An XML e-invoice may be sent together with a readable representation of the same invoice. For an additional PDF, the German tax authorities explicitly confirm that this is permitted. An accompanying Word document is also generally possible, although it does not independently meet the requirements for an e-invoice.
The decisive factor is that both files represent the same invoice and contain no contradictory information relevant to tax law. The number of files alone does not create an additional VAT liability. [1, 2, 3]
For businesses and professional practices, this distinction has immediate practical implications. Accounting departments require structured data, while invoice approval is often carried out using an easily readable document. Both workflows can be combined, provided that invoice creation, transmission, and archiving rely on a single, consistent set of invoice data.
What Qualifies as an E-Invoice Under German Law?
Section 14(1) of the German VAT Act (Umsatzsteuergesetz, UStG) requires an e-invoice to use a structured electronic format that enables electronic processing. An ordinary PDF or Word document, by contrast, falls into the category of other invoices.
The XML file extension alone is not sufficient. The data record must satisfy the statutory requirements for the applicable format. [1]
XRechnung and suitable ZUGFeRD formats are widely used implementations. ZUGFeRD combines the readable invoice representation and the structured data record in a single file.
By contrast, sending two separate attachments — for example, an XRechnung file and an ordinary PDF — does not turn them into a hybrid ZUGFeRD invoice. This distinction should be considered when selecting the invoice transmission method. [4]
Why Sending an Additional PDF Is Permitted
The German Federal Ministry of Finance (Bundesministerium der Finanzen, BMF), in its letter dated 15 October 2024, states in paragraph 6 that an additional human-readable document may optionally be transmitted. The guidance expressly mentions both hybrid formats and an additional PDF. The tax authorities therefore do not require an XML file to be transmitted exclusively. [2]
The second file must be understood as an alternative representation of the same invoice. The invoice number, issue date, parties involved, supply or service, consideration, and VAT details must be substantively consistent. Differences in layout, page breaks, or graphic design do not create a separate invoice.
The cited passage does not establish an explicit special rule for Word documents. The general permissibility of an additional Word representation instead follows from the treatment of multiple identical copies and the fact that German VAT law does not prescribe a specific format for an additional readable representation.
As a practical recommendation, PDF is preferable. It provides a more stable presentation and reduces the risk of unintended changes. However, a PDF is not automatically immutable either. [1, 2, 3]
Invoice Copies Versus Separate Invoices
Section 14c.1(4), sentence 6, of the German VAT Application Decree (Umsatzsteuer-Anwendungserlass, UStAE) excludes substantively identical multiple copies of the same invoice from the consequences associated with issuing multiple invoices. Explicitly marking a document as a copy is not a prerequisite for this exception.
The BMF letter dated 15 October 2025 adds in sentence 7 that repeatedly transmitting an e-invoice file is also harmless where the file is merely sent more than once as a substantively identical copy of the same invoice. [3, 5]
The situation may be different when several separate invoices are issued for the same supply or service. In such cases, any additional tax liability under Section 14c of the German VAT Act must be examined.
Neither the number of attachments nor the word “invoice” in a filename determines the outcome. The decisive factor is the actual content of the billing documents. [3, 6]
A note such as “Readable representation of the attached e-invoice. No additional payment request” is therefore a useful administrative measure. It helps the recipient associate both files with a single transaction. However, such a note does not compensate for inconsistencies between their contents.
Discrepancies Between XML Data and the Invoice Image
For hybrid invoices, Section 14c.1(4a) of the UStAE expressly provides that a visual representation containing different invoice details relevant to tax law may constitute an additional invoice in another format. In that case, the requirements of Section 14c of the German VAT Act must be examined.
Minor technical discrepancies or supplementary information are not challenged under the conditions specified in that provision, provided that the document retains its character as an identical copy. This rule directly concerns hybrid formats. Separate XML and PDF files are subject to the general rules governing multiple copies. [5]
In practice, both representations should be generated from the same approved data set. For example, if the invoice amount is changed in Word after the XML file has been generated, both files must be reconciled again before transmission.
Labeling a document as a copy does not make an inconsistent representation legally harmless.
Mandatory Invoice Information and Supplementary Service Records
As a general rule, all mandatory information required under VAT law must be included in the structured part of the e-invoice. A missing description of the supply or service cannot be remedied merely by including that information in the accompanying PDF.
The structured data must identify the invoiced supply or service clearly and in a manner that allows it to be readily verified. Additional details, such as comprehensive time sheets, may be included in an attachment incorporated into the e-invoice. Specific rules for particular situations must also be observed, such as the deduction of advance payments already received in final invoices. [4, 5]
For example, a patent law firm could identify the patent application concerned, the specific work performed, and the service period in the structured service description. An attachment could then explain the individual work steps in greater detail.
This example is a recommendation for invoice design. Whether the description is sufficient in a particular case depends on the actual supply or service being invoiced.
Technical validation helps identify format errors and business-rule violations. According to the BMF FAQ, however, validation is not itself a direct prerequisite for tax recognition, nor does it replace a substantive review of the invoice. [4]
Invoice Transmission and Archiving in Daily Law Firm Operations
The tax-law permissibility of an additional PDF does not resolve every question concerning the transmission method. A recipient portal may impose technical restrictions on the number and type of attachments.
