Checklist: Obligation to issue
electronic invoices from 2025

What companies in the healthcare sector need to know about the e-invoicing mandate in Germany

It’s time to say goodbye to paper invoices. Not immediately, but from 2025, when companies will have to send electronic invoices in a specified format. According to the European standard EN 16931, this means that not only paper invoices will be no longer be accepted. By 2027 at the latest, digital invoices sent as PDF e-mail attachments will also become invalid—even if transmitted via Electronic Data Interchange (EDI).

This may seem a little too ambitious because of the time frame. And indeed, the introduction of the e-invoicing mandate sounds like a major challenge when you consider that this change will affect around three and a half million companies in Germany. It is estimated that these companies send over 32 billion invoices to each other every year. 

Step by step to a seamless e-invoicing mandate

In order to slow down the entire process towards the full implementation of the e-invoicing mandate for companies, the whole project is to be implemented gradually in several stages. The plan of the federal government and the tax authorities is to revolutionize accounts payable and accounts receivable accounting within three years—and to do so as smoothly and carefully as possible. After all, moving away from paper invoices sent by mail, fax, or e-mail will certainly not be so easy.

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Digitalization in three steps—goodbye traditional invoicing, hello mandatory XRechnung!

The first step will be to put an end to paper invoices in 2026. After that, all other electronic formats that are not compliant with the European standard EN 16931 and Directive 2014/55/EU will also have to be phased out. In Germany, valid formats would therefore be XRechnung or ZUGFeRD (and only from version 2.x).

Graphic Phases Introduction e-invoice

Attention: E-invoices must be accepted!

The implementation of the e-invoicing mandate will begin on January 1, 2025, but only the receipt of electronic invoices will be mandatory for the time being. In other words:

From January 1, 2025, healthcare facilities, including hospitals, rehabilitation facilities, and care services as well as other players in the healthcare sector will be legally obliged to accept electronic invoices in one of the aforementioned EN-compliant formats. If they do not comply with this requirement, they will be in breach of the law.

But there is a way out—at least for a short time. If the suppliers agree to continue exchanging paper invoices for the time being, they can do so for the whole of 2025. However, postponed does not not canceled. After that, this will be possible only if the company receiving the invoices had a turnover of less than €800,000 in the previous year. However, this exemption will also be abolished from 2027.

From 2027, companies will be allowed to exchange invoices only digitally—with no exceptions. This means that the era of paper invoices will soon come to an end. From this date, they will no longer be recognized as vouchers by the German tax authorities.

The digital transformation does not stop at the healthcare sector. This affects not only large hospital groups or rehabilitation and care facilities but also small healthcare companies. From the trusted local pharmacist to the small solo doctor’s practice to super-specialized specialist clinics, all players in the healthcare sector are facing the challenge of converting their processes to digital standards.

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What is a “genuine” electronic invoice?

So why all the changeover? It’s simple: e-invoicing promises efficiency, progress, and better security standards. And how does that come about? They

  • make manual invoice processing unnecessary,
  • reduce paper consumption by hundreds of thousands of tons,
  • offer greater security, reliability, and speed compared with traditional invoice formats,

and enable the German tax authorities to carry out VAT audits digitally and in real time. This monitoring advantage could generate additional annual revenue of more than EUR 10 billion for the German state because VAT fraud will be virtually eliminated.

So it should come as no surprise that Italy, Spain, and Hungary have been using e-invoices for some time now. It’s even less surprising that Germany is noticeably promoting the exchange of electronic invoices.

This is possible only because a "genuine” e-invoice consists of a machine-readable data record, including all important (and tax-relevant) invoice data.

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How does the receipt of digital documents such as e-invoices work?

In fact, every company in Germany is faced with the task of meeting the minimum requirements of the revised VAT Act within the next nine months (as of April 2024).

Easier said than done. While politicians and the financial administration still seem to be convinced that implementation is totally feasible, many companies see things quite differently. After all, they have to take care of everything themselves. Even if they can draw on the expertise of experienced accounting and IT teams, getting started with electronic invoicing in accordance with German legislation is proving to be a considerable challenge. The healthcare sector—and therefore all clinics and rehabilitation and care facilities—are not spared either.

Why is the gradual e-invoicing mandate of all things a challenge?

Particularly in the healthcare industry, where a large number of supplier relationships are necessary, the initial retention of paper and PDF invoices could make the management of payables considerably more difficult. And often across national borders. It is unlikely that there will be an immediate and exclusive switch to electronic invoices at the start of 2025.

How do you receive such an electronic invoice now?

This is not so easy to answer. The exact transmission channel for electronic invoices under the new VAT Act has not (yet) been defined. However, there are actually already three main channels through which electronic invoices can be exchanged—and have already been transmitted in the public sector for years:

  1. Electronic invoicing by e-mail (insecure and impractical)
  2. Electronic invoice exchange via EDI (expensive and time-consuming)
  3. E-invoice exchange via the European Peppol network (still relatively unknown)

E-invoices via e-mail: possible, but that’s it

Sure, the e-mail option still exists. But is that really good news? After all, despite the option of end-to-end encryption, e-mail traffic is particularly susceptible to security breaches. There is also additional work involved: electronic invoices sent by e-mail usually have to be processed manually and integrated into the recipient’s accounting or ERP system. In addition, only an e-invoice in the hybrid ZUGFeRD format (consisting of the structured data record and the readable PDF) can be read by humans. This makes manual verification of a “genuine” electronic invoice virtually impossible.

