This article describes the situation in Germany (German law and practice). It is a translation of the German original and is not legal or tax advice.
Martin Felux, civil engineer and industrial engineer
A well-organised intake for an e-invoice (E-Rechnung) has six steps: one mailbox, checking the data record, allocation to the building project, approval by site management, unalterable storage and handover to accounting. A program reads the file. My assumption, not measured: allocation and approval take the most time, because people have to decide there.
- Incoming mailbox One mailbox for all invoices, collected daily
- Check data record Read the XML, check format and totals by rule
- Suggest allocation Suggestion from project number, order, supplier AI prepares
- Site approval Readable view with attachment, a person confirms
- Archive Store XML, attachments and check report unaltered
- Accounting Account coding and input VAT stay with the tax adviser
Text version of the graphic
- 1. Incoming mailbox: One mailbox for all invoices, collected daily
- 2. Check data record: Read the XML, check format and totals by rule
- 3. Suggest allocation: Suggestion from project number, order, supplier (the AI prepares)
- 4. Site approval: Readable view with attachment, a person confirms
- 5. Archive: Store XML, attachments and check report unaltered
- 6. Accounting: Account coding and input VAT stay with the tax adviser
How it often works today
A survey by the ZDH (Zentralverband des Deutschen Handwerks, the German Confederation of Skilled Crafts) of almost 2,000 craft businesses (press release of 18 May 2026) found an average of around 1,200 incoming invoices for 2025, of which only about half arrived as an e-invoice. Processing is mostly manual; fully automated workflows are the exception. About half of the businesses find receiving and processing more laborious than with a PDF invoice. The figures apply to craft businesses, not to all construction companies, but they give a rough guide.
A typical picture, as a sketch and not a measured value: the invoice arrives with one person and is forwarded, printed or put in a folder. Site management gets it by email, the document goes to accounting, and the XML file stays unopened. Who allocates it to a building project and when the early-payment discount (Skonto) period ends is, in the end, known only to whoever had the email.
Receiving an e-invoice: mailbox and check
You can receive e-invoices with an email mailbox (BMF letter of 15 October 2024, a circular of the Federal Ministry of Finance; below “BMF 2024”, para. 40). In its FAQ, the Federal Chamber of Tax Advisers (Bundessteuerberaterkammer, BStBK) recommends retrieving e-invoices daily or several times a day and documenting receipt. If the email serves only as a means of transport, like an envelope, it does not have to be kept as well. If it contains details that must themselves be retained, keep it unaltered. You may also keep it voluntarily to evidence sender and time.
Then the data record is checked. With ZUGFeRD, the embedded XML is read, not the PDF image by OCR. A validation shows format errors and business-rule errors. According to the FAQ, mere warnings are in principle no reason to reject the invoice. What validation does not find is described in the article “XRechnung and ZUGFeRD: what the data set holds, how to read it”.
XML needs no AI for this. Only a PDF without a data record, or a scan, has to be read out first. Because a wrongly read amount is expensive, a person confirms the fields there.
Invoices do not have to arrive by email. The BMF also names an electronic interface or a download via a portal as possible transmission routes (BMF 2024, para. 36). The more routes you allow, the more important a duplicate check becomes: if the same file is sent twice, that is harmless for tax purposes (para. 39), but it may be booked and paid only once.
Allocation to the building project
An invoice does not always carry a project number. Without a fixed rule it ends up with the wrong project. So decide what the allocation is based on:
- an order number or contract number that you give to the supplier,
- the project number in the reference of the data record,
- supplier and trade, if the supplier works on only one project.
An AI suggestion should be allowed to choose only values from the project list, and it should say “unclear” when nothing fits. Site management confirms or changes it. The suggestion saves searching; the decision stays with site management.
Approval by site management
Site management checks whether the invoiced work was carried out. For this the BStBK describes a checking path: the service on the invoice is compared with the order, the contract and the delivery note, at the level of the data record, using a program that makes the XML readable. Payment is instructed after the check at the earliest.
The attachments belong to this. The bill of quantities (BoQ), site measurements and timesheets are the basis of the approval. What the BMF says about these attachments is in the article “Interim and final invoices and measurement in e-invoicing”.
If the invoice has defects, it is queried with the issuer, and no payment should be made until this is resolved (BStBK FAQ). A correction is also made as an e-invoice where an obligation to issue an e-invoice applies (BMF letter of 15 October 2026, para. 20).
- Does the invoice arrive as a structured data record (XML)?
Yescontinue
NoPDF or scan: read the fields, a person confirms
- Does validation pass without errors (warnings are allowed)?
Yescontinue
NoQuery with the issuer, no payment until it is resolved
- Does the invoice match a building project in the project list?
YesSuggestion is set, site management confirms
NoStatus unclear, site management allocates by hand
- Does site management confirm the work was carried out?
YesApproval, with the Skonto deadline visible
NoQuery with the issuer, no payment
- ResultData record, attachments and check report sit unaltered in the archive
Text version of the graphic
- 1. Does the invoice arrive as a structured data record (XML)? Yes: continue. No: PDF or scan: read the fields, a person confirms.
- 2. Does validation pass without errors (warnings are allowed)? Yes: continue. No: Query with the issuer, no payment until it is resolved.
- 3. Does the invoice match a building project in the project list? Yes: Suggestion is set, site management confirms. No: Status unclear, site management allocates by hand.
- 4. Does site management confirm the work was carried out? Yes: Approval, with the Skonto deadline visible. No: Query with the issuer, no payment.
