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E-billing is mandatory: These rules apply in 2025

From January 2025, e-billing will be mandatory for companies. Find out here what that means, how to create e-invoices and which legal framework conditions must be observed.

Tanja Hartmann
Content Marketing Manager
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Digitalization is advancing and is influencing more and more areas of our daily lives and business processes. Since January 2025, a significant change has been in force: e-billing is mandatory for companies. Here you can find out everything you need to know about the new regulations and what this means for your company.

New law since January 2025: e-billing mandatory for companies

Since January 1, 2025 Companies in Germany must issue and receive electronic invoices. This new law, the so-called E-billing regulation, aims to improve efficiency and transparency in accounting while reducing paperwork. For many companies, this means a significant change in their previous invoicing processes.

The e-invoicing obligation applies to all B2B transactions. Companies must therefore familiarise themselves with the new requirements at an early stage and adapt their systems accordingly in order to be prepared in good time.

E-invoicing requirement for domestic sales: Who is affected?

According to the Federal Ministry of Finance, the mandatory e-invoice applies exclusively to transactions between domestic companies. For foreign companies, the e-invoicing requirement only applies if a permanent establishment involved in the turnover exists in Germany.

A company is considered “domestic” if it has its registered office, management or a permanent establishment in Germany. This also includes free ports and certain bodies of water and mudflats in accordance with Section 1 (2) and (3) of the UStG — but not Büsingen and the island of Heligoland. If the company has no registered office, the domicile or habitual place of residence of the entrepreneur is taken into account instead.

The most important changes to the new e-billing regulation

Since January 1, 2025, new definitions and requirements for electronic invoices have been in force in accordance with the updated Sales Tax Act (UStG). The new regulations bring significant changes and clarifications that companies in Germany must comply with.

These are the key elements of the new legislative changes:

New Definitions Starting January 1, 2025, a distinction will be made between electronic invoices and other invoices.
Electronic Invoice An electronic invoice is an invoice that is issued, transmitted, and received in a structured electronic format, allowing for electronic processing. This format must comply with the European standard for electronic invoicing (CEN standard EN 16931).
Technology Neutrality Electronic invoice formats can be agreed upon between the issuer and the recipient, provided the required information can be correctly and completely extracted into a format-compliant format. This allows for EDI procedures as well.
Permissible Formats Formats such as XRechnung and the hybrid ZUGFeRD format meet the requirements. Other European formats like "FatturaPA" (Italy) or "Factur-X" (France) are generally permitted as well.
Hybrid Invoice Formats In hybrid invoice formats, the structured part takes precedence. Discrepancies between the image and structured parts may lead to issues under § 14c UStG (German VAT Act).
Other Invoices Paper invoices and invoices in other electronic formats (e.g., PDFs sent via email) will no longer be considered electronic invoices starting in 2025.
Preliminary Definitions The new definitions will take effect on January 1, 2025, even though the obligation to issue electronic invoices will apply later.


These changes are essential for adapting billing processes and ensuring compliance with new legal requirements.

All information about the background & expert meeting in Brussels

The decision to introduce electronic invoicing was made at European level. At an expert meeting in Brussels, the benefits and challenges of e-billing were discussed intensively. The aim is to create uniform standards across Europe to facilitate cross-border trade and simplify administrative processes.

This initiative is part of a larger EU digitization strategy aimed at strengthening the single market and increasing the competitiveness of European companies.

Overview: What is an e-invoice?‎

In general language and depending on the area of law, the definition of an e-bill varies. According to EU Directive 2014/55/EU, this is a structured data set for automated processing. Tax law, on the other hand, has also allowed pictorial representations such as PDFs to date, but this is changing with the new Growth Opportunities Act, which requires a structured electronic format in accordance with EN16931.

ℹ️ Important:

Since 2025, an invoice sent via e-mail as a PDF is no longer considered an electronic invoice!

Digitize invoices: All benefits at a glance!

