---
title: "B2B E-Invoice: Checklist and Implementation for Companies"
date: 2026-11-03
author: "Irina Emdina"
featured_image: "https://www.easybill.de/wp-content/uploads/E-Rechnung_im_B2B.png"
categories:
  - name: "E-Invoicing"
    url: "/en/category/e-invoicing.md"
  - name: "Freelancers"
    url: "/en/category/freelancer.md"
  - name: "Starting a Business"
    url: "/en/category/starting-a-business.md"
---

# B2B E-Invoice: Checklist and Implementation for Companies

Anyone issuing invoices in the B2B space has had to be able to accept incoming e-invoices since 2025, and must issue e-invoices themselves by 2028 at the latest. What that means for your business in practice depends on your revenue and your systems. This article shows you which obligation applies to you and when, what you need to do for incoming and outgoing invoices, and which implementation approach fits you.

**In a nutshell:** Since 2025, every business in Germany must be able to receive e-invoices compliant with EN 16931 and archive them in the original format. Starting in 2027, businesses with more than 800,000 euros in total revenue in 2026 must also issue them; starting in 2028, this applies to all domestic B2B invoices. To implement this, you need three things: a fixed receipt channel, software that creates and checks e-invoices, and a GoBD-compliant archive.

## **The e-invoice in B2B**

An e-invoice is a structured invoice under the European EU standard EN 16931, for example in the XRechnung or ZUGFeRD format. Paper and PDF invoices have been considered “other invoices” since 2025. The obligation applies only to B2B: It affects transactions between businesses where both are established in Germany. Invoices to private customers and cross-border transactions are not covered.

| From when | What applies |
|---|---|
| since January 1, 2025 | Receipt obligation for all businesses. You do not need the recipient’s consent for an e-invoice. |
| Transactions in 2025 and 2026 | Transitional period: other invoices remain permitted. Paper is allowed without consent; PDF only with the recipient’s consent. |
| starting January 1, 2027 | Issuance obligation if total revenue exceeds 800,000 euros in 2026. All others may still issue other invoices for 2027 transactions. |
| starting January 1, 2028 | Issuance obligation for all domestic B2B transactions. Exception: small businesses. |

You can find the [basics on e-invoicing](https://www.easybill.de/en/guide/e-invoice/) and all deadlines and exceptions in detail in our guides.

## **Self-check: which obligation applies to you and when**

Which obligation applies to you depends on two things: whether you receive invoices from other businesses and how high your total revenue is in 2026.

| Your business | 2026 | 2027 | starting in 2028 |
|---|---|---|---|
| Small business (§ 19 UStG) | Receive and archive e-invoices | Receive and archive e-invoices | Receive and archive e-invoices; issuing is voluntary |
| Self-employed professionals and businesses with total revenue in 2026 up to 800,000 euros | Receive e-invoices; issuing is voluntary | Receive e-invoices; issuing other invoices still permitted | Receive and issue e-invoices |
| Businesses with total revenue in 2026 over 800,000 euros | Receive e-invoices; issuing is voluntary | Receive and issue e-invoices | Receive and issue e-invoices |
| Businesses with only private customers (B2C) | Receive incoming invoices from suppliers as e-invoices | Receive incoming invoices from suppliers as e-invoices | Receive incoming invoices from suppliers as e-invoices; no e-invoicing obligation for invoices to private customers |

For the 800,000-euro threshold, total revenue under § 19 para. 3 UStG in calendar year 2026 is decisive. This means your entire revenue, not just the portion with business customers. That makes 2026 the measurement year. If you’re close to the threshold, you won’t know the answer until year-end—so prepare for the transition in advance.

Under § 34a UStDV, small businesses have an option and may continue to issue paper or PDF invoices permanently. However, they still must accept incoming e-invoices and retain them for eight years. More on this is covered in the guide to the e-invoice for small businesses.

## **Checklist for incoming invoices: receive, check, archive**

Receiving e-invoices has been mandatory since 2025 and is the first step for every business. The task has three levels that are often mixed up: the channel through which the invoice arrives, reading and checking it, and archiving. Our guide Receiving and archiving e-invoices explains how this works in detail.

### **Define a receipt channel**

A standard email inbox is sufficient for receipt. The Federal Ministry of Finance (BMF) clarified this in its letter dated October 15, 2025. A separate invoicing portal or access to the Peppol network is not required between businesses. What matters is that invoices arrive at a fixed point and no one overlooks them there.

- Set up a dedicated email address for incoming invoices, for example rechnung@deine-firma.de.
- Share this address with all suppliers.
- Decide who is responsible for the inbox and how often it is processed.
- Check whether your mail system delivers XML attachments and does not filter them out.