- Result: Data record, attachments and check report sit unaltered in the archive
Making the early-payment discount deadline visible in the process
The early-payment discount (Skonto) is an agreement between you and the supplier. If the amount of the reduction is not fixed when the invoice is issued, the invoice must refer to the agreement. A general reference is not objected to if the agreement exists in writing and can be produced quickly (BMF 2026, paras 15 and 16). The deadline is therefore often found only in the agreement and not in the data record. Record the date of receipt and enter the end of the deadline in the approval. Then site management can see how much time is left.
Archiving an e-invoice: storage and accounting
Invoices must be kept for eight years (section 14b of the German VAT Act, Umsatzsteuergesetz, UStG). The period starts at the end of the calendar year of issue and can run longer, as the article Retaining e-invoices: data set, period and archive explains. For an e-invoice, at least the structured part must be kept so that it exists intact in its original form (BMF 2024 as amended in 2025, para. 60). Incoming documents must be kept in the format in which they were received, for an e-invoice that is XML (GoBD para. 131). Storage outside a system that meets the GoBD (German principles for proper bookkeeping and record-keeping) is not in itself a breach of section 14b UStG for VAT purposes, but the GoBD continue to apply for other tax purposes (BMF 2025, paras 60 and 61). According to the BStBK FAQ, the requirement that nothing may be altered also covers tax-relevant additional information in an accompanying document. If the data record is converted into an in-house format, both versions are archived under the same index under GoBD para. 135, and the converted version is marked as such.
After that, accounting or the tax adviser (Steuerberater) assigns the account codes. The technology does not do this; for the demarcation see section 2 of the Tax Advisory Act (Steuerberatungsgesetz, StBerG).
Who clarifies what
| The tax adviser clarifies | The technology supplies |
|---|---|
| Account coding, tax codes, input VAT deduction | Mailbox, reading and validating with a report |
| Treatment under section 13b UStG (reverse charge) | Suggestion for the building project, confirmation by site management |
| Whether the archive meets the GoBD and the invoice is in order for tax purposes | Approval workflow with attachment, unalterable storage, handover to accounting |
The BStBK also advises agreeing between client and tax adviser who takes over the technical check of format and business rules in addition to the check of content. That depends on whether you validate yourself before filing or the firm does it with its software.
Invoices contain personal data, for example the names of sole traders and account details. Such an intake can be operated in line with the GDPR if access, deletion periods and service providers are regulated. Your data protection officer clarifies the individual case.
What you can do now
- Set up an invoice mailbox and decide who retrieves it every day.
- Decide what you use to recognise a building project, and keep a list of project and order numbers for this.
- Determine for each building project who approves and who stands in.
- Ask your tax adviser where XML files together with their attachments should be stored unaltered.
General information, not legal or tax advice. Your tax adviser clarifies the individual case. As at 13 November 2026.
General information, not legal or tax advice. Your tax adviser, data protection officer or lawyer will clarify the individual case.
Frequently asked questions
Do I need a separate email mailbox for e-invoices?
No. According to the BMF letter of 15 October 2024, an email mailbox is enough; it does not have to be set up solely for e-invoices (para. 40). A separate mailbox makes retrieval and documentation easier.
May I print the e-invoice and file the printout?
Not as a substitute. Under the GoBD, electronically received invoices may no longer be kept solely in printed form (para. 119). According to the BMF, at least the structured part must be kept intact in its original form (BMF letter of 15 October 2024 as amended on 15 October 2025, para. 60). In its FAQ, the Federal Chamber of Tax Advisers recommends prohibiting printing combined with keeping only the printouts by an internal organisational instruction. Whether your archive meets this is for your tax adviser to clarify.
Does site management have to read the XML file?
No. A visualisation displays the data record in readable form. Site management needs this view, together with attachments such as the bill of quantities and timesheets, in order to approve.
Sources
- BMF-Schreiben vom 15.10.2024 zur E-Rechnung, Bundesfinanzministerium, Rn. 36, 39, 40, 62 (BMF letter on e-invoicing) (retrieved on 13 November 2026)
- BMF-Schreiben vom 15.10.2025 (Änderung Rn. 60 und 61), Bundesfinanzministerium (BMF letter amending paras 60 and 61) (retrieved on 13 November 2026)
- BMF-Schreiben vom 15.10.2026, ergänzende Regelungen, Bundesfinanzministerium, Rn. 15, 16, 20 (BMF letter with supplementary rules) (retrieved on 13 November 2026)
- Bundessteuerberaterkammer: FAQ zur E-Rechnung (Stand 3.3.2026), Abschnitt 3 (Federal Chamber of Tax Advisers, FAQ on the e-invoice) (retrieved on 13 November 2026)
- § 14b UStG (Aufbewahrung von Rechnungen) (retention of invoices) (retrieved on 13 November 2026)
- ZDH: E-Rechnung, noch mehr Aufwand statt Entlastung (Pressemitteilung 18.5.2026) (press release of the German Confederation of Skilled Crafts) (retrieved on 13 November 2026)
- BMF-Schreiben vom 14.07.2025, GoBD, 2. Änderung (Rz. 119, 131), Bundesfinanzministerium (BMF letter amending the GoBD) (retrieved on 13 November 2026)
- GoBD vom 28.11.2019 im AO-Handbuch 2023 (ohne die Änderungen von 2024 und 2025), Rz. 119, 131, 135 (GoBD in the tax code handbook, without the 2024 and 2025 amendments) (retrieved on 13 November 2026)
- § 2 StBerG (Befugnis zu geschäftsmäßiger Hilfeleistung in Steuersachen) (authority to provide tax assistance on a commercial basis) (retrieved on 13 November 2026)