ZUGFeRD (with an EN-16931-compliant XML component).

A PDF therefore remains, in many cases, merely an “other invoice” — and not what the legislator means by an e-invoice.

Who is affected — specifically?

The obligation applies to B2B transactions where one business supplies another business for its business purposes, and where the supplies are taxable and subject to VAT in Germany. VAT-exempt supplies under Section 4 nos. 8 to 29 German VAT Act (UStG) are excluded.

German-French practice that is often overlooked:

• French companies with German B2B turnover (e.g., construction sites, installations, supply chains, services with a German place of supply) need e-invoicing in German logic — regardless of how invoicing is handled in France.
• Groups with centralized billing/ERP must implement German e-invoicing capability in templates, interfaces, and validation/control rules. “We have a group template” is rarely sufficient in practice.

Transitional rules 2025–2028: this is not a postponement — it is your project window

Implementation is phased. It may feel relaxed — but it is, in reality, a clear roadmap:

• 01/01/2025 to 12/31/2026: existing rules may still be used (paper / other electronic formats — in part subject to the recipient’s consent).
• 01/01/2027 to 12/31/2027: relief applies for issuers with total turnover ≤ €800,000 (prior year).
• from 01/01/2028: EN 16931 becomes standard operation for B2B — and the room for “other invoices” shrinks significantly.

Take-away: If you don’t use 2026/2027, you enter 2028 in live operation — and pay with time, risk, and internal friction.

Exceptions: yes — but please don’t build a strategy on them

The following remain permanently outside the strict e-invoice obligation, among others:

• Low-value invoices (Section 33 UStDV) and transport tickets (Section 34 UStDV): still possible in any format.
• Small businesses (Section 19 UStG): no e-invoice obligation on the outbound side; invoices may be issued as “other invoices” (paper/PDF etc.).

Important from a business perspective: especially in groups and platforms, supplier landscapes are mixed. That means: your inbound process must be able to handle e-invoices — even if not every supplier delivers perfectly from day one.

BMF 2024/2025: more clarity — and a clear focus on validation

The German Federal Ministry of Finance (BMF) explained the application of e-invoicing comprehensively and further specified it in 2025 (corrections, additions, examples, and practical guidance). The message is clear: technical quality and validation are becoming the standard.

Validation & input VAT deduction: this is where it becomes “tax-relevant”

The key point for Finance and Tax: for input VAT deduction, the XML file is decisive. Technology therefore becomes part of the invoice review — in addition to the classic review of mandatory invoice elements.

In practice, errors can be grouped into three categories:

• Format errors: the file does not comply with permitted technical specifications → risk that it is not an e-invoice; input VAT deduction may be jeopardized from 01/01/2028.
• Business rule errors: the file is an e-invoice, but “not compliant” → input VAT may only be deductible after correction.
• Content errors: classic substantive deficiencies (mandatory data, VAT rate, etc.) → not everything can be validated purely technically.

What follows: validation does not replace a commercial review — it becomes an additional control layer that should be integrated cleanly into the process. And: validation reports can be extremely valuable as evidence of a controlled process.

What does this mean for companies? A pragmatic implementation framework

To prevent e-invoicing from becoming a permanent construction site, you need a setup along the process chain:

A) Receipt & processing

• Technical receipt + correct processing in ERP/finance system
• Clear responsibilities (AP / Accounting / Tax / IT) — without “ping-pong”

B) Outbound invoices

• EN-16931-compliant formats (XRechnung / ZUGFeRD with XML)
• Clean master-data and mapping setup (VAT ID, tax keys, service descriptions, payment terms)

C) Review & governance

• Validation (tool/ERP module) + commercial review
• Documentation of logic and evidence (incl. validation reports)

D) Archiving

• GoBD-compliant archiving, including machine readability of the XML data

German-French perspective: why cross-border setups become complex faster

In a German-French environment, different invoicing realities collide: French processes and formats, German VAT logic, group-wide ERPs, shared service centers. That doesn’t make the topic harder in principle — but it makes it less forgiving.

This is exactly where FRADECO positions itself:

• VAT classification DE/FR: which transactions are taxable in Germany — and therefore e-invoice relevant?
• Process and system translation: translate requirements from Section 14 UStG / EN 16931 cleanly into ERP templates, workflows, and internal controls.
• Audit readiness: auditable documentation and robust routines for inbound and outbound invoicing, including error handling and correction processes.