---
id: RISK-POL-0012
type: legal-policy
title: "E-invoicing"
regime: "UStG §14 (as amended by the Wachstumschancengesetz), EN 16931, ViDA"
status: active
activates_when: "the estate is a German business receiving B2B invoices — already true"
owner: risk-nexus
written: "2026-08-20"
cadence: instant
clean_streak: 0
last_checked: "2026-08-20T21:30:00Z"
next_check: "2026-08-20T21:30:00Z"
---

# RISK-POL-0012 — e-invoicing

**Active now, on the receiving side.** Since 1 January 2025 a German business
must be **able to receive** a structured electronic invoice conforming to
EN 16931 for domestic B2B transactions. That obligation had no transition
period: the issuing obligations are phased, the receiving one was not.

Issuing obligations phase in afterwards, with thresholds by turnover. The
estate should assume it will be required to issue conformant invoices before it
notices the deadline, because the receiving obligation arrived that way.

## What it requires of systems

- An inbox that accepts a structured invoice (XRechnung, or ZUGFeRD's hybrid
  PDF/A-3 carrying the XML) and does not treat it as an attachment to be
  eyeballed.
- Storage of the **structured original**. A rendered PDF is not the invoice; a
  human-readable copy alongside it is not sufficient by itself.
- Retention per `RISK-POL-0009` — eight years for the voucher, in the original
  format it was received in.

## Where it bears on this estate

`markitect` and `binect-js` handle document flows, and `rapp-qonto`/`fin-hub`
touch payment and banking records. None of them is currently claimed to be the
receiving point for statutory invoices, and **this policy does not assign that
role** — naming the system that must satisfy this is the owning repo's
decision, not the register's.

What the register records is that the duty exists, is live, and currently has
no named owner in the estate.

## Evidence that would show this is met

A demonstrated receipt and archival of an EN 16931 invoice, retained in its
structured form, retrievable at eight years.

Not established. If a supplier sends one tomorrow, nobody here can say what
happens to it — which is a small, ordinary, entirely fixable gap, and exactly
the kind that only becomes visible when it is written down.