As of January 1, 2025, the e-invoicing mandate applies in Germany for all companies in the B2B sector. This also affects the automotive trade – from large multi-brand dealerships to small independent used car dealers. In this comprehensive guide, you will learn everything you need to know as a car dealer about the e-invoicing obligation 2025: legal foundations, deadlines, formats, exceptions, and above all, concrete steps you should take now.
What Is an E-Invoice – and What Is Not?
First, an important clarification: An electronic invoice (e-invoice) is not simply a PDF file sent by email. An e-invoice is a structured, machine-readable data format that complies with the European standard EN 16931. Invoice data is transmitted in an XML format so that it can be automatically processed without manual entry.
Important: A PDF invoice sent by email will no longer qualify as an e-invoice under the law from 2025 onward. It will be classified as an “other invoice” and will progressively lose its validity in B2B transactions.
In practice, this means: Your invoices must in the future be created and transmitted in a format that can be automatically read by accounting systems. The two formats commonly used in Germany are XRechnung and ZUGFeRD (from version 2.0). Learn more in our comparison of ZUGFeRD and XRechnung.
The Growth Opportunities Act: Legal Basis for the E-Invoicing Mandate
The legal basis for the e-invoicing mandate 2025 is the Growth Opportunities Act (officially: “Act to Strengthen Growth Opportunities, Investment, and Innovation as well as Tax Simplification and Tax Fairness”). This was passed by the Bundesrat (Federal Council) on March 22, 2024 and came into effect in key parts on January 1, 2025.
The act fundamentally amends § 14 UStG (VAT Act). The most important changes:
- New Definition: An invoice within the meaning of the UStG will in the future only be an e-invoice (structured format per EN 16931) or an “other invoice” (everything else, including paper and PDF).
- Priority of the E-Invoice: In the B2B sector, the e-invoice becomes the standard. Paper invoices and PDFs are only permissible during a transitional phase.
- Receiving Obligation Effective Immediately: All companies have been required since January 1, 2025 to be able to receive e-invoices.
- Phased Sending Obligation: Sending e-invoices will become mandatory for all companies in stages by 2028.
The legislator’s goal is clear: The electronic invoice is meant to modernize business processes, curb tax fraud, and prepare Germany for the planned EU-wide reporting system “ViDA” (VAT in the Digital Age), which is expected to launch around 2030.
Timeline and Transitional Periods: What Applies When?
The introduction of the e-invoicing mandate occurs in several stages. The following timeline shows you exactly when which obligations take effect:
| Period | Obligation | Details |
|---|---|---|
| From 01/01/2025 | Receiving obligation for all | Every company must be able to receive and process e-invoices. No exceptions, no transitional periods. |
| 01/01/2025 – 12/31/2026 | Transitional Phase 1 | Invoices may still be sent as paper or PDF (with recipient consent). E-invoice sending is voluntary but recommended. |
| 01/01/2027 – 12/31/2027 | Transitional Phase 2 | Only companies with a previous year revenue under €800,000 may continue sending paper or PDF invoices (with recipient consent). All others must send e-invoices. |
| From 01/01/2028 | Full e-invoicing mandate | All companies must send e-invoices in the B2B sector. Paper and PDF are no longer permissible. |
Special Rule: EDI Procedures
Companies that already use EDI procedures (Electronic Data Interchange) may continue to use them until December 31, 2027 – even if the EDI format does not comply with the EN 16931 standard. From 2028, EDI formats must also meet the requirements of the EU standard or be replaced by compliant formats.
Who Is Affected? B2B Obligation in Detail
The e-invoicing mandate applies to all domestic B2B transactions (business-to-business), meaning invoices between two companies based in Germany. Specifically, this means:
Affected are:
- All companies based in Germany – regardless of size, legal form, or industry
- Freelancers and self-employed individuals who provide B2B services
- Car dealerships and automotive businesses for transactions with other companies (e.g. fleet sales, dealer-to-dealer sales, workshop services for corporate clients)
- All suppliers and service providers you commission as a car dealer (parts dealers, marketing agencies, IT service providers, etc.)
