E-Invoicing – Overview

What an e-invoice is technically and legally, which obligations apply to companies in Germany and Austria, and which formats are relevant.

What is an e-invoice?

An e-invoice in the EU sense is not a PDF — not even a PDF sent by email. What matters is machine-readability: the invoice must be issued, transmitted and received in a structured format that enables automatic processing (Directive 2014/55/EU). Technically this means XML following the semantic data model EN 16931. The distinction between unstructured, hybrid and purely structured invoices is fundamental in practice.

Unstructured

Paper, image files, plain PDF — even if sent by email. Only human-readable, not machine-processable. Does not meet the EU definition.

Hybrid format

PDF with embedded XML (Factur-X / ZUGFeRD): human-readable and machine-readable in one file. Qualifies as an e-invoice provided the XML is the authoritative data source and meets EN 16931 (from COMFORT profile onwards).

Structured (pure XML)

XRechnung, PEPPOL BIS 3.0, ebInterface: no visual PDF, pure machine-readable XML. Always meets the EU definition, provided the format is EN-16931-compliant.

Structured means: an ERP or accounting system can read, validate and process the invoice directly — no manual data entry required. This is what makes e-invoices essential for automated workflows.

Terms explained: Glossary →

Legal and normative framework

EU Directive 2014/55/EU obligated public contracting authorities to accept structured e-invoices and mandated CEN to create a European standard. The result is EN 16931 — the semantic data model shared by all compliant formats. A CIUS (Core Invoice Usage Specification) such as XRechnung or PEPPOL BIS 3.0 restricts this model for a national use case without extending it.

EN 16931 defines which data an invoice must carry (BT fields such as invoice number, date, IBAN) and how totals are calculated (BR rules). The standard is currently being updated for ViDA; the revised version EN 16931-1:2026 has been published since March 2026.

The EU ViDA package (VAT in the Digital Age, Directive (EU) 2025/516, in force since 14 April 2025) requires EU businesses to issue structured e-invoices for cross-border B2B transactions from 2030 and simultaneously introduces Digital Reporting Requirements (DRR): transaction data must be reported to national tax authorities in near-real time. National mandates such as Germany's B2B requirement go further and have been permitted without EU special authorisation since April 2025.

Official sources and references →

E-Invoicing mandate in Germany

The Growth Opportunities Act (BGBl. I 2024 Nr. 108, 27 March 2024) revised §14 UStG: an e-invoice is now only a structured document per EN 16931. Paper and PDF are classified as "other invoices". The following phased mandate applies to domestic B2B transactions:

  1. 1 Jan 2025 – Receiving obligation

    All domestic companies must be able to receive EN-16931-compliant e-invoices. Accepted formats: Factur-X/ZUGFeRD from COMFORT profile, XRechnung, PEPPOL BIS 3.0. Transmission is decentralised — email, PEPPOL network, EDI or ERP direct connection are all permitted.

  2. 1 Jan 2027 – Issuing obligation (turnover > €800,000)

    Companies with prior-year turnover above €800,000 must issue e-invoices. Until then and until end of 2026, other invoices (paper/PDF) remain permissible with recipient consent (§27 para. 38 UStG).

  3. 1 Jan 2028 – Issuing obligation (all companies)

    Full issuing obligation for all domestic B2B transactions. EDI remains permissible provided a compliant reporting dataset can be extracted.

Legal basis: §14 UStG, Growth Opportunities Act (BGBl. I 2024 Nr. 108, 27 March 2024). Administrative guidance: BMF letters of 15 Oct 2024 and 15 Oct 2025. Retention: 8 years under §14b UStG (reduced from 10 to 8 years by the Fourth Bureaucracy Relief Act, effective for periods not yet expired on 31 Dec 2024).
Exemptions from the issuing obligation: invoices up to €250 gross (§33 UStDV), travel tickets (§34 UStDV) and B2C transactions. Small businesses (§19 UStG, Kleinunternehmer) are exempt from issuing but must still be able to receive.

E-Invoicing in Austria

No B2B mandate (as of May 2026)

Austria has no general B2B mandate for e-invoices — PDF and paper remain permissible in the private sector. In one area, however, Austria moved early: the obligation to submit structured e-invoices to public authorities (B2G) has been in place at federal level since 2014.

