What actually counts as an E-Rechnung
An E-Rechnung (electronic invoice) is an invoice issued, transmitted and received in a structured electronic format that allows the data to be processed automatically, without a person having to retype it. The legal definition, set out in §14 of the German VAT Act (Umsatzsteuergesetz), requires the invoice data to comply with the European semantic standard EN 16931 — a fixed set of data fields (amounts, tax rates, dates, parties) arranged so that software can read them directly.
The key word is structured. A human being being able to read an invoice is not the same as software being able to read it — an E-Rechnung has to satisfy the second condition.
XRechnung and ZUGFeRD, compared
Two formats dominate in Germany, and they solve the same problem differently.
| Format | What it is | Human-readable? |
|---|---|---|
| XRechnung | A pure XML file containing only structured data, with no visual layout of its own | No — needs a viewer or compatible software to display |
| ZUGFeRD | A hybrid PDF/A-3 file with the same structured XML data embedded inside it | Yes — opens and displays like a normal PDF |
XRechnung originated as the format required for invoicing German federal and state public administrations (B2G) and remains common there. ZUGFeRD's hybrid nature — a real PDF that a person can open, alongside embedded data that software can extract — has made it the more practical choice for many business-to-business (B2B) relationships, since the recipient doesn't need special software just to look at the invoice.
What an E-Rechnung is not
This is where most confusion happens, because these all look like "digital invoices" without meeting the legal definition:
- A PDF invoice sent by email. It's digital, but it's an image of an invoice, not structured data a system can read automatically.
- A scanned paper invoice. Same problem — scanning doesn't create structure.
- A Word or Excel invoice exported to PDF. Still just a formatted document, however tidy it looks.
Under the current transitional rules, these formats can often still be used for a limited time with the recipient's consent — but they are not E-Rechnungen in the legal sense, and that distinction is what determines whether a business is meeting its obligations. Our guide to why E-Rechnung is mandatory covers exactly when the transitional allowances run out.
Who needs to be able to receive one
Since 1 January 2025, every business established in Germany must be able to receive a structured E-Rechnung for domestic B2B transactions — this applies regardless of size, including freelancers and small Gewerbe. Being able to receive one and being required to issue one are two different obligations on two different timelines; see our guide on creating and sending an E-Rechnung for the practical side of issuing them.
Frequently asked questions
Is a PDF invoice sent by email an E-Rechnung?
No. A PDF is a digital image of an invoice, not structured data. An E-Rechnung must contain the invoice data in a structured, machine-readable format such as XRechnung or ZUGFeRD.
What is the difference between XRechnung and ZUGFeRD?
XRechnung is a pure XML format with no visual layout of its own, originally built for invoicing German public administrations. ZUGFeRD is a hybrid format: a normal PDF with the same structured data embedded inside it, so it can be read by a person and processed automatically by software.
What is EN 16931?
EN 16931 is the European semantic standard defining which data fields a compliant e-invoice must contain and how they're structured. Both XRechnung and ZUGFeRD comply with it.
Does a scanned paper invoice count as an E-Rechnung?
No. A scan is an image, not structured data, so it doesn't meet the legal definition regardless of how it's delivered.
Do I need special software to read an E-Rechnung?
For a pure XRechnung XML file, yes — you need a viewer or accounting software that can render it. A ZUGFeRD file opens like any ordinary PDF, so no special software is needed just to read it.