5 questions… about e-invoicing in direct marketing

The digitisation of accounting is becoming mandatory, and electronic invoicing (e-invoicing) is gradually becoming the norm in the B2B sector. This transition also brings significant changes for operators of renewable energy plants.

 June 2026

1. What is an e-invoice and what is the legal basis for it?

An invoice does not become electronic simply by converting it to a PDF – it must be in a structured, machine-readable XML format that allows for fully automated processing. The invoice must comply with the EU standard EN 16931; the XRechnung and ZUGFeRD formats are permitted. The ZUGFeRD format is an XRechnung plus PDF and is regarded as the standard for the B2B sector. An XRechnung is more of a standard for public authorities.

The obligation to use e-invoicing stems from the Growth Opportunities Act and the revised version of Section 14 of the Value Added Tax Act.[1] A breach has legal consequences: the invoice is considered an invalid ‘other invoice’, which jeopardises the right to deduct input tax. Furthermore, clauses such as ‘invoice by PDF’ will be invalid in contracts from 2027 onwards, and recipients may insist on receiving an e-invoice.

 

2. Who is required to issue e-invoices, and from when?

E-invoices will become mandatory for all businesses that generate domestic B2B turnover where both companies involved are resident in Germany for VAT purposes. This does not apply to B2C invoices, amounts under €250, tax-exempt transactions, or travel tickets.

The following deadlines apply to the introduction:

  • From 1 January 2025, every domestic company must be able to receive e-invoices. Refusal is not permitted.
  • From 1 January 2027, companies with a turnover of over €800,000 in the previous year must issue e-invoices.
  • From 1 January 2028, all companies must issue e-invoices.

 

3. What does e-invoicing mean for direct marketing, and what are its benefits?

Direct marketers and network operators usually issue credit notes. As these are treated as invoices for VAT purposes, our customers need to coordinate with service providers such as ourselves in good time and use compatible accounting software. We will send a ZUGFeRD invoice by email, giving our customers the greatest possible flexibility. Incidentally, in the case of negative amounts, we may need to issue two separate invoices.

The switch offers significant advantages, particularly in terms of error prevention and legal certainty: the settlement of electricity volumes, exchange prices and market premiums is automated via software interfaces. Manual entries via Excel or PDF are no longer required, which saves time and minimises errors. Furthermore, e-invoices comply with the EU standard and contain all mandatory information. This facilitates the correct VAT separation of taxable income, such as net proceeds from electricity sales, and non-taxable subsidies, such as the market premium.

 

4. What information must an e-invoice contain as a minimum?

All mandatory information in accordance with Sections 14 and 14a of the German Value Added Tax Act (UStG)[2] must be included in the structured data section. Attachments or free-text PDFs do not replace structured fields. The following are required:

  • Full name and address of both parties
  • Tax number or VAT number
  • Invoice date and sequential invoice number
  • Precise description of services
  • Amount payable, tax rate and tax amount
  • Where applicable, a reference to tax exemption
     

5. What practical steps do we recommend?

Of course, there are no official or legally mandated guidelines. However, when customers ask us, we recommend the following practical steps for implementation:

  • Check that your ERP and billing systems support XRechnung and ZUGFeRD.
  • Set up a central e-invoicing email address or suitable interfaces.
  • Review existing contract and terms and conditions relating to invoicing.
  • Adapt internal processes promptly, for example regarding the verification, approval and legally compliant archiving of invoices.

 

Do you have any questions about e-billing? Please feel free to get in touch!

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[1] https://www.bundesfinanzministerium.de/Content/DE/FAQ/e-rechnung.html und https://invoice-portal.de/de/neue-bmf-klarstellungen-zur-verpflichtenden-e-rechnung-was-sie-wissen-muessen/

[2] https://www.gesetze-im-internet.de/ustg_1980/__14a.html