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Differences between paper, PDF and e-invoices

by | Dec 17, 2020

In this article, we explain what makes an invoice an e-invoice that is compliant with the Federal Government’s Regulation on Electronic Invoicing by comparing the differences between the various invoice formats.

Since 2011, electronic invoices (e-invoices) have essentially been deemed equivalent to paper invoices for VAT purposes. Now, the introduction of e-invoicing into public administration is reaching a new milestone in the digitalisation of administration. Consequently, the Federal Administration has been obliged to accept and process e-invoices since late 2019. Now the invoice issuers are next in line: The obligation to invoice the Federal Administration electronically takes effect from 27 November 2020.

In reality, however, there are still a lot of unresolved questions about e-invoicing and everything it entails. After all, from a technical perspective, the term e-invoice is not clear. In general language usage, both visual representations and exclusively structured data formats are termed e-invoices. This quickly leads to a misconception however because visual representations, a PDF file for example, are not e-invoices according to the definition in the EU Directive 2014/55/EU. But if a PDF invoice does not constitute an electronic invoice, what exactly is the difference?

To give you an understanding, and to highlight the differences between the various formats, the common invoice formats are examined in detail below.

Paper invoice

The conventional paper invoice format is a visually represented invoice that does not enable automatic and electronic processing. Even digitising the invoice information (e.g. by scanning or a digital photo), which enables electronic processing, does not provide the invoice information in a structured form and it must then still be copied into the accounting software in a structured form manually or using additional systems.


Furthermore, a PDF invoice has in fact already been issued, submitted and received in electronic form but it is still a digital and visually represented invoice that does not enable automatic and electronic processing. The focus is purely on the paper-equivalent visual representation of the invoice content. For electronic processing, the invoice information must also be transferred into the accounting software, either manually or using additional systems (e.g. text recognition systems or OCR). The PDF invoice here is typical of a visually represented invoice. Other formats, e.g. .tif, .jpeg, .docx, are also suitable for a purely visual representation of the invoice.

The difference to e-invoicing

The main difference between a scanned paper or PDF invoice and an e-invoice is that an e-invoice is an invoice issued in a structured format in compliance with the EU standard, which is submitted and received electronically, and enables seamless automatic and electronic processing. This means that, unlike a paper or PDF invoice,

  • it is designed as a purely semantic data format and therefore enables invoice data to be imported into the processing systems directly and seamlessly.
  • It is also based on an XML format, which is primarily used for automated processing and is not suitable for a visual inspection. The XML record can be rendered human-readable using viewer programs however.

The diagram below shows the differences between paper, PDF and e-invoices. While paper and PDF invoices (left diagram) show human-readable visual representations, the e-invoice (right diagram) represents a structured data record.

Electronic invoicing can be enabled by means of various standards and specifications, including using the XRechnung standard for example.

  • To ensure that every Member State can implement the European standard (EN) 16931 with its own country-specific requirements, each country defines its own specific Core Invoice Usage Specification (CIUS).
  • Within this process, the XRechnung standard represents the national embodiment of the European standard EN 16931 in Germany, in other words the German CIUS, and was developed by the Coordination Office for IT Standards on behalf of the IT Planning Council.
  • In Germany, the XRechnung standard is used for the standardised implementation of the requirements of public contracting authorities within the Federal Government in the majority of states and local authorities.
  • When submitting an e-invoice to the Federal Government, any other standard (e.g. ZUGFeRD version 2.1.1 XRechnung profile, as a purely structured XML file) can also be used, if it meets the requirements of the European standard for electronic invoicing (EN–16931), the Federal Government’s Regulation on Electronic Invoicing (E-RechV) and the Federal Government’s terms of use for the invoice submission platforms.

Ultimately, paper-based processes are increasingly being replaced with digital processes. Both invoice issuers and invoice recipients therefore benefit from e-invoicing in terms of cost savings, efficiency and transparency.

If you still have questions about e-invoicing, see our FAQ section and our information pages for further details.

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Peppol for the Federal Administration

Peppol (Pan-European Public Procurement OnLine) is a compilation of components and specifications enabling the standardised exchange of documents between different business partners, using the infrastructure of the Peppol network.

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