E-invoicing: Sector-specific considerations for the healthcare professions (e.g. doctors, alternative practitioners)
For healthcare professionals, e-invoicing is generally not a cause for concern: tax-exempt medical treatments are excluded. However, this article explains which services may be affected.
Introduction
If you work in a healthcare profession, you may be wondering whether the e-invoicing requirement applies to your practice. In most cases, it does not – and we’ll explain when it does.
First, a clarification, as there is a common misconception here:
It is not the case that all medical invoices are subject to the e-invoicing requirement. Typical medical treatment is exempt from VAT – and VAT-exempt services are excluded from the e-invoicing requirement.
What matters is the distinction between tax-exempt medical treatments and taxable services. Only the latter may fall within the scope of the regulations at all.
This article explains the exemption for medical treatment, how it differs from taxable services, and what applies to recipients.
Tax-exempt medical treatments are exempt
The key point for healthcare professions: medical treatments in the field of human medicine are exempt from VAT under Section 4(14) of the German VAT Act (UStG). This applies to doctors, dentists, alternative practitioners, physiotherapists, midwives and similar healthcare professions, provided that the therapeutic purpose is the primary focus.
Tax-exempt transactions are exempt from the e-invoicing obligation. You therefore do not need to issue an e-invoice for the actual medical treatment itself.
Nothing changes for typical medical treatment. It remains exempt from VAT and is therefore not subject to the e-invoicing requirement.
When it becomes taxable
Not every service provided in a practice constitutes tax-exempt medical treatment. Some services are subject to VAT – and only these may be subject to the e-invoicing requirement at all.
These typically include individual healthcare services without a medical indication, such as purely cosmetic procedures, certain expert reports without a therapeutic purpose, and the sale of goods such as medicines from a practice dispensary. Whether a service is VAT-exempt or subject to VAT depends on the individual case and is not always clear-cut.
Even if a service is subject to VAT, e-invoicing is only an option in dealings with businesses (e.g. occupational health services). A service subject to VAT provided to a private patient remains excluded, as invoices to private individuals are generally not covered by the e-invoicing requirement.
Two conditions must be met
For a medical invoice to be classified as an e-invoice at all, two conditions must be met. This significantly limits the number of cases affected.
Firstly, the service must be subject to VAT – tax-exempt medical treatment is excluded.
Secondly, the invoice must be issued to a business, not to a private patient. A practical example would be a taxable expert report for an insurance company or a business.
| Scenario | E-invoice? |
|---|---|
| Tax-exempt medical treatment (private patient or health insurance fund) | No, excluded |
| Taxable service provided to a private individual | No, except for B2C |
| Taxable service provided to a business | Yes, after the deadline has passed |
What about receipt?
Regardless of who issues them, the following applies: if you are in business, you must be able to receive incoming e-invoices – for example, from suppliers of practice supplies, equipment or services.
This obligation to receive e-invoices also applies even if your treatment services are tax-exempt. All you need to receive them is an email inbox; we’ll take care of processing them.
We cover how to receive e-invoices separately:
Submission to us
For processing, we require your incoming invoices and – where available – your taxable outgoing invoices in their original formats.
The documents are submitted via the method agreed with us, such as DATEV Unternehmen Online or another document exchange solution. If you are unsure whether a service is tax-exempt or taxable, we will clarify this together.
Common sources of error
- Assumption that all medical bills are affected: Tax-exempt medical treatments are excluded. Only taxable services provided to businesses may be subject to e-invoicing.
- Failure to distinguish between tax-exempt and taxable services : IGeL services or expert reports are treated as medical treatments across the board. However, the classification may differ.
- B2C overlooked: Even in the case of a taxable service provided to a private patient, an e-invoice is not required. Only services provided to a business trigger the obligation.
- Not prepared to receive e-invoices : There is no way to receive e-invoices from suppliers. The obligation to receive e-invoices also applies to tax-exempt medical treatments.
- Only a printout is provided: An incoming e-invoice is printed out and passed on. We require the original structured file.
How we work together
In the healthcare sector, we work together to clarify whether a service is tax-exempt or taxable; you ensure the e-invoice is received, and we handle the processing.
Your tasks:
- Issue e-invoices for taxable services to businesses, where the obligation applies
- Ensure the receipt of e-invoices, at least via an email inbox
- Provide us with the supporting documents in their original format via the agreed method
Our tasks:
- Check the distinction between tax-exempt and taxable services
- Post the supporting documents and classify them for tax purposes
- Provide support with any questions regarding format or receipt
We will agree the exact breakdown with you.
Frequently asked questions
Are all medical invoices subject to the e-invoicing requirement?
No. Tax-exempt medical treatments under Section 4(14) of the German Value Added Tax Act (UStG) are excluded. Only taxable services provided to businesses may be subject to the e-invoicing requirement.
Which services are subject to tax?
Typically, these include individual healthcare services without a medical indication, certain expert reports without a therapeutic purpose, or the sale of goods. The classification depends on the individual case.
Do I have to issue an e-invoice to a private patient?
No. Invoices to private individuals are generally not subject to the e-invoicing requirement – even in the case of a taxable service.
Do I have to be able to receive e-invoices?
Yes, if you are carrying out business activities. The obligation to receive e-invoices also applies even if your treatment services are tax-exempt. An email inbox is the minimum requirement.
When do I actually need an e-invoice?
Only if both conditions are met: a taxable service and a business recipient. A taxable expert report for a company is one such case.
How do I send my supporting documents to you?
In their original format via the agreed method, usually via DATEV Unternehmen online or an upload address. If there are any questions regarding classification, we will clarify the categorisation together. \[Link zu einem Hilfsartikel]
Legal notice
This article provides an overview and is not a substitute for individual advice. The VAT classification of healthcare services depends on the individual case; the current legal position is decisive.
If you have any questions regarding your practice’s services, please contact us directly.
As at: June 2026