### **Read and check**

At its core, an e-invoice consists of an XML file, which is barely readable without software. The tax authorities’ free e-invoice viewer on ELSTER makes it visible. It does not replace the review process or the archive.

- Use software that displays e-invoices in a readable way and validates them automatically.
- Check every incoming invoice for format errors before you approve it for payment, for example with the [e-invoice validator](https://www.easybill.de/en/e-invoice-validator/).
- Save the audit report together with the invoice.
- Define who sends incorrect invoices back to the supplier.

### **Archive in the original format**

The e-invoice must be archived in the original format, i.e., as an XML file. For hybrid ZUGFeRD invoices, the XML part is the actual invoice. If the image and the data differ, the XML part prevails. Since 2025, the retention period for invoices has been eight years; the details are covered in the guide to retention periods.

- Store the XML file in an unalterable manner, not just the PDF.
- File invoices so that you can evaluate them electronically.
- Describe the workflow from receipt to filing in procedural documentation.

The GoBD govern the requirements for the archive; for more, see [Working in compliance with the GoBD](https://www.easybill.de/en/guide/gobd-compliance/).

## **Outgoing invoice checklist: Create and send e-invoices**

For outgoing invoices, your revenue sets the pace: If your total annual revenue in 2026 is more than 800,000 euros, you’re up in 2027; everyone else starts in 2028. You may voluntarily issue e-invoices already today, without your customer having to agree.

### **Choose a format**

The format must comply with EN 16931. In Germany, two formats are widely used: XRechnung as a pure XML file, and ZUGFeRD as a PDF with an embedded XML file. For many customers, ZUGFeRD is the easier entry point because they can still view the PDF. For ZUGFeRD, choose a profile that meets EN 16931. You can find a comparison under E-invoice formats at a glance.

### **Prepare master data**

Larger customers process incoming invoices automatically. If a detail their system expects is missing, your invoice ends up in manual follow-up processing.

- Ask every business customer for the email address for incoming invoices.
- Store purchase order numbers or buyer references if the customer requires them.
- Check your own mandatory information, such as tax number or VAT ID (USt-IdNr.), in the invoicing program.

### **Validate before sending**

A file with a format error is not an e-invoice. Therefore, have every invoice checked before sending—either automatically in your invoicing software or with a validator. This helps you avoid follow-up questions and corrective invoices.

### **Make conscious use of the transitional rule for e-invoicing (B2B)**

For supplies in 2025 and 2026, you may still issue other types of invoices. If your total revenue in 2026 was no more than 800,000 euros, this also applies to supplies in 2027. Paper is possible without consent; for PDF you need the recipient’s consent. Consent may also be implied, for example if your customer accepts and pays PDF invoices without objection. If they refuse, your only options are paper or the e-invoice.

## **Implementation options for e-invoicing (B2B) compared**

How you implement e-invoicing technically depends on two questions: how many invoices you issue and which systems you already use. Four options are possible.

| Approach | Suitable for | Effort | Covers | Watch out for |
|---|---|---|---|---|
| Cloud-based invoicing software | Freelancers, small and medium-sized businesses without an ERP | low | Creating, receiving, checking, and archiving in one system | XRechnung and ZUGFeRD, GoBD-compliant archive, export to tax advisor |
| E-invoicing module in the ERP or inventory management system | Businesses that already generate invoices in the ERP | medium to high | Outgoing invoicing directly from the existing process | whether the module also covers incoming invoices and archiving in the original format |
| External service provider or Peppol access | Businesses with many partners or customers that use Peppol | medium | Transmission and conversion of formats | ongoing costs; responsibility for correct invoices remains with you |
| EDI | Businesses with large trading partners and an existing EDI connection | high | automated exchange with fixed partners | permitted for supplies in 2026 and 2027 with consent; after that only if transferable into EN 16931 |

If you don’t have an ERP and issue invoices individually or in small batches, invoicing software is sufficient. If you already generate invoices in the ERP, ask your vendor first what its module can do before introducing a second system. Service providers and EDI are mainly an option when your customers specify the transmission channel.

## **Special cases in day-to-day practice: what the BMF letter of 10/15/2026 clarifies**

With its third letter dated October 15, 2026, the BMF regulated cases where the transition often gets stuck in everyday practice. This does not change the deadlines in 2027 and 2028.

**Down payment and final invoices:** You do not have to subsequently send down payment invoices that you issued before your obligation to issue e-invoices began as e-invoices. In the final invoice, you may also present partial payments already received in another way until June 30, 2030.

**Discounts, bonuses, and cash discounts (Skonto):** The letter specifies how price reductions are to be shown in the e-invoice. Check with your software provider whether your Skonto terms are being transferred in the structured part.