Invoices are of central importance in business transactions, both in the B2B, B2C and B2G sectors. By digitizing and automating invoicing processes, companies can realize significant savings potential.

The use of e-invoices offers numerous practical benefits, in particular through the use of structured data sets:

  • Smooth processing: Error-prone manual entries are superfluous, which increases data quality.
  • Shorter turnaround times: Invoices can be processed and paid more quickly.
  • Less paper usage: The switch to digital invoices significantly reduces paper consumption.
  • Elimination of postage costs and transport routes: E-invoices save postage costs and are immediately transferable.
  • Automated processes: Depending on the level of automation, e-invoices can be read, assigned, checked, posted and ordered to pay electronically.

These benefits contribute to more efficient structures and significant cost savings in companies.

When does the new e-billing obligation come into force?

The obligation to issue and receive e-invoices came into force on January 1, 2025.

These transition periods apply to B2B transactions in Germany

The introduction of e-invoices in accordance with the Growth Opportunities Act poses challenges for companies for which transition periods are foreseen. These regulations relate in particular to the issuance and receipt of invoices in various formats:

By the end of 2026: Companies are still allowed to issue paper invoices for B2B sales. Electronic invoices are also allowed. As long as they do not comply with the new format, however, the consent of the invoice recipient is required.

By the end of 2027: Smaller companies with a total turnover of up to 800,000 EUR in the previous year are granted an extension to issue invoices in paper form or another electronic format.

From 2028:
From this point on, all companies must comply with the new e-billing requirements. It is then no longer permitted to use other electronic formats such as EDI for invoicing, unless there is a specific exemption.

These transition periods should enable a gradual transition and ensure that companies can adapt their processes accordingly to meet the new legal requirements.

Who is affected by the change?

The obligation to issue e-invoices from 2028 concerns only services between entrepreneurs (B2B), regardless of whether the company is run as a main or a sideline. Both the provider and the recipient of the service must be resident in Germany, although this may be the case through registered office, management or a permanent establishment (participating in the relevant turnover) in Germany.

ℹ️ Important:

According to the current situation, landlords would also be required to issue an e-bill if they rent to other companies subject to tax. To date, for example, the rental agreement could also be used as an invoice. Under the new law, this would no longer apply!

What do bill recipients have to pay attention to since January?

Since January 1, 2025, domestic companies as invoice recipients must be able to receive and process electronic invoices in accordance with the new requirements if their suppliers want to send them. Unlike before, receipt of the “new” e-bill no longer requires explicit consent, unless the invoice does not comply with the new standards or there is no e-invoicing requirement (e.g. for certain tax-free transactions or small amount invoices). Invoices to end users (B2C) still require their consent to electronic invoicing.

Mandatory information: What is included in an e-bill?

Every business invoice, whether on paper or electronic, must contain certain mandatory information in order to meet the requirements of sales tax law.

The following information is decisive for the invoice recipient's input tax deduction and recognition by the tax office:

  • Full names and addresses of the supplier and service recipient
  • Consecutive invoice number
  • Date of issue of invoice
  • Quantity and type of goods delivered or scope and type of other service
  • Time of delivery or service (if different)
  • Payment for delivery or other service, in each case and net and gross
  • Applicable tax rate and tax amount or reference to tax exemption
  • Tax number or one for the company

Flexibility, transparency & efficiency with ZEP: The best software support for e-invoices & your company!

With ZEP, you get a powerful software solution that helps you to invoicing to design efficiently and at the same time respond flexibly to individual requirements. The functions for managing additional project and customer fields enable you to predefine standardized data for each invoice and adjust it as required.

The best thing is that with the Invoicing module, you meet all e-billing requirements!

As part of the transition to e-billing, you will benefit from the following benefits in ZEP:

Customizable Additional Fields 📊 Create custom fields for projects and clients that are automatically displayed on every invoice.
Easy Customization Options 🖥️ Customize pre-set data depending on the project or client and modify it as needed for each invoice creation.
Integration of ZUGFeRD Format 📧 Optionally create invoices in the ZUGFeRD format to ensure standardized and simplified invoice processing.
Update Company Information 🌐 Manage your company information centrally under "My Company" in the master data to ensure that all invoices always contain up-to-date data.