Exempted are:
- B2C transactions: Invoices to private customers are not affected by the e-invoicing mandate. As a car dealer, you may continue to issue private customer invoices as PDF or on paper.
- Small-amount invoices up to €250 gross (§ 33 UStDV)
- Travel tickets (§ 34 UStDV)
- Tax-exempt transactions under § 4 No. 8 to 29 UStG (e.g. certain insurance or financial services)
Practical Example for Car Dealerships: If you sell a vehicle to a GmbH (limited liability company), you must issue an e-invoice. If you sell the same vehicle to a private individual, a conventional invoice continues to suffice. For mixed businesses – which applies to most car dealerships – you therefore need a system that handles both.
Formats Compared: ZUGFeRD vs. XRechnung vs. PDF
Which format is right for your automotive business? Here is a detailed comparison of the three relevant invoice formats:
| Criterion | ZUGFeRD 2.0+ | XRechnung | PDF (classic) |
|---|---|---|---|
| Format | PDF/A-3 with embedded XML | Pure XML | PDF document |
| EN 16931 Compliant | Yes (from profile EN16931 upward) | Yes | No |
| Machine-Readable | Yes (XML part) | Yes (fully) | No |
| Human-Readable | Yes (PDF part) | No (only with viewer) | Yes |
| Qualifies as E-Invoice from 2025 | Yes | Yes | No |
| Ideal for | Companies wanting to retain PDF appearance | Public sector clients, purely digital processes | B2C, internal |
| Recommendation for Car Dealers | ★★★ Recommended | ★★ Well suited | ★ Only for private customers |
For most car dealerships and automotive businesses, we recommend ZUGFeRD 2.0 (or higher) as the preferred format. The advantage: ZUGFeRD combines a human-readable PDF with machine-readable XML data in a single file. This means your invoices still look professional when opened, while being fully compliant with the e-invoicing mandate. Find more details in our article ZUGFeRD vs. XRechnung in Detail.
What Does the E-Invoicing Mandate Specifically Mean for Car Dealers?
As an automotive business, you face particular challenges. The automotive trade has specific invoicing requirements that must be considered when switching to e-invoices:
1. Diverse Invoice Types
In the car trade, there are numerous invoice types: vehicle sales invoices, workshop invoices, partial invoices, warranty settlements, commission invoices, and more. Each of these invoice types must be representable in e-invoice format – with all industry-specific details such as vehicle identification numbers, margin taxation, or warranty information.
2. Margin Taxation (§ 25a UStG)
Many used car sales to companies are invoiced under margin taxation. The correct representation of margin taxation in e-invoice formats requires special attention. The XML schema must correctly flag the regulation, and VAT must not be shown separately.
3. Mixed B2B and B2C Operations
Most car dealerships serve both business and private customers. Your system must recognize when an e-invoice needs to be created (B2B) and when a conventional invoice suffices (B2C). Ideally, this happens automatically based on customer master data.
4. Integration with DMS and Manufacturer Systems
Car dealerships often work with complex IT landscapes: Dealer Management Systems (DMS), manufacturer portals, accounting software, archiving solutions. The e-invoice must integrate seamlessly into these systems.
5. GoBD-Compliant Archiving
E-invoices are subject to the GoBD (Principles for the Proper Management and Storage of Books, Records, and Documents in Electronic Form). This means: E-invoices must be archived in an audit-proof, unalterable manner for the duration of the statutory retention period (10 years). Learn more about GoBD-compliant archiving with AutoPult.
Penalties and Consequences for Non-Compliance
What happens if you ignore the e-invoicing mandate? The consequences can be significant:
- Input Tax Deduction at Risk: If you fail to issue proper e-invoices from the respective deadlines, the tax office could deny your customers the input tax deduction. This leads to significant problems in your business relationship.