Invoices to public authorities (B2G)

Suppliers and service providers invoicing federal agencies must submit structured e-invoices. Legal basis: ICT Consolidation Act (BGBl. I Nr. 35/2012) §5 and Federal Public Procurement Act 2018 (BVergG 2018) §368.

  1. 1 Jan 2014 — Mandatory for federal agencies (IKTKonG §5, BGBl. I Nr. 35/2012)

  2. 18 Apr 2020 — Extended to all central contracting authorities (BVergG 2018 §368)

Accepted formats: ebInterface (4.3, 5.0, 6.0, 6.1) and PEPPOL BIS 3.0 (UBL). XRechnung and ZUGFeRD are not accepted by Austrian federal agencies.

Submission channels

USP

Business service portal (usp.gv.at) — upload or web service, authenticated via company login

e-rechnung.gv.at

Direct upload and web service interface for federal agencies

PEPPOL

Submission via an authorised PEPPOL Access Point — no USP login required

No qualified electronic signature (QES) required. Authentication is handled via USP account access.

ebInterface — the Austrian standard

ebInterface is Austria's XML format for e-invoices, developed and maintained by AUSTRIAPRO (a subsidiary of the Austrian Federal Economic Chamber, WKÖ). The standard has been in use since 2009, is free to use, and is actively maintained. From version 5.0 onwards, ebInterface is EN-16931-compliant.

Current version: 6.1 (25 August 2022) · EN-16931-compliant from version 5.0 · Version 7.0 planned for Q4 2026

Retention obligation: 7 years (BAO §132)

Format overview

From EN-16931-compliant hybrid formats to national mandatory solutions — Europe's e-invoicing landscape is varied. An overview of what milchrechnung supports and what exists in other countries.

Formats supported by milchrechnung

🇩🇪 🇫🇷 Supported

Factur-X

Hybrid format (PDF/A-3 + CII-XML), developed by FNFE-MPE. From version 2.1 technically identical to ZUGFeRD 2.x. Accepted in France and Germany.

🇩🇪 Supported

ZUGFeRD

Germany's leading hybrid format: PDF/A-3 with embedded CII-XML, maintained by FeRD. EN-16931-compliant from version 2.0.1 / profile COMFORT. Accepted under Germany's B2B mandate.

🇩🇪 Supported

XRechnung

German CIUS on EN 16931, maintained by KoSIT. Pure XML (UBL 2.1 or CII), B2G standard for German federal agencies since 2020. Permissible under the B2B mandate. Fully supported in milchrechnung — analysis, preview, conversion and creation.

🇪🇺 Supported

PEPPOL BIS 3.0

CIUS on EN 16931 in the international PEPPOL network (OpenPeppol), UBL 2.1. Four-corner model: transmission via accredited Access Points. Used in over 30 countries.

🇦🇹 Supported

ebInterface

Austria's XML standard, maintained by AUSTRIAPRO (WKÖ). B2G mandatory since 2014. Current version 6.1 (25 Aug 2022), EN-16931-compliant from version 5.0.

Other formats in the European context

For reference only — these formats are not currently available in milchrechnung.

🇮🇹 Reference only

FatturaPA

Italy's national mandatory format since 2019, transmitted exclusively via the state SDI platform. Based on a proprietary schema — not EN-16931-compliant.

🇵🇱 Reference only

KSeF / FA(3)

Poland's central e-invoicing system. Mandatory for large businesses since February 2026, for all others since April 2026. National schema, aligned with EN 16931 but not identical.

🇫🇷 Reference only

Chorus Pro / Factur-X

France's B2G platform. B2B mandate from September 2026 for large companies, September 2027 for SMEs. Accepted format includes Factur-X.

🇬🇷 Reference only

myDATA

Greece's real-time CTC platform. Mandatory for most businesses from March 2026. Proprietary national schema.

Formats and terminology in the Glossary →

In practice: milchrechnung

milchrechnung.at analyzes, validates, displays, converts and creates e-invoices per EN 16931 — in the browser, no installation, no sign-up required. The core library is open source on GitHub. All facts on these pages are referenced to official sources.

Analyze, validate, view or create e-invoices

Free, right in your browser — no sign-up, no data storage.

Official sources and references →

This information is provided for general orientation and does not constitute legal or tax advice. Despite careful research and verification against official sources, no guarantee is given for completeness or accuracy. Last updated: May 2026.