E-invoices via EDI: more for the really big players

In contrast to ZUGFeRD, XRechnung is a cryptic data record and is preferred by the German tax authorities. This means that the invoice is only machine-readable. In addition, most e-invoices at the European level are not sent by e-mail. Instead, this is done specifically via individual data connections (better known as EDI). However, this is worthwhile only if tens or hundreds of thousands of invoices need to be sent between two parties.

E-invoices in the Peppol network: the digital future?

Alternatively, the exchange of electronic invoices can be handled via the Peppol network (previously rather unknown). The idea behind this was to use the network for the exchange of digital data and invoices between government institutions. However, it now plays a central role in the digital exchange of transaction data and has done so for some time in the business-to-business (B2B) sector. A key feature of Peppol is its stability, security, and high transmission speed. However, a Peppol Access Point is required to access this network. This makes it impossible to send or receive data directly without this access point.

What do companies in the healthcare sector have to do to comply with the legal requirements?

The obligation to issue invoices electronically poses a considerable challenge. Even the planned “phased plan” or the fact that companies have to receive e-invoices “only” by January 1, 2025 does not fully help. After all, the entire implementation requires a great deal of organizational, procedural, and technical effort. Those who have already relied on digital processes in purchasing, invoice receipt and voucher processing for their accounts payable management have a clear head start. But don’t panic. There is still plenty of time for all other companies to take care of the implementation of the e-invoicing mandate.

How can you make it particularly easy? With our specialized solution for digital accounts payable management, cisbox Invoice. This makes the transition not only completely simple but also cost-effective.

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FAQ

Frequently asked questions about the e-invoicing mandate from 2025 for clinics and rehabilitation and care facilities as well as other companies in the healthcare sector

In theory, printing out documents is not prohibited for the time being. In practice, however, a printed copy does not replace the originally transmitted electronic document. In fact, this procedure contradicts the purpose of an electronic invoice by turning a digital data record into a physical “image” again, a step that goes against the planned workflow and legal requirements. According to the “Principles for properly maintaining, keeping and storing books, records and documents in electronic form and for data access” (GoBD), it is also not permitted to archive invoices in printed form. The originally transmitted electronic format must be retained as the only valid original vouchers. According to official terminology, a printout serves merely as a posting aid. Printing out such invoices is usually not particularly useful anyway. After all, e-invoices are often in formats that are difficult for people to read and do not look like traditional invoices. 
Electronic invoices are subject to the same legal requirements and storage obligations as conventional invoice formats (e.g., paper, PDF). This also includes the aforementioned GoBD.
Yes, the obligation to receive genuine electronic invoices in Germany also extends to invoices from foreign suppliers provided they are issued in an electronic format. This regulation applies to suppliers both within the European Union and in third countries regardless of their registered office.
Yes, invoices for smaller amounts must also be sent electronically in Germany. However, the obligation to receive electronic invoices does not apply to invoices under €250 or tickets.
This is somewhat complicated. The legal regulations for electronic invoices in Germany vary depending on the recipient group and area of responsibility, especially when it comes to invoicing public institutions.

For companies in the healthcare sector, the regulations that stipulate the mandatory receipt of electronic invoices for B2B transactions from January 1, 2025 are particularly important.

Genuine electronic invoices, which consist of machine-readable data records, are designed primarily for automatic processing by computer programs. They are therefore not directly readable by the human eye. However, suitable visualization software, web portals, or conversion to PDF can make it possible for humans to decipher the e-invoice. These tools offer the opportunity to view electronic invoices in a familiar layout.

Please note: This method of presentation is no substitute for the legally binding nature of the electronic data record and should be regarded only as a supporting tool (posting aid). Therefore, do not use printed electronic invoices for the legally required voucher archiving. 

Yes, electronic invoices are GoBD-compliant. However, they must meet certain conditions. In principle, the e-invoice must be in a structured, machine-readable format according to the EN 16931 standard. In addition, electronic invoices must contain all legally required information, as is the case for paper invoices. This includes the invoice number, date, the addresses of the issuer and recipient, description of the goods or services supplied, net amount, and VAT. It is also important that the electronic invoice remains unalterable throughout the entire retention period and can be analyzed automatically at any time in order to meet the GoBD requirements.
There are several technical requirements for receiving electronic invoices that must be observed:

  1. Readiness to receive: From January 1, 2025, companies must demonstrate the ability to receive electronic invoices in a structured, machine-readable format. This can be done via a special e-invoicing system, an ERP system, or a portal.
  2. Suitable IT infrastructure: The company should not only ensure that the IT infrastructure can handle the expected volume of e-invoices but also integrate the e-invoice format into the accounting system and other relevant systems.
  3. Validation and processing: It is necessary that e-invoices can be reliably validated and processed. In other words, the validity and correctness of the invoices must be verifiable, the data should be transferable to other systems in the company, and the e-invoices must be archived in such a way that they are accessible in full and unchanged at all times. 

Failure to comply with the e-invoicing obligation in Germany can lead to various legal consequences. These include fines, late payments, or audits by the tax office. In addition, such a failure could damage a company’s reputation if business partners view it as unreliable and end their cooperation as a result.