Germany Confirms Email can be Used for E-Invoices, but PDF Alone is not Enough

Germany allows e-invoices to be sent by email, but the attached invoice must be in a compliant structured format such as XRechnung or ZUGFeRD with XML, while ordinary PDFs, scans, Word/Excel files, or invoice text in the email body do not qualify as legal e-invoices.

Germany allows businesses to send e-invoices by email, but only if the invoice is attached in a legally valid structured format. A standard PDF invoice, scanned document, Word file, Excel file, or invoice written directly in the email body does not qualify as an e-invoice under German law.

Since January 1, 2025, an e-invoice in Germany must be issued in a structured electronic format, based on XML, compliant with the European standard EN 16931, and machine-readable so that accounting software can automatically process it. The main accepted formats are XRechnung and ZUGFeRD from version 2.0.1 onward.

The important point is that the transmission method is not the decisive factor. Businesses may send an e-invoice by normal business email, through Peppol, EDI, or a customer portal. What matters is that the attached file itself meets the legal format requirements. A digital signature, encryption, and prior consent from the recipient are not required for German B2B e-invoices.

The obligation is being introduced in stages. Since January 1, 2025, all German B2B companies must be able to receive e-invoices. From January 1, 2027, companies with annual turnover above €800,000 must issue e-invoices for domestic B2B transactions. From January 1, 2028, the issuing obligation will apply to all other B2B companies.

For businesses that currently create a PDF invoice and send it by email, the workflow does not necessarily need to change completely. Instead, the invoice file must be replaced with a compliant XRechnung XML file or a ZUGFeRD file with embedded XML. The email can still be used only as the delivery channel.

Companies should also remember that the structured original invoice must be archived for the legally required retention period. Keeping only a printed version, screenshot, or converted PDF copy is not sufficient.

Overall, Germany’s rule is simple: email is allowed, but a normal PDF is not an e-invoice. Businesses affected by the 2027 and 2028 deadlines should make sure their invoicing systems can create and store compliant structured invoice files.