Since 1 January 2025, B2B companies in Germany have been required to be able to receive structured electronic invoices. From 2027, they will have to issue e-invoices themselves. This sounds like a technical requirement that IT solves. It is a process requirement that changes the entire AP workflow.
This article describes what the e-invoicing obligation concretely means, what effects it has on AP processes, which mistakes are systematically made during implementation, and what a CFO must do now.
What the e-invoicing obligation really is and what it is not
An e-invoice in the sense of the new obligation is a structured, machine-readable format. The relevant formats in Germany are XRechnung and ZUGFeRD. A PDF sent by email is not an e-invoice in the legal sense. A scanned document is not an e-invoice. An Excel file is not an e-invoice.
What counts as an e-invoice: XRechnung is a purely structured XML format with no visual representation. ZUGFeRD combines a visually readable PDF with an embedded XML data set. Both formats must comply with the requirements of EN 16931.
What concretely changes in the AP process
The receiving process changes fundamentally
Today: invoices arrive by post or email, are captured manually or via OCR, and transferred into the ERP system.
Tomorrow: invoices arrive as a structured file, are validated in machine-readable form, and fed directly into the ERP system. This sounds simpler. It only is if the prerequisites are in place.
The three-way match becomes more complex and more important at the same time
When structured invoice data is fed directly into the system, the system expects an automatic match against the purchase order and goods receipt. A low three-way-match rate that is currently absorbed by manual rework becomes a scaled problem in an e-invoicing environment.
Master data quality becomes the decisive success factor
E-invoices are validated against master data. Supplier IDs, routing IDs (Leitweg-IDs), purchase order numbers, tax numbers. If the master data is not clean, validation fails. This creates manual interventions that undo the efficiency gains of the system.
The archiving requirements become stricter
E-invoices must be archived unaltered and in machine-readable form. The retention period is 10 years. This places demands on the archiving system that go beyond the previous requirements.
The most common mistakes during implementation
The implementation is treated as an IT project. E-invoicing implementation is not an IT project. It is a process change project that has IT components.
Supplier coordination is forgotten. Not all suppliers are ready or able to issue e-invoices. Coordinating with suppliers takes time.
The transition phase is underestimated. During the transition phase, e-invoices and conventional invoices run in parallel. This creates processes that have to be managed twice over.
Validation is not defined. What happens when an incoming e-invoice fails validation? Who is informed? Which process takes effect?
What a CFO must concretely do now
As-is analysis of the current AP process. System check and requirements definition. Master data cleansing for all relevant suppliers. Process definition for e-invoices. Supplier communication and coordination. Pilot phase with selected suppliers. Training of the AP team.
What I bring
I am Nicole Vekonj, Interim Finance & Controlling Manager. I guide AP process changes from the as-is analysis through to stable implementation, with an understanding of what e-invoices really mean in day-to-day operations.
👉 Submit a project enquiry: zahlenkompetenz.de/en/contact
