Is a PDF Invoice Still Valid in Germany? PDF vs E-Invoice Explained

Short answer: yes, for now – but not for long in domestic business-to-business (B2B) trade. A PDF invoice is still a valid invoice in Germany, but it is not an e-invoice. Between businesses established in Germany, you may send PDF invoices until the end of 2026 if your customer agrees, and in 2027 only if your turnover in the previous year was no more than €800,000. From 1 January 2028, a PDF is generally no longer enough for domestic B2B invoices. For private customers and for most cross-border invoices, PDF invoices remain fine.

This guide explains the rules, the exceptions and how to move from PDF to e-invoices. For the full background on the German mandate, see our guide to Germany's e-invoicing mandate.

Why a PDF invoice is not an e-invoice

Since 1 January 2025, German VAT law distinguishes between two types of electronic invoice:

• E-invoice (E-Rechnung): an invoice issued, sent and received in a structured electronic format that allows automatic processing and complies with the European standard EN 16931 – for example XRechnung or ZUGFeRD.
• Other electronic invoice (sonstige Rechnung): any other electronic format, including a PDF, a scanned image or a Word file.

A PDF is designed for people to read. A computer cannot reliably extract the invoice data from it. It does not matter how the PDF is delivered: a PDF attached to an e-mail is still a PDF, not an e-invoice.

When you can still send PDF invoices: the transition timeline

The obligation to issue e-invoices applies to supplies between businesses that are both established in Germany. For these domestic B2B invoices, the following transition rules apply:

• Since 1 January 2025: every business established in Germany must be able to receive e-invoices.
• 2025 and 2026: paper invoices are still allowed. PDF and other electronic invoices that are not e-invoices are allowed only if the recipient agrees.
• 2027: paper and PDF invoices are still allowed only if your total turnover in 2026 was no more than €800,000. Businesses above that threshold must issue e-invoices.
• From 1 January 2028: all businesses established in Germany must issue e-invoices for domestic B2B supplies, subject to the exceptions below.

When a PDF invoice remains allowed after 2027

Even after the transition period, you may continue to use PDF or paper invoices in these cases:

• Invoices to private customers (B2C).
• Invoices to customers that are not established in Germany, and invoices from suppliers that are not established in Germany.
• Small-value invoices with a total of up to €250 including VAT.
• Invoices issued by Kleinunternehmer (businesses using the small business exemption under § 19 UStG).
• Travel tickets that count as invoices, and certain VAT-exempt supplies.

Your customer may still ask for an e-invoice in these cases, and you can always send one voluntarily.

ZUGFeRD and Factur-X: the PDF that is an e-invoice

ZUGFeRD (called Factur-X in France) looks like a normal PDF, but it contains an embedded XML file with the structured invoice data. The XML part is what makes it an e-invoice. A ZUGFeRD invoice from version 2.0.1 onwards counts as an e-invoice in Germany – except the MINIMUM and BASIC WL profiles, which do not contain all the data an invoice requires.

This makes ZUGFeRD a practical choice if your customers want to keep seeing a familiar PDF. For a full comparison, read XRechnung vs ZUGFeRD.

PDF invoice vs e-invoice at a glance

• Readable by people: PDF – yes. XRechnung – only with a viewer. ZUGFeRD – yes.
• Machine-readable structured data: PDF – no. XRechnung – yes (XML). ZUGFeRD – yes (embedded XML).
• Counts as an e-invoice in Germany: PDF – no. XRechnung – yes. ZUGFeRD – yes, except MINIMUM and BASIC WL.
• Domestic B2B from 2028: PDF – generally no longer sufficient. XRechnung and ZUGFeRD – accepted.

What happens if you send a PDF when an e-invoice is required?

Once the obligation applies to you, a PDF invoice for a domestic B2B supply does not meet the legal requirements for a proper invoice. In practice, your customer may reject it and ask for a correct e-invoice, which can delay your payment. Your customer's right to deduct input VAT may also be at risk. If you are unsure about a specific case, ask a tax adviser (Steuerberater).

What to do if you receive a PDF invoice

During the transition period, you can accept PDF invoices from German suppliers. Store them in their original form for the required retention period – see how long to keep invoices in Germany. From 2028 (or 2027 for larger suppliers), you can ask a German supplier for an e-invoice instead. If you receive an XRechnung and cannot read it, our guide on how to open an XRechnung helps.

How to move from PDF to e-invoices

1. Check which of your customers are businesses established in Germany – they are the ones affected.
2. Choose a format: XRechnung for public authorities, XRechnung or ZUGFeRD for private-sector customers.
3. Create e-invoices directly in invoicing software instead of exporting PDFs from Word or Excel.
4. For existing PDF invoices, use a converter as a stop-gap – see how to convert a PDF invoice to ZUGFeRD or XRechnung.
5. Check each invoice with a validator before you send it.

XRechnungs.de is e-invoicing software for Germany: a web application for creating XRechnung, ZUGFeRD and Factur-X invoices that follow EN 16931. It also offers a PDF converter with OCR, a free validator and a free viewer. Data is hosted in the EU.

Frequently asked questions

Is a PDF invoice still valid in Germany?

Yes, it is still a valid invoice, but it is not an e-invoice. For domestic B2B supplies, PDF invoices are allowed with the recipient's consent until the end of 2026, in 2027 only for businesses with a prior-year turnover of up to €800,000, and generally no longer from 2028.

Is a PDF sent by e-mail an e-invoice?

No. An e-invoice must contain structured data in a format that complies with EN 16931. A PDF attached to an e-mail remains an other electronic invoice.

Can I keep sending PDF invoices to private customers?

Yes. The e-invoicing obligation applies only to supplies between businesses established in Germany. Invoices to private customers are not affected.

Can I send PDF invoices to customers outside Germany?

Yes, under German rules. The German obligation does not cover invoices to customers that are not established in Germany. Check whether the customer's country has its own e-invoicing rules.

Is a ZUGFeRD invoice a PDF or an e-invoice?

Both: it is a PDF with embedded XML data. From version 2.0.1, it counts as an e-invoice in Germany, except for the MINIMUM and BASIC WL profiles.

Can I convert a PDF invoice into an e-invoice?

Yes, with a converter that reads the invoice data, for example using OCR, and creates a structured XRechnung or ZUGFeRD file. Always check the result with a validator. For regular invoicing, creating e-invoices directly is more reliable.

Next step

The PDF invoice is being phased out for domestic B2B trade, but the change is gradual. If you start now, you can test e-invoices with your customers before the deadlines. Try XRechnungs.de free for 14 days – up to 50 documents, no credit card required. Plans are listed on the pricing page.