**Corrections:** If you correct an e-invoice, you also send the correction as an e-invoice—not as an informal email or PDF.

**Types of errors:** The BMF distinguishes format errors from business rule errors and content errors. In the case of a format error, the file cannot be read correctly; then there is no e-invoice. Business rule errors and content errors relate to the information provided, such as a missing mandatory detail or an incorrect tax rate.

**Non-objection until the end of 2026:** The tax authorities will not object to e-invoices that you issue by December 31, 2026 in accordance with the requirements of the 2024 and 2025 letters, including for input VAT deduction. From 2027, the new detailed rules apply.

You do not need an e-invoice for Kleinbetragsrechnungen (small-amount invoices) up to 250 euros, for travel tickets, and for VAT-exempt supplies under § 4 no. 8 to 29 UStG. Reverse-charge supplies under § 13b UStG, however, are not exempt.

## **Inform customers and suppliers**

The transition will only work if your business partners know what you are sending and what you expect. A short notice to customers and suppliers is usually sufficient.

- Provide your suppliers with the address for incoming invoices and ask for e-invoices.
- Inform your customers of the format you will be sending in the future, for example ZUGFeRD.
- Get your customer’s consent for PDF invoices as long as you are using the transitional rule.
- Ask for purchase order numbers or references that your customer needs on the invoice.

You don’t need a Leitweg-ID for this. This identifier exists only for invoices to public contracting authorities.

## **Roadmap for e-invoicing in B2B through 2028**

When you need to take care of what can be planned in four stages using the following timeline .

| Period | What you need to do |
|---|---|
| Now | Ensure receipt: define an inbox, set up software for reading and checking, set up an archive in the original format. |
| By the end of 2026 | Keep an eye on total revenue in 2026, choose the implementation approach, test initial e-invoices with selected customers. |
| 2027 | If total revenue in 2026 is more than 800,000 euros: all B2B invoices as e-invoices. |
| From 2028 | All domestic B2B invoices as e-invoices, unless you are a Kleinunternehmer. |

**Implement B2B e-invoicing with easybill**

easybill Invoice creates e-invoices in the XRechnung and ZUGFeRD formats from your usual invoice data. You import incoming e-invoices, check them, and archive them in the original format in compliance with GoBD. For collaboration with your tax advisor, you export documents and postings to DATEV. Our free setup service helps you get everything configured so B2B e-invoicing runs smoothly in your business quickly.

[Start free trial](https://app.easybill.de/signup?lang=de)

[View features](https://www.easybill.de/en/features/)

## Frequently asked questions & answers about B2B e-invoicing

### Does the e-invoicing requirement apply only to B2B?

Yes. The requirement applies only to transactions between businesses where both are established in Germany. You can continue to send invoices to private customers as paper invoices or PDFs. Also excluded are low-value invoices up to 250 euros, travel tickets, and certain tax-exempt supplies.

### Is a normal email inbox sufficient for receiving?

Yes, an email inbox is sufficient as a receiving channel. The BMF clarified this in its letter dated October 15, 2025; a special portal or Peppol is not mandatory. Still, you must be able to read and check the XML file and retain it in the original format for eight years. For that, you need suitable software and a GoBD-compliant archive.

### Do I need a Leitweg-ID in B2B?

No. The Leitweg-ID is an identifier for invoices to public contracting authorities such as federal, state, and municipal authorities. Between businesses it is irrelevant. Instead, larger business customers often require a purchase order number or buyer reference so their system can match the invoice.

### Am I still allowed to send PDF invoices in 2027?

That depends on your total revenue in 2026. If it was no more than 800,000 euros, you may still issue other types of invoices for 2027 transactions; however, PDFs are only allowed with the recipient’s consent. If it was above that, you must issue e-invoices starting January 1, 2027. From 2028, the requirement applies to all businesses except Kleinunternehmer.

### What happens if an e-invoice is incorrect?

What matters is the type of error. If the file cannot be properly read due to a formatting error, then there is no e-invoice, and you send a new, error-free file. If mandatory information is missing or, for example, the VAT rate is incorrect, you correct it by issuing a corrected e-invoice. Whether your input VAT deduction as the recipient is affected should be clarified on a case-by-case basis with your tax advisor.

### Does the mandatory e-invoicing requirement also apply to invoices to Austria?

No. The German requirement applies only if you and your customer are resident in Germany; invoices to business customers in Austria are not covered. In Austria, there is no general domestic B2B requirement (as of October 2026). Structured e-invoices have been mandatory there since 2014 only for invoices to the federal government, for example in the ebInterface format via the Unternehmensserviceportal or via Peppol. From July 1, 2030, e-invoices under the EU ViDA initiative will be mandatory for cross-border B2B transactions within the EU—meaning also for invoices from Germany to Austria.