Invoices issued to public-sector contracting authorities are also subject to the applicable rules governing electronic invoicing in public procurement. If a submission is rejected for technical reasons, it should therefore be re transmitted through an appropriate channel. [4]
As an organizational recommendation, law firms should store both representations under the same invoice number, record the invoice only once in their accounts, and approve it for payment only once. Proof of transmission, the approved invoice version, and any subsequent corrections should be associated with the same transaction.
A subsequent change to the visual representation alone does not create a consistent set of invoice records.
Section 14b of the German VAT Act generally provides for an eight-year retention period, calculated from the end of the year in which the invoice was issued. Any additional retention obligations must also be observed.
For e-invoices, at least the structured component must be preserved intact in its original form. A printout or ordinary PDF does not replace the XML file. If attachments contain other information subject to retention requirements, that information must also be preserved. [7, 4]
Law firm management software should therefore manage the structured invoice and its readable representation as related documents. Generating both files from a central data set, maintaining a traceable approval process, and linking the documents permanently to the corresponding accounting entry help prevent errors caused by separate processing.
Sending both representations together is therefore a permissible and practical process, provided that both consistently represent the same invoice.
Creating Individual and Consolidated Invoices with Genese
With Genese, e-invoices can be created easily as individual invoices or consolidated invoices. This allows a law firm to process a single billing transaction or combine multiple services for the same invoice recipient into one invoice.
The appropriate option depends on the agreed billing arrangement and the client’s requirements. E-invoicing thus becomes an integrated part of the firm’s day-to-day workflow.
An individual invoice may be suitable for a specific completed task in an intellectual property matter. A consolidated invoice can group several billable services for the same client, such as work performed during a billing period across multiple intellectual property rights.
Even in a consolidated invoice, the services, relevant service dates or periods, consideration, and VAT details must remain clearly identifiable and verifiable. Different invoice recipients do not become a single invoice recipient merely because they belong to the same corporate group. [1]
A consolidated invoice must be distinguished from the collective transmission of invoices.
When several separate invoices are transmitted together, each retains its own invoice number and remains a separate billing transaction. A consolidated invoice, by contrast, combines several services into one invoice.
This distinction is important for accounting and payment allocation. A PDF that summarizes several individual invoices does not turn the associated XML files into a single structured consolidated invoice.
Genese supports the delivery of generated e-invoices through customer portals, Gweb, or email. The appropriate method depends on the agreed process and the technical requirements of the invoice recipient.
The actual e-invoice file must be transmitted or made available for retrieval. Merely displaying a visual invoice representation in a portal is not sufficient for this purpose. An identical readable representation may be provided in addition.
XRechnung and the Leitweg-ID for Public-Sector Invoices
For XRechnung invoices addressed to public-sector contracting authorities, the Leitweg-ID supplied by the recipient enables unique addressing and routing within the designated invoice-receipt platform. It is included in the structured invoice data as the buyer reference.
The Leitweg-ID is not itself a transmission channel and does not initiate the sending process. The invoice must also be transmitted through an approved route, such as uploading it to a designated portal or sending it to the appropriate platform email address.
Making an invoice available through Gweb does not automatically replace a mandatory public-sector submission channel. [8]
For ordinary business-to-business invoicing, a Leitweg-ID is not required, even when the XRechnung format is used.
Genese’s supported creation and delivery of individual and consolidated invoices can therefore accommodate the different receipt processes used by clients. As an organizational recommendation, the matter-file reference, selected transmission method, and exact version sent should remain traceable within each invoice transaction. [4]
Legal Disclaimer
The statements concerning administrative practice are based on the German VAT Application Decree and the relevant BMF letters. These documents are administrative guidance rather than independent legislation; they do not bind the courts in the same way as statutory provisions.
This article addresses general VAT requirements and does not replace an assessment of specific circumstances.
The statutory and administrative sources cited in this article have been reviewed for the purposes of its preparation.
Sources and Legal References
[1] German VAT Act (Umsatzsteuergesetz), Section 14 — Invoicing, particularly paragraphs 1, 3 and 4
https://www.gesetze-im-internet.de/ustg_1980/__14.html
[2] BMF letter dated 15 October 2024, reference III C 2 — S 7287-a/23/10001:007, particularly paragraph 6. Official text reproduced by NWB.
https://datenbank.nwb.de/Dokument/1046425/
[3] German VAT Application Decree (UStAE), Section 14c.1(4), sentences 5 and 6. Official 2024 German VAT Handbook; see source [5] for the 2025 amendment.
[4] BMF FAQ on mandatory e-invoicing, as of March 2026, particularly questions 4a, 7, 7a, 7b, 8 and 13.
https://www.bundesfinanzministerium.de/Content/DE/FAQ/e-rechnung.html
[5] BMF letter dated 15 October 2025, reference III C 2 — S 7287-a/00019/007/243, particularly the amendments to Section 14c.1(4), sentence 7, and paragraph 4a. Official text reproduced by NWB.
https://datenbank.nwb.de/Dokument/1072024/
[6] German VAT Act, Section 14c — Unlawful or incorrect VAT disclosure
https://www.gesetze-im-internet.de/ustg_1980/__14c.html
[7] German VAT Act, Section 14b — Retention of invoices
https://www.gesetze-im-internet.de/ustg_1980/__14b.html
[8] Procurement Office of the Federal Ministry of the Interior (BMI), information for federal administration invoice issuers, particularly the Leitweg-ID and transmission via OZG-RE.
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