E-invoicing obligation for online retailers and Amazon sellers

If you sell through marketplaces such as Amazon, eBay, Kaufland, and OTTO Market, or through your own online shop, the e-invoicing obligation affects you in two ways: when receiving invoices and when issuing them. It applies in stages starting in 2025 for domestic B2B transactions. For invoices to private customers, much will remain the same. This article shows you when which obligation applies, what specifically applies on Amazon, and how to make the switch cleanly.

What you need to know as an online retailer about the e-invoicing obligation

The e-invoicing requirement applies to domestic B2B supplies between businesses. As an online retailer, you must be able to receive e-invoices since January 1, 2025. The obligation to issue e-invoices yourself will apply starting in 2027 for businesses with more than 800,000 euros in prior-year revenue, and starting in 2028 for all businesses. Invoices to private individuals are exempt; PDFs and paper remain permitted here.

An e-invoice is not a PDF. It is a structured, machine-readable dataset in accordance with EN 16931. The two common formats are XRechnung and ZUGFeRD. A scanned document or a document sent as a PDF does not meet the requirement. You can read about how an electronic invoice is technically structured in the guide to e-invoicing.

Who the e-invoicing requirement applies to in online retail

Affected are domestic transactions between entrepreneurs—that is, invoices to business customers in Germany. Legal form and size do not matter. A GmbH is covered just as much as a sole proprietor or a small business under Section 19 UStG. The mandatory invoice details under Section 14 UStG remain unchanged; the e-invoice only adds the structured data component.

One point is often overlooked: small businesses are not completely exempt. They must be able to receive and process an e-invoice. As soon as a supplier or service provider sends you an XRechnung or ZUGFeRD file, you need a way to read it and archive it in an audit-proof manner. This receipt obligation already applies.

E-invoices to private individuals: what applies in B2C

Invoices to private individuals are not subject to the e-invoicing requirement. If you sell to end consumers, you may continue to issue your invoice as a PDF, on paper, or in any other format. Formally, nothing changes for classic B2C sales in your shop or via Amazon. This also applies to e-invoices to private customers abroad.

In addition, there is the small-amount invoice: Up to 250 euros gross (Section 33 UStDV), no e-invoice is required, regardless of the recipient. For retailers with many small orders, this takes some pressure off the issue.

The real challenge lies in a mixed customer base. On Amazon, both private individuals and business customers buy via Amazon Business. For the same goods, an informal B2C invoice or a structured B2B invoice may therefore be required. What matters is whether your system reliably identifies the customer type and derives the correct invoice format from it.

Receiving and issuing: two obligations, different deadlines

The e-invoicing requirement consists of two separate obligations with their own deadlines. First comes receiving, then issuing. Anyone who mixes these up misjudges what they need to do.

The receipt obligation is the part that already matters now. Your business partners and suppliers are already allowed to send you an e-invoice today, and you must be able to accept it.

E-Invoicing on marketplaces and in your own online shop

The e-invoicing obligation does not depend on the sales channel, but on you as a company. If you sell to domestic business customers, you need an e-invoice that complies with EN 16931, and the platform will not reliably handle this for you.

This is exactly where easybill Connect comes in. It connects marketplaces and online shops with your invoicing system, automatically imports orders, and creates legally compliant invoices, including e-invoices. This allows you to manage B2B and B2C processes centrally in one place, regardless of which channel the order comes from.

Issuing and receiving e-invoices on Amazon

Amazon generates invoices to your customers via the VAT Calculation Service (Amazon VCS), usually as PDFs. For private purchases, this is sufficient. For a business customer who needs an e-invoice, it is not sufficient. You must ensure yourself, using appropriate software, that you issue compliant e-invoices in accordance with EN 16931.

