E-Rechnung without the typing: what a German firm must receive, issue and stop rekeying

What actually changed, and what did not

The change is a definition, and everything else follows from it. § 14(1) UStG now says an electronic invoice is one issued, transmitted and received in a structured electronic format that permits electronic processing. Anything transmitted in another electronic format, or on paper, is a sonstige Rechnung. The structured format has to match the European norm for electronic invoicing under Directive 2014/55/EU, or be agreed between the two parties provided the required data can be extracted correctly into something that norm-compliant systems can read.

So the single most common belief about this rule is wrong. A PDF sent by email is not an electronic invoice in the sense of the statute. It is a sonstige Rechnung that happens to travel electronically. That distinction is the whole reform: the law is not asking you to stop printing, it is asking for a data file that software can read without a human retyping the contents into an accounting system.

What did not change is who you work with. Nothing in this reform asks you to leave DATEV, Lexware or whatever your Steuerberater has standardised on. Those systems already read and write the formats above. The gap the reform exposes is not in the accounting software: it is in the twenty minutes a day somebody spends moving data between an inbox and that software by hand.

The dates, and who each one applies to

Three dates matter, and only one of them has already passed. The transitional rules live in § 27(38) UStG rather than in § 14, which is why so much secondary reporting gets them slightly wrong. Each row below names the provision it comes from so you can check it in about a minute.

Two details in that threshold catch people out. It is measured on the previous calendar year, so the year that decides your 2027 obligation is 2026, which is running now. And it is a test on the issuer, not on the customer: a small firm invoicing a large one is judged on its own turnover, not on its client's.

What "must be able to receive" actually obliges you to do

Less than the software industry has been telling you, and more than doing nothing. The Bundesfinanzministerium is unusually direct about the minimum in its letter of 15 October 2025: domestic businesses must create the technical conditions to receive an e-invoice, this applies to Kleinunternehmer as recipients too, and where the invoice arrives by email no separate mailbox just for e-invoices is required. Your existing inbox is a compliant receiving channel.

What you cannot do is decline. Issuing an e-invoice to another domestic business does not require the recipient's agreement, and the recipient has to create the conditions to take it. The same letter says that a business which is technically unable to receive one, or refuses to accept it, has no right to be sent a substitute invoice in another form, and that the issuer's VAT obligations count as fulfilled where they can show they tried to deliver it properly, for example with a send log.

So the honest floor for 2026 is small. A receiving address that a person actually monitors, a viewer that renders XRechnung and ZUGFeRD so a human can read what arrived, and a filing rule so the XML itself is retained rather than a printout of it. That is the compliance job. Everything after this section is the opportunity, and it is optional.

Where the typing goes, if you let it

A structured invoice is a data file that arrived by email, and data files do not need a typist. The same rule that creates the chore removes the reason anybody was rekeying supplier invoices, because the fields you used to copy are now labelled fields in a document your systems can read. The pipeline that replaces the typing has four stages, and the last one is the only one a person should still touch.

1. Capture. Everything that arrives in the invoice inbox is picked up, structured or not. Structured files are parsed directly. PDFs and paper are read the old way, because you will keep receiving both for years and a pipeline that only handles the compliant half is not a pipeline.
2. Coding. Supplier, cost centre, tax rate and account are proposed from the invoice data and from what happened last time the same supplier billed you. This is the stage that used to be the twenty minutes, and it is the stage where the structured format earns its keep.
3. Validation. The file is checked against the norm and against the business rules before anything is booked. Failures split into two kinds, which is the subject of the next section, and only one of the two kinds is worth a human's attention.
4. Handover. The booked and coded records go to the accounting system your Steuerberater already uses, in the shape they already expect. Nothing about their month-end changes except that it starts with fewer corrections.

The arithmetic on the second stage is the one worth doing before you commit to anything. A firm handling 150 supplier invoices a month at around six minutes of handling each is spending something close to 15 hours a month on it, and that model is editable rather than asserted. Put your own volume, your own handling time and your own hourly rate into the invoice calculator and see what the number looks like at your scale. If it comes out small, do not automate it, and we will say so before you ask.

The invoices that fail validation, and why the last tenth is a design decision

The Bundesfinanzministerium draws a line that most software does not surface, and it is the useful line. A format error means the file does not meet the structural requirements of § 14(1) at all: it is then not an e-invoice but a sonstige Rechnung, with all the consequences that follow. A business-rule error means the file is structurally fine but its contents are incomplete or contradictory, for example a missing entry in the mandatory BT-10 buyer reference field of an XRechnung, or a tax amount that does not reconcile with the stated rate. Those surface as critical errors during validation.

The two need different handling and almost nobody separates them. A format error is a conversation with the supplier, because they sent you the wrong kind of document. A business-rule error is a correction, and often a correction you can make a confident proposal for. Routing both to the same review queue is how firms end up believing that automated invoice processing does not work for them.

Which is why the number we quote for automatic capture is deliberately conservative. We state around 90% of documents auto-captured with the remainder routed to a human by design, and the second half of that sentence is the part that matters. The residue is not a failure rate to be squeezed towards zero. It is the set of documents where a person should look, and building the pipeline so that set is visible, small and worked daily is the actual job.

The checklist, ordered by when each item stops being optional

Nothing here needs new accounting software, and most of it is an afternoon. Work down until you reach the first item you have not done. That is where you are.

1. Already overdue: a monitored receiving address, and a viewer. One address that a named person checks, and something that renders XRechnung and ZUGFeRD legibly. Without the second half, a compliant invoice is indistinguishable from a broken attachment.
2. Already overdue: retain the XML, not a printout. The original structured file is the invoice. A PDF rendering of it is a picture of the invoice. Archive the file that arrived, in the form it arrived in.
3. Before the end of 2026: check your 2026 turnover against the threshold. The previous calendar year decides which side of 1 January 2027 you are on, and 2026 is the year being measured while you read this. If you are near the line, plan for the earlier date.
4. Before the end of 2026: agree the format with your Steuerberater, not with a vendor. They will have a preference, it will be well founded in what their practice software handles at volume, and following it costs you nothing.
5. During 2027: switch issuing over, in a quiet month. If you are above the threshold this is a hard date. If you are below it you have a year of slack, and using that slack to go early is the cheapest version of this project, because nothing is on fire.
6. Whenever you like: take the typing out of the middle. This is the only optional item on the list, and it is the only one that pays anything back. Everything above it is the cost of staying legal.

The handover your Steuerberater actually needs

This is where German firms feel the reform, and it is a relationship question before it is a technical one. Your tax adviser is not an obstacle to automating invoice handling. They are the constraint that makes it worth doing properly: they already know which fields have to be right, which suppliers habitually get them wrong, and what a clean month looks like. Ask them what shape they want the data in and build to that, rather than presenting them with an export from a tool they have never seen.

And if you want the whole picture for a firm like yours before committing to any of it, start with the smaller of the two analyses. The free analysis looks at the surfaces where a German firm usually leaks time, invoice handling included, and reports what it finds with the method shown rather than as a score. The tax-adviser page walks the same ground for a Steuerberater's own practice rather than for their clients.