E-invoicing: technical implementation on marketplaces (e.g. Amazon, eBay)
Anyone selling via Amazon or eBay remains responsible for their own invoices – the marketplace does not relieve you of your obligation to issue e-invoices.
Introduction
If you sell via a marketplace such as Amazon or eBay, the question arises as to who is responsible for e-invoicing. The clear answer is: you, as the seller. We’ll show you the right way to do it and take care of the tax processing.
A clarification first, as there is a common misconception here:
Even if you sell exclusively via a marketplace, you cannot pass on the responsibility for invoicing to the marketplace.
Amazon makes this clear itself: sellers who do not use the invoicing tool remain responsible for issuing compliant e-invoices.
It’s also crucial to consider who you’re selling to. Different rules apply to private customers than to business customers – and it’s precisely this distinction that can be tricky on marketplaces.
This article explains your responsibilities, the distinction between customer types and the straightforward approach using a suitable invoicing tool.
The responsibility lies with you
The most common misconception is that the marketplace takes care of everything. This is not the case. The obligation to issue a proper invoice lies with the seller.
Marketplaces do offer invoicing services – Amazon, for example, provides an invoicing service or a VAT calculation service. For sales to private customers, such a service is often sufficient. However, you cannot rely on it for business-to-business transactions, as the marketplace does not guarantee that it will provide valid, structured data in good time for every domestic business customer.
‘The marketplace will sort it out’ is not a reliable basis. If you continue to send business customers nothing more than simple PDFs, you risk the invoice being rejected because the customer cannot claim input tax deduction from it – leading to payment delays and problems during a tax audit.
B2C and B2B – the crucial distinction
Whether you need an e-invoice depends on the type of customer. It’s worth taking a closer look here, as the two scenarios differ significantly.
Nothing changes for sales to private customers. A standard invoice or receipt remains acceptable; an e-invoice is not required. As private customers account for the majority of marketplace business, there is no immediate need for action here.
For sales to domestic business customers, the obligation applies in full. Once your transition period has expired, they must receive a genuine e-invoice in the XRechnung or ZUGFeRD format.
The specific challenge on marketplaces
Marketplaces present an additional difficulty that does not exist in your own shop: at the time of ordering, you often do not know whether the buyer is purchasing as a business.
B2B status often only becomes apparent after the order has been placed. This means you cannot always decide at the time of sale whether a standard invoice is sufficient or whether an e-invoice is required.
This creates a need for a system that automatically recognises who the customer is and generates the correct format for business customers. This is exactly where ‘Saubere Wege’ comes in.
The ‘clean’ approach
There are two viable ways to ensure legally compliant e-invoices on marketplaces.
The first involves using an invoicing tool specialising in marketplaces, which connects to Amazon or eBay, recognises the customer type and automatically generates an e-invoice for business customers. The second involves integrating your order data with accounting or invoicing software that generates e-invoices natively. We cover which programmes generate e-invoices in separate articles.
Which solution is right for you depends on your marketplaces, your order volume and the proportion of business customers you have. We list tool categories for guidance, not as a recommendation of a specific provider, and will look at your specific situation together.
What about receiving e-invoices?
The obligation does not apply solely to issuing invoices. As a business, you must also be able to receive incoming e-invoices – for example, from your suppliers.
The marketplace is not the tool for this. At a minimum, an email inbox is sufficient for receiving e-invoices; we or your accounting software will handle the processing. We’ll cover how to receive e-invoices separately. \[Link zu einem Hilfsartikel]
Submission to us
For processing, we require the original structured data from your invoices, not just the marketplace documents.
If the e-invoice originates from a marketplace tool or your accounting software, please forward the original file to us via the agreed method – such as DATEV Unternehmen Online or an alternative solution for document upload.
Common sources of error
- Responsibility handed over to the marketplace: It is assumed that Amazon or eBay will take care of the invoice. The obligation lies with the seller.
- Marketplace receipt used for B2B: A simple invoice is sent to a business customer. For B2B, a genuine e-invoice format is required once the deadline has passed.
- B2B status not recognised: There is no system in place to recognise business customers. As a result, the incorrect document format is generated for B2B orders.
- Only simple PDFs sent to businesses: Business customers continue to receive only PDFs. This can lead to rejection and problems with input tax deduction.
- Only the document is transferred: The marketplace document is used for transfer to us. We require the structured data.
How we work together
For marketplace sales, you set up a suitable invoicing tool; we advise on the solution and handle the processing.
Your tasks:
- Integrate a marketplace tool or transfer the order data to accounting software
- Ensure that business customers receive an e-invoice
- Transfer the original structured data to us via the agreed method
Our tasks:
- Determine which method is best suited to your marketplace business
- Post the documents and classify them for tax purposes
We will agree the exact breakdown with you.
Frequently asked questions
Does Amazon or eBay handle my e-invoices?
No. The responsibility lies with the seller. Amazon itself makes it clear that sellers who do not use the invoicing tool remain responsible for compliant e-invoices.
Is the Amazon invoicing service sufficient?
For sales to private customers, often yes. For business customers, it is risky because the marketplace does not guarantee that it will provide valid, structured data in good time for every domestic business customer.
Do I need an e-invoice for every marketplace sale?
No. Not for private customers. For domestic business customers, the obligation applies once their transition period has expired.
How can I tell if a buyer is a business?
On marketplaces, this is often only apparent after the order has been placed. That’s why you need a tool that recognises the customer type and generates the correct format for business customers.
What happens if I only send PDFs to business customers?
You risk the invoice being rejected because it does not allow for input tax deduction – leading to payment delays and potential problems during a tax audit.
How do the invoices reach you?
Via the agreed method, usually DATEV Unternehmen online or an upload address. It is important that the structured data reaches us. \[Link zu einem Hilfsartikel]
Legal notice
This article provides an overview and is not a substitute for individual advice. The scope of functions and invoicing services offered by Amazon, eBay and the tool categories mentioned are subject to change; the current status of the providers and the legal situation at any given time shall prevail.
If you have any questions about which approach is best for you, please contact us directly.
As at: June 2026