Does Trusted Shops provide e-invoices?

An e-invoice is an invoice that is issued, transmitted and received in a structured electronic format and whose data can be read out electronically and processed automatically. It must comply with the requirements of European standard EN 16931 (Section 14b of the German VAT Act (UStG)).

A simple PDF document, a scan of a paper invoice or an invoice document in image format are not considered an e-invoice as it does not contain a machine-readable structure.

Formats that comply with the EN 16931 standard or are interoperable are permitted. This applies in particular to the formats XRechnung and ZUGFeRD 2.x (profile EN 16931).

No. A qualified electronic signature is not required. The structured data display is decisive, not the electronic signature.

The transmission can take place by e-mail, via a customer portal, via an EDI process or via the Peppol network, as long as the structured data set is transferred.

We are currently working on a solution that meets the legal requirements. You will be informed as soon as the final version is available.

From 1 January 2025, all entrepreneurs based in Germany must be able to receive and process e-invoices. Accordingly, Trusted Shops has been able to receive e-invoices since 1 January 2025.

As of 1 January 2025, e-invoices have legally been established as a standard business practice, although they are not yet mandatory. However, the following transitional arrangements apply:

• From 1 January 2025 to 31 December 2026, issuing e-invoices is not yet mandatory, but is voluntary.
• From 1 January 2027, entrepreneurs with a previous year’s turnover of more than €800,000 will be obliged to issue e-invoices.
• From 1 January 2028, all entrepreneurs based in Germany will be required to issue e-invoices.

Unless the recipient has actively objected, invoices can still be issued in paper form or as unstructured PDF files until the end. For companies with a turnover of up to €800,000, this option applies until the end of 2027.

Due to its size, Trusted Shops is obliged to send e-invoices from 1 January 2027. We are working on providing a solution much earlier.

No, there are limitations. During the transition period (until the end of 2026 or for smaller companies until the end of 2027), there is still no general legal obligation for the issuer to issue e-invoices. The issuer may use “other invoices” (e.g. paper or unstructured PDF) during this period. However, the recipient can contractually agree that they will only accept e-invoices in future. In addition, since 1 January 2025, the recipient has been obliged to technically receive e-invoices in such a way that structured formats can be processed.

The e-invoicing obligation applies to taxable turnover between entrepreneurs based in Germany (B2B services), unless they are exempt from VAT under Section 4 of the German VAT Act (UStG).

No. The e-invoicing obligation applies exclusively to the business sector (B2B).

The obligation only applies to turnover where both the service provider and the service recipient are based in Germany. Cross-border services are not included.

Turnover that is exempt from VAT under Section 4 of the German VAT Act (UStG) (e.g. financial services, insurance, or rental of property) is not subject to the e-invoice obligation.

All information required under Section 14 of the German VAT Act (UStG), in particular: Name and address of the contracting parties, tax number or VAT ID number, invoice date, invoice number, service description, service date, remuneration, tax rate and tax amount.

Yes. All mandatory information must be contained in the structured XML part. External references or appendices do not replace this obligation.

Yes, as long as they do not affect the technical structure of the e-invoice (e.g. bank details, order numbers, internal IDs).

A hybrid invoice combines a readable PDF document with an embedded structured XML dataset. It is considered an e-invoice if the XML part complies with the EN 16931 standard.

By 2025, companies must have systems that can receive, read, validate and process e-invoices (e.g. ERP or accounting software with XML import capability).

No. From 2025 onwards, a properly created e-invoice may not be rejected on the grounds that it has been sent electronically.

This counts as a failure to fulfil the duty to receive e-invoices and can be raised as an issue during a tax audit.

Yes, it can be converted to a human-readable format and controlled. However, automated validation should be preferred.

The input tax deduction is at risk if an e-invoice is incorrect in terms of form or content, for example due to missing mandatory information or an impermissible format.

Incorrect e-invoices are rectified by cancellation and re-issuance or by a credit note in e-invoice format.

According to the German VAT Act, there are no direct fines for non-compliance with Section 14, but input tax deduction can be refused if the formal requirements are not met.

According to Section 14b of the German VAT Act (UStG), e-invoices must be retained for at least eight years.

Authenticity of origin, integrity of contents and legibility must be ensured throughout the entire storage period.

No. The structured data record (e.g. XML) must be archived unchanged and electronically.

• Assess their ability to receive e-invoices
• Update accounting and ERP systems
• Update and format information on their business partner
• Train staff
• Introduce a tamper-proof archiving system

E-invoices enable automated processing, faster allocation, a lower error rate and, overall, more efficient liquidity management.

Platform operators issuing invoices on behalf of the Seller must ensure that these invoices comply with legal e-invoicing requirements.

The BMF distinguishes between three categories: Format errors (incorrect technical structure), business rule errors (plausibility or validation errors) and content errors (material errors such as incorrect amounts or tax rates).

A format error exists if the e-invoice does not correspond to the technical structure of standard EN 16931. It is then not considered an e-invoice and input tax deduction is excluded until a rectified invoice is available.

These are violations of the technical validation rules, such as impermissible codings or inconsistent sums. The input tax deduction is only at risk if mandatory information is affected; otherwise these errors must be technically corrected, but are not necessarily tax-relevant.

A content error affects the substantive accuracy of the invoice content (e.g. incorrect tax rate, incorrect service description). It regularly means that input tax deduction is not possible until a rectified e-invoice is available.

Corrections are made by cancelling and re-issuing a complete e-invoice or an e-credit note. It is not permitted for the recipient to simply add PDFs or make manual changes.

Yes. As part of the EU initiative “VAT in the Digital Age (ViDA)”, a central electronic reporting system is planned to be introduced in the future.

Paper invoices will be phased out in the B2B sector, but will continue to be permitted in the B2C sector.

There are currently no industry-specific exceptions. The regulation only relates to the aforementioned type of turnover, not to specific industries.

Trusted Shops accepts XRechnung and ZUGFeRD.

Since Trusted Shops currently does not work with a PO/ordering system for invoice receipt, there are no requirements in this regard that could lead to a rejection of the e-invoice.

Trusted Shops does not have a portal for uploading invoices and does not currently use a PEPPOL system. All invoices can easily be sent to our central invoice receipt email address invoice@trustedshops.com.