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EN 16931: Are you really ready for mandatory e-invoicing?

Written by Marie-Josée Ruhm | Jul 30, 2024 8:44:34 AM

It's official: mandatory e-invoicing will be introduced in Germany from 2025. This poses a huge challenge for companies that are not yet prepared: How will processes change? What are the technical requirements? Where exactly do you still need to act in your invoicing process according to the EU standard EN 16931? But don't worry, this article will not only help you get your business ready for e-invoicing, but it will also help you realize the full potential of the changeover.


In this blog post, you will find out

  • What the legal deadlines and frameworks are for receiving, processing and sending invoices in terms of invoice types and formats.
  • Which invoices and companies are not yet affected by the e-invoicing obligation, and which formats need to be addressed most urgently.
  • An as-is and to-be analysis in the three key areas of your invoicing process: invoice dispatch, system landscape, invoice content.
  • the specific recommendations for your company.

Finally, we show you a procedure that makes the technical implementation of EN 16931-compliant e-invoicing child's play for your company.

1. Framework and timetable for the introduction of EN 16931 compliant e-invoicing in Germany

To understand what the introduction of mandatory e-invoicing means for your company, you need to know the timeline and framework. These are precisely defined by the German legislators to ensure a comprehensive and smooth implementation. You can then use this information to determine the specific action you need to take. There are different deadlines depending on the format. If you are already using only electronic invoice formats, you should also check whether they are already fully compliant with the EU standard EN 16931. You may need to make improvements in one area or another.


a. Timetable for full implementation of EN 16931 compliant e-invoicing

The introduction of e-invoicing should be gradual. This allows companies sufficient time to adapt their systems and processes to ensure a smooth transition. The transition periods for e-invoicing distinguish between sending and receiving e-invoices. For receiving e-invoices, there are no exceptions:

From 1 January 2025, all businesses and public authorities must be able to receive and process e-invoices. This means that the invoice recipient must be able to visualize and archive the XML record for further processing. The visualization of the records is typically done within (ERP) systems.. The KoSIT (Coordination Centre for IT Standards, in German Koordinierungsstelle für IT-Standards) also offers a visualization component. These are publicly available in the XRechnungs-GitHub. If system-supported and automated invoice processing is not possible, the use of a visualization solution is recommended to better identify potential errors. DThis means that your systems and internal processes need to be fully EN 16931 compliant by then at the latest.


As far as dispatch is concerned, the e-invoice will be introduced in stages:

  1. The dispatch of paper invoices and electronic invoice formats (e.g. PDF, EDI) that are not EN 16931 compliant will be permitted until the end of 2026. The transitional period is intended to give all businesses concerned the time they need to adapt their systems and processes to the e-invoice format.
  2. From 1 January 2027, e-invoicing will be mandatory in the B2B sector. From this date, all companies will have to issue e-invoices to their business partners. Non-EN 16931 compliant formats can still be sent after this date. However, this is only permitted with the explicit consent of the recipient. You must therefore communicate directly with your customers and suppliers. You should also check that your partners also meet the requirements of EN 16931.

Important to know: Invoice senders must also be able to visualize both the XML record and the original invoice as part of their accounting processes. This functionality can either be integrated into an e-invoicing system or provided by a separate, dedicated visualization solution.


b. Framework conditions that an e-invoice must fulfil in order to comply with the EU standard EN 16931

As far as the technical framework is concerned, the e-invoice in Germany is based on the XRechnung standard. This is an XML-based syntax. Two variants are permitted: Cross Industry Invoice (CII) and Universal Business Language (UBL). They also comply with the EU standard EN 16931. Currently (as of 15/07/2024), only version 3.0.1 of the XRechnung standard is permitted. The use of extensions to map extended information is allowed.

An essential e-invoice format that complies with the XRechnung standard is ZUGFeRD (Central User Guide of the German Electronic Invoice Forum, in German Zentraler User Guide des Forums elektronische Rechnung Deutschlands). Its big advantage is that it can store both human-readable and machine-readable invoice data in one document. This hybrid format combines a classic PDF invoice with an integrated XML file. It was developed by the German Electronic Invoice Forum (FeRD) to comply with the EU standard EN 16931. ZUGFeRD can be used in different business scenarios (B2B, B2G, B2C). It is therefore a versatile solution for companies and public authorities that need to automate their invoicing processes. ZUGFeRD is currently approved from version 2.0.1 to the latest version 2.2 (Basic, EN 16931 and Extended profiles).

If the receiving and sending of e-invoices in your organization is not yet compliant with EU Standard 16931, you need to act. However, there are certain exemptions for which the e-invoicing requirement is also being phased in.


c. Who is not affected by the e-invoicing obligation (for the time being)?

The e-invoicing obligation applies to all invoice issuers and recipients, regardless of whether they operate in the private or public sector. This means that companies providing services to other companies or to public authorities will have to switch their invoicing processes to e-invoicing. The same applies to public authorities receiving services from businesses.

However, there are exceptions for certain sectors where it is not yet possible or practical to use e-invoicing:

  • Small businesses that do not have the necessary digital infrastructure. Therefore, a transitional period until December 2027 will apply to companies with an annual turnover of no more than €800,000 in 2026.
  • Invoices under €250 are completely exempt from the e-invoicing obligation under Section 33 UStDV.
  • Tickets according to § 34 UStDV
  • Invoices to consumers are also exempt from the e-invoicing obligation.
  • Areas in which the exchange of paper invoices is still required by law

2. First steps for the introduction of EN 16931 compliant e-invoicing in your company

It is now clear that the e-invoicing obligation is coming in stages and if you have not already done so, you need to prepare your company. The first step is to assess the status quo in your organization and determine the first steps you need to take.


