E-invoicing: How is the term ‘e-invoicing’ defined?
An e-invoice is more than just an invoice in digital form. This article explains what makes it technically distinct and how it differs from an invoice that has been scanned or sent as a PDF
Introduction
Since the introduction of the e-invoicing requirement, the term ‘e-invoice’ has been clearly defined by law. Not every invoice sent digitally falls under this definition. This distinction is relevant to you in practical terms, as it determines whether an invoice meets the legal requirements – and we take this into account when posting it to the accounts.
A few clarifications first, as there are often misunderstandings surrounding this term: a scanned paper invoice is not an e-invoice. Nor is an invoice sent as a PDF via email. And an e-invoice is not ‘just for large companies with their own IT systems’.
The difference lies not in the method of delivery, but in the data format. An e-invoice contains the invoice data in such a way that a programme can read it directly. The following sections explain exactly what this means.
The legal definition
An e-invoice is an invoice that is issued, transmitted and received in a structured electronic format and can be processed electronically. The format must comply with the European standard EN 16931.
The key word in this definition is ‘structured’. In an e-invoice, every piece of information – invoice number, amount, tax rate, recipient – is contained within a defined data field. This means a programme knows exactly where to find the invoice amount and does not have to extract it from continuous text or an image.
It is precisely this structure that allows the data to be processed further without the need for manual data entry. For accounting purposes, this means that the details can be imported directly, thereby avoiding transmission errors or errors arising from text recognition when processing a scan or a PDF.
What the EN 16931 standard regulates
EN 16931 is a European standard that specifies which data fields an e-invoice must contain and how it is structured. It ensures that an e-invoice from Germany can be read according to the same rules throughout Europe.
The standard describes what is known as the semantic data model – in other words, the meaning of the individual fields. The specific formats you encounter in practice – XRechnung and ZUGFeRD – are based on this.
You do not need to know the standard in detail. In practice, it is sufficient to understand that every valid e-invoice – regardless of its format – complies with the same common data core as defined by EN 16931.
E-invoices and ‘other invoices’: the difference
Under the new definition, there have been two categories of invoices since 2025. The e-invoice is the structured, machine-readable variant. The legislator classifies everything else as an ‘other invoice’.
What counts as an e-invoice
Formats compliant with EN 16931 are regarded as e-invoices; in Germany, these are primarily:
- XRechnung – a pure XML file containing structured data
- ZUGFeRD (from version 2.0.1 onwards, excluding the MINIMUM and BASIC-WL profiles) – a PDF in which a structured XML data record is embedded
Both contain the same structured data core. We cover the differences and the choice of the appropriate format separately:
What counts as an ‘other invoice’
An ‘other invoice’ is any invoice that does not contain this structured data. These include:
- the traditional paper invoice
- a scanned paper invoice
- a standard PDF, even if sent by email
- a photograph or image of an invoice
The most common misconception concerns PDFs. A PDF looks digital and can be read on a screen – but its data appears as an image or text on the page, not in machine-readable fields. This means it is not an e-invoice.
A PDF with an embedded XML data set (ZUGFeRD) looks like an ordinary PDF, but is a genuine e-invoice. The file contains the structured data invisibly within it. You should therefore not rely on its outward appearance – only software or a verification tool can determine whether it is an e-invoice.
Why this distinction matters to you
This classification is not merely a technical quibble. It determines whether an invoice meets the legal requirements, and it can affect input VAT deduction.
If you issue invoices yourself, depending on your transition period, these must eventually be genuine e-invoices – a PDF will no longer suffice. If you receive invoices, from 2025 onwards it will be permissible for business partners to send you e-invoices, and you must be able to process them.
For day-to-day bookkeeping, please forward the original incoming e-invoice to us, not a printout. Only the original file contains the structured data that matters.
Common sources of error
- Confusing a PDF with an e-invoice: A standard PDF is mistaken for an e-invoice and sent as such. It does not comply with the format, which may lead to complaints from the recipient and during the transition period.
- E-invoice forwarded as a printout: The structured file is printed out and the printout is submitted. The machine-readable data is lost in the process, and the file must be obtained again.
- ZUGFeRD PDF not recognised as an e-invoice: A ZUGFeRD file is treated like a standard PDF and the embedded data record is ignored. The invoice is then not automatically read, even though it could be.
- Incorrect ZUGFeRD profile: A ZUGFeRD file in the MINIMUM or BASIC-WL profile is sent. These profiles are not considered full e-invoices because they do not contain all the mandatory details.
Frequently asked questions
Is a PDF sent by email an e-invoice?
No. A standard PDF is regarded as a ‘standard invoice’, regardless of how it is sent. Only structured, machine-readable data in accordance with EN 16931 constitutes an e-invoice.
Is a scanned invoice an e-invoice?
No. A scan is an image of the invoice. It does not contain any structured data fields and is therefore classified as a standard invoice.
How can I tell if I have received a genuine e-invoice?
You can recognise an XRechnung by the file extension .xml. With ZUGFeRD, the file looks like a PDF but contains structured data – only your software or a verification tool can reliably confirm this. We explain how to open and check an e-invoice separately. \[Link zu einem Hilfsartikel]
Are XRechnung and ZUGFeRD equivalent?
Both are legally recognised e-invoice formats in accordance with EN 16931. They differ in structure: XRechnung is a pure XML file, whilst ZUGFeRD is a PDF with embedded data. We discuss which format is best suited to which purpose in a separate article. \[Link zu einem Hilfsartikel]
As a small business, do I need to understand e-invoices?
You don’t need to master the technical structure – your software takes care of that. The only important thing is to have a basic understanding that a genuine e-invoice contains different data to a PDF, and that you forward the original file to us.
Will my existing paper invoices remain valid?
Yes. Invoices issued before the changeover remain valid and should be retained as before. The new definition applies to transactions from 2025 onwards.
What is EN 16931 in a nutshell?
EN 16931 is the European standard that specifies which data fields an e-invoice must contain and how it is structured – the common standard behind XRechnung and ZUGFeRD.
Legal notice
This article provides an overview and is not a substitute for individual advice. The legal situation and its interpretation may change; the current status at any given time is decisive.
If you have any questions about whether a specific document qualifies as an e-invoice, please contact us directly.
As at: June 2026