For receipt via an Amazon Business account, according to Amazon’s terms and conditions: Without registering for electronic invoicing, you receive your invoices as PDFs. With registration, you receive an electronic format such as cXML or EDI, which then counts as the “original,” and the PDF only as a “copy.” These formats generally do not meet the requirements for an e-invoice under EN 16931. You can find the detailed rules in the Amazon Terms and Conditions.

How you can properly receive and issue e-invoices via Amazon with easybill is shown on the page about Amazon invoices.

E-invoicing on eBay: mandatory for B2B sales

Many orders on eBay are placed by private customers, but business buyers also use the platform. For these customers, issuing a compliant e-invoice remains your responsibility. eBay does not automatically generate a structured invoice, so you need your own solution to create B2B invoices in the required format.

Kaufland and OTTO Market: e-invoices for business customers

The share of business customers on German marketplaces such as Kaufland and OTTO Market is growing. Here, too, invoicing software is required to issue e-invoices to B2B customers. The same principle applies to niche marketplaces such as Etsy or ManoMano, regardless of the size of the platform.

E-invoicing in your own online shop: Shopify, Shopware, and WooCommerce

For your own online shop, the options depend on the platform you use. Shopware, for example, offers an e-invoicing app that can generate ZUGFeRD and XRechnung files. Shopify and WooCommerce do not support this functionality natively, so you need a plugin or an integrated invoicing solution.

By default, an online shop system only provides an order confirmation, not a legally compliant e-invoice. This step is handled by an integrated invoicing solution such as easybill, which uses the order data to generate the appropriate XRechnung or ZUGFeRD invoice.

XRechnung or ZUGFeRD: which format is right for retailers

Both mandatory formats comply with EN 16931, but they differ in presentation. The choice depends on how your accounting works.

For everyday Amazon and shop operations, ZUGFeRD is often the more pragmatic choice because you and your customer continue to see a readable invoice. However, what matters is still the structured data component, not the PDF image. A pure PDF without an embedded dataset is not an e-invoice.

Special tax cases in online retail: OSS and reverse charge

In online retail, two special tax cases occur regularly that complicate the invoicing process. For cross-border sales to private customers in the EU, the One-Stop Shop (OSS) applies once the 10,000-euro delivery threshold is exceeded: the supply is then taxed in the buyer’s country. For the fees that Amazon charges you from Luxembourg, the reverse-charge procedure applies; the VAT liability rests with you.

Both cases are prone to errors as soon as invoices are processed automatically. An incorrect tax rate in the dataset is posted incorrectly by the recipient right away. easybill Connect imports your orders from marketplaces and shops and creates invoices including the appropriate tax logic, OSS included. This keeps the allocation traceable and does not need to be checked manually.

Archiving e-invoices correctly

You must retain e-invoices in the original format, i.e., as an XML dataset, GoBD-compliant and machine-readable. For invoices and accounting documents, an eight-year retention period has applied since 2025, reduced from the previous ten years.

A common mistake is printing the e-invoice and filing the printout. A printout of a ZUGFeRD file is legally only a copy. The valid original is the structured dataset. Therefore, always store e-invoices digitally in the original format, not on paper or as a newly generated PDF. GoBD-compliant retention also includes process documentation that records how e-invoices are received, reviewed, and archived in your business.

What you should do now as an online retailer

The first step is not issuing, but receiving. Make sure you can accept, read, and archive e-invoices from suppliers and marketplaces. After that, clarify which format fits your accounting and how your invoices to business customers will be created in the future.

Specifically, that means:

• Check whether your software can receive e-invoices and archive them in compliance with GoBD.
• Define for Amazon and other marketplaces how B2B and B2C invoices are generated.
• Choose an output format: XRechnung or ZUGFeRD.
• Test a complete end-to-end run: create the invoice, review it, post it, archive it.

For automated billing via marketplaces and shops, easybill Connect bundles these steps—from the integration through to the e-invoice. The page on e-commerce marketplaces provides an overview of the supported platforms. You can try easybill free of charge and without obligation for 7 days, no credit card required.