Step 1: Status of invoicing

The first step is to look at the channels and formats you use to send and receive invoices. This will also show you the frequency with which this is done. A simple table will help you get a quick overview:



Once you have completed this table for yourself, you will immediately see whether you are on track. If you still need to act, you will also see how extensive this change will be. You can also immediately see where the biggest challenges lie. For example, if you are still sending and receiving a lot of paper invoices, you should prioritize the changeover. This is where the deadline is the shortest (until 12.2026). Simple PDF, EDIFACT and other electronic formats with structured data, but which do not comply with the EU standard EN 16931, have a second priority (until 12.2027).


Step 2: Status of the system landscape

The next step is to identify the relevant systems and interfaces that need to be considered to send and receive invoices in compliance with the EU standard. To do this, you need to determine what additional data is required to create e-invoices. This is the only way to ensure seamless integration with your financial accounting, ERP, archiving and document management systems. You should also make sure that the data contained in the e-invoice is stored correctly in your systems, such as financial accounting and ERP.

This is not just about correctly reading and recognizing the structured data from an e-invoice. Correct decoding of XML and process-related storage are equally important. It is also essential to ask whether you already have an EN 16931 compliant version of your accounting/ERP system. If this is the case, you should check carefully that you are compliant with the requirements of your organization and industry. You should also check that the EN 16931-compliant codes are correctly translated into your target systems. They should also be stored in such a way that accounts payable can work with them seamlessly. This applies to the invoice type, invoice-related attachments and units of measure.


Step 3: Status of invoice content

Finally, you should check whether the content of your e-invoices complies with EN 16931. We have prepared the following checklist for you:

  • Have the correct syntaxes been chosen? (Cross Industry Invoice (CII) or Universal Business Language (UBL))
  • Are all mandatory details present and correctly displayed?
  • Does the formatting comply with legal requirements? (e.g. date, amounts)
  • Is the information presented in the correct order?
  • Are the stated values of EN 16931 compliant? Are there no negative amounts for dates and amounts?
  • What processes are implemented in your system for handling attachments? What are the processes for detection, embedding and de-embedding? In what form is transaction-related data stored in or from other systems?
  • What communication channels are available in your organization? Peppol, MFT, e-mail, WebService, etc.
  • Does the ID for dates have the same meaning in all systems? (e.g. DD/MM/YYYY or MM/DD/YYYY)

If you can answer all these questions with yes, your e-invoice integration with your ERP system is 16931 compliant.

However, if there are still major gaps in the three steps of your invoice process mentioned above, it may be worth considering a platform that will take care of the data integration for you and close all these gaps.


3. edbic as the optimal platform for using EN 16931-compliant invoicing processes

This is where edbic comes in. edbic is not only EN 16931 compliant and offers an easy-to-implement solution through automation. It also maximizes efficiency and transparency in the secure handling of e-invoicing processes.

What is edbic: edbic is an innovative data hub from compacer that enables the digitization and optimization of business processes. It is versatile and offers a comprehensive solution for the management and exchange of electronic documents and data. This includes, of course, EN 16931-compliant e-invoicing.


9 strong reasons why edbic is the ideal solution for you:

  1. automated invoice processing: edbic fully automates the processing of e-invoices, reducing the susceptibility to errors and processing times.
  2. optimized order-to-cash process: by integrating e-invoices into the order-to-cash process, your company can speed up its payment flows and improve its liquidity.
  3. digital accounting: edbic enables the seamless integration of e-invoices into your accounting systems and thus offers better control of your finances.
  4. digital invoice receipt: edbic allows you to receive and process e-invoices directly from your suppliers, increasing the efficiency of your invoice processing.
  5. customizable e-invoice functions: edbic offers flexible solutions that can be adapted to your individual needs. This also enables optimal integration into your existing business processes.
  6. ZUGFeRD conformity: edbic is compatible with the ZUGFeRD standard commonly used in Germany, which ensures the smooth and legally compliant processing of e-invoices.
  7. data security: compacer is ISO 27001 certified. edbic therefore offers the highest standards in terms of data protection and security. The ISO 27001 standard ensures that your data is optimally protected.
  8. e-invoicing on the compacer platform: edbic offers a standardized platform for the exchange and management of electronic documents. It allows you to manage all your e-invoices in one place.
  9. our cloud-based compacer archive: Our in-house digital archiving system is not only optimally harmonized with edbic, but also GDPR-compliant. It also enables business documents to be quickly found and stored in an access-protected manner. They are also archived in an audit-proof manner and in accordance with the German Fiscal Code (AO). This also guarantees protection against changes. Important to know: compacer archive can also be used fully functional without the use of edbic.

In summary, this means

edbic is an optimal platform for the 16931-compliant introduction of e-invoicing in your company. Through the automation and standardization of invoice processes, compatibility with common standards such as ZUGFeRD and the provision of secure and customizable solutions, edbic offers an efficient and smooth integration of e-invoices into your existing business processes.

With edbic, you can not only speed up your invoice processing in compliance with EN 16931 and better control your finances. It also guarantees the highest security standards and data protection compliance in accordance with GDPR when processing e-invoices.

All in all, edbic, especially in combination with compacer Archive, is the ideal choice for your company if you want to take the easy way out and take advantage of the benefits of e-invoicing. Here you can see how we have successfully introduced e-invoicing in two companies with the help of edbic:


Are you really EN 16931 compliant? We can help you find out!

Arrange a no-obligation consultation with our team of experts to find out what you still need to do in your invoicing process to ensure you are EN 16931-ready. You will also find out about the other benefits of implementing edbic in your organization.