ZEP therefore not only offers you transparency and efficiency, but also the necessary flexibility to optimally support your business operations and meet the requirements of e-billing.

Archiving e-invoices: How long do you have to keep documents

Electronic invoices are subject to the same storage requirements as paper documents. In Germany, invoices must be archived for at least ten years. It is important that archiving is audit-proof so that the documents are stored in a system for document management are available in full and unchanged at any time.

Transmission of e-invoices: What transmission methods are there?

Currently, in the new legal regulation, there are no specific requirements the transmission channel for electronic invoices. It therefore appears to be sufficient to first receive an electronic invoice via an e-mail inbox.

Are there any exceptions to the obligation?

In certain cases, there is no obligation to issue an e-invoice in accordance with current requirements. Small amount invoices in accordance with Section 33 UStDV and tickets in accordance with Section 34 UStDV can still be sent as “other invoices”, for example in paper form. For small amount invoices, the total amount is decisive:

ℹ️ If the invoice amount is less than 250 EUR, services that would otherwise have an e-billing obligation can also be treated as other invoices.

Conclusion

Digitalization is advancing and is influencing more and more areas of our daily lives and business processes. From January 2025, a significant change will come into force: e-billing will become mandatory for companies. This new regulation, known as the e-billing regulation, aims to improve efficiency and transparency in accounting while reducing paperwork. For many companies, this means a significant change in their previous invoicing processes.

Since January 1, 2025, companies in Germany must issue and receive electronic invoices. This Act introduces new definitions and requirements, including the use of standardized formats such as XRechnung and ZUGFeRD. Companies should prepare early on to adapt their systems and ensure that they meet regulatory standards.

These changes are essential for adapting billing processes and ensuring compliance with new legal requirements. Companies can use software solutions such as ZEP to create legally compliant e-invoices in the required formats. ZEP offers functions for managing projects and customers, which enable companies to organize their invoicing efficiently and respond flexibly to individual requirements.

FAQs

Is a PDF Invoice an e-Invoice?

No, as of January 2025, PDF Invoices will no longer be considered e-invoices in accordance with the new e-billing regulation. An e-invoice must be issued, transmitted and received in a structured electronic format that enables electronic processing and meets the requirements of CEN standard EN 16931.

How do I create an e-invoice?

To create an e-invoice, companies must use a structured electronic format that meets legal standards, such as XRechnung or ZUGFeRD. The invoice must contain all required mandatory information and can be generated using special software solutions such as ZEP, which make it easier to comply with the standards.

Is an invoice sent by email legally valid?

Yes, an invoice sent by email is generally valid. However, from January 2025, electronic invoices must meet the new requirements in order to be considered an e-bill. It is important to ensure that the invoice contains all required mandatory information and is submitted in a structured electronic format that allows automated processing.

Welche Rechnungsformate sind für elektronische Rechnungen zulässig?

Rechtskonforme E-Rechnungen können in Formaten wie XRechnung, ZUGFeRD oder nach Vereinbarung in anderen EN 16931-konformen Formaten versendet werden.

Wie kann ich eine E-Rechnung schreiben und versenden?

Mit modernen Softwarelösungen wie ZEP können E-Rechnungen komfortabel erstellt, an individuelle Vorgaben angepasst und rechtssicher im passenden elektronischen Format (z. B. ZUGFeRD) versendet werden.

Was passiert, wenn ich 2025 keine E-Rechnung ausstelle?

Wer als B2B-Unternehmen keine E-Rechnung ausstellt, riskiert die Nichtanerkennung der Rechnungen durch das Finanzamt und mögliche Sanktionen. Rechtssichere E-Abrechnung ist daher für Unternehmer Pflicht.

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