The e-bill – are you on the safe side legally?

E-invoicing has been mandatory in the B2B sector since January 1, 2025 – a topic that most of you had to get to grips with first. While numerous providers advertised their solution in the beginning, communication has since become much quieter. However, the requirements remain high and implementation in everyday life poses challenges for many retailers. In this article, you will get an overview of typical stumbling blocks – and what you should pay attention to now when creating and processing e-invoices.

What does the law say?

Although the topic of e-billing seems to have fallen somewhat out of the public spotlight at the moment, the legal requirements still apply without restriction.

• For business transactions between companies (B2B) within Germany, both the invoice issuer and the invoice recipient must be able to receive e-invoices. This obligation applies to all companies with a registered office in Germany – or, if there is no registered office, with a domicile or habitual residence in Germany. The same applies to the areas specified in Section 1 (3) UStG.
• Only an invoice created in XML format is accepted as an e-invoice. The structure for this is specified in EU-DIN 16931. All other formats, e.g. in paper form or as a PDF, are regarded as “other invoices” and do not entitle to input tax deduction.
• The invoice in XML format may not be changed and must be archived in the format in which it was received. In the event of a tax audit, the invoice must be made available in XML format. To ensure this, the invoice data records must be checked electronically. After a technical and factual check, they receive an electronic identifier that identifies the data record as formally and factually correct, the so-called validation.

IMPORTANT: Only a validated and archived e-invoice entitles you to deduct input tax!

Exceptions to this obligation only apply in a few cases, namely:

• for tax-free transactions according to §4 number 8 to 29 UstG
• for invoice amounts up to 250 euros
• and for tickets (e.g. for local public transport).

The expert talk on the subject of e-invoices: Ulrich Pöhner, Sascha Lammers from GREYHOUND and Johannes Seidel from JERA talk about everything retailers need to know.

Typical stumbling blocks from practice

In the first few months of this year, we were able to gain a lot of experience in the area of e-invoicing and have summarized a few frequently asked questions:

Outgoing invoices

The creation of outgoing invoices seems simple at first glance. However, some questions arise in detail.

1. Which format should be used?
   Ideally, every company should define a standard format for its outgoing invoices. However, if your customer requires a specific format – such as XML or ZUGFeRD – this must also be used. This means that your ERP system should be able to support both formats. This is no problem with JTL.
2. Are all fields filled in correctly?
   The devil is in the detail here: e-invoices are not only defined as a file format (XML), but are also subject to content specifications. For example, the customer’s own IBAN number must also be transmitted if customers use the “Payment 10 days net” payment method. We are currently observing that it is precisely such dependencies that cause the most frequent queries – usually only when processing the incoming invoice, even though it is formally structured correctly.

Incoming invoices

Difficulties also occur time and again with incoming invoices – often only at second glance. We have summarized the most common challenges for you here.

1. Why are many e-invoices incorrect?
   As described for outgoing invoices, incorrect e-invoices frequently occur. There are many reasons for this:
   
   – Formats are not correct (rather rare)
   – Content errors
   
   As the error codes are not always meaningful, an analysis is difficult and must of course be carried out by the sender of the invoice.
   
   Tip:
   👉 To analyze incorrect e-invoices, it helps to take a look at the preview – the so-called e-invoice viewer. In addition to the error codes, specific indications of missing or incorrect data are also displayed there.
   The meaning of the error codes can usually be found on the websites of the respective software manufacturers. A comprehensive definition can also be found in the XRechnung Standard and Extension specification of the IT Planning Council of the Coordination Office for IT Standards(XStandards Purchasing).
2. How do you even recognize an e-bill?
   It is difficult to recognize the e-invoice as an e-invoice if, for example, the ZUGFeRD format is used without a reference. At first glance, the PDF with embedded XML file looks just like a normal PDF. If this is then processed like a normal PDF invoice, there is a theoretical risk that the input tax deduction will be denied, as this invoice must be processed like an e-invoice.
   
   Tip:
   👉 When importing a file, the processing software automatically checks whether it is a regular PDF or a PDF with embedded XML data – i.e. the structured ZUGFeRD format. The E-Rechnung 2 FIBU solution from JERA, a subsidiary of the JTL Group, reliably recognizes this difference and issues a corresponding error message if there is no valid e-invoice.
3. What does e-billing mean for internal processes?
   E-invoicing will have a major impact on the processes involved in processing incoming invoices. If a procedure for processing an incoming invoice is established, various processing steps take place (see diagram). If a second processing procedure is now introduced with an e-invoice, this creates additional work in the first step, which should actually be avoided. Here, the process is further optimized through further development of the software and better integration by providers such as JERA and JTL.

Above you can see the classic invoice receipt posting process: receipt of the invoice, payment and posting in financial accounting.

Below is an illustration of how the e-invoice creates a second process strand that drives digital processing but still has to be merged with the conventional invoice receipt process in the final stage.

Successful implementation with the right preparation

E-billing is here to stay – and presents many retailers with new challenges. Our experience to date shows that Those who know the technical and content requirements and adapt their processes accordingly can master the changeover well. Above all, it is important that the ERP system used supports both XML and ZUGFeRD, that content is filled correctly and that the internal processes for incoming invoices are clearly regulated.

Even if getting started can involve additional effort, investing in well thought-out e-invoice processes pays off in the long term – especially in terms of efficiency, transparency and legal security.

With the JERA E-Invoice 2 FIBU add-on, you can create and process e-invoices in a legally compliant manner – including validation, archiving and transfer to the accounting department.

We have already created an extensive blog series on the topic of mandatory e-invoicing. You can find all the articles here:
Part 1: E-invoicing obligation 2025: everything online retailers need to know
Part 2: E-billing in just a few steps
Part 3: Expert tips: The e-bill with JERA and GREYHOUND