- Fines: Violations of invoicing obligations can be penalized as administrative offenses with fines of up to €5,000 per violation (§ 26a UStG).
- Tax Audit Risk: Missing or incorrect e-invoices increase the likelihood of a tax audit and can lead to additional assessments and estimates.
- Business Disadvantages: Business partners who cannot process your invoices automatically will, in the medium term, look for other suppliers.
Even though the Federal Ministry of Finance has signaled some leniency for the initial phase, you should not delay the transition. The earlier you prepare, the smoother the changeover will be.
Step by Step: Implementing E-Invoicing in Your Car Dealership
Use these instructions to systematically introduce e-invoicing in your automotive business:
Step 1: Conduct an Assessment
Analyze your current invoicing situation: How many invoices do you issue monthly? How many are B2B? What software do you currently use? What interfaces exist to DMS, accounting, and DATEV? An honest assessment is the foundation for everything that follows.
Step 2: Define Requirements
Determine what your e-invoicing solution must be capable of: support for ZUGFeRD and/or XRechnung, integration with existing systems, automatic B2B/B2C recognition, representation of margin taxation, GoBD-compliant archiving, DATEV interface for your tax advisor.
Step 3: Select a Software Solution
Choose a solution specifically tailored to the requirements of the automotive trade. Generic invoicing software often fails at industry-specific requirements. AutoPult E-Invoice was developed specifically for car dealers and covers all requirements – from margin taxation to manufacturer integration.
Step 4: Update Master Data
Review and update your customer master data: Are business customers correctly flagged as B2B? Are VAT IDs on file? Are email addresses for e-invoice receipt stored? Clean master data is the prerequisite for smooth e-invoice dispatch.
Step 5: Start a Test Phase
Begin with a test phase: Create e-invoices in parallel with your conventional invoices and check them for accuracy. Send test e-invoices to selected business partners and gather feedback. Validate your e-invoices with official testing tools (e.g. the KoSIT validator).
Step 6: Adjust Processes
Adapt your internal processes: Define workflows for incoming and outgoing e-invoices. Train your staff in accounting, sales, and the workshop. Document the new processes for GoBD process documentation.
Step 7: Go-Live and Monitoring
Switch to e-invoice dispatch and intensively monitor the first few weeks: Are invoices arriving correctly? Are there questions from business partners? Is archiving working? Are invoices being correctly transferred to DATEV?
How AutoPult Solves the E-Invoicing Mandate for Car Dealers
AutoPult E-Invoice was developed specifically for the requirements of the German automotive trade. As an integrated solution within the AutoPult platform, the module offers everything you need for the transition – and more.
Automatic Format Generation
AutoPult automatically creates your invoices in the correct e-invoice format. Based on your customer master data, the system recognizes whether an e-invoice (B2B) or a conventional invoice (B2C) needs to be created. You can choose between ZUGFeRD 2.0 and XRechnung – or use both in parallel. Invoices are automatically validated against the EN 16931 standard.
Industry-Specific Features
AutoPult covers all the specifics of the car trade: Margin taxation per § 25a UStG is correctly represented in the XML, vehicle identification numbers and vehicle-specific data are automatically transferred, workshop invoices with labor items and spare parts are captured in a structured format.
Seamless Integration
As part of the AutoPult platform, e-invoicing is seamlessly integrated into your existing processes: vehicle sales, workshop billing, accounting, and archiving work together. The DATEV interface automatically transfers all data to your tax advisor.
GoBD-Compliant Archiving Included
Every e-invoice is automatically archived in a GoBD-compliant manner: audit-proof, unalterable, and searchable at any time. The statutory retention period of 10 years is automatically monitored. Comprehensive process documentation is integrated.
Processing Incoming E-Invoices
AutoPult also receives and processes incoming e-invoices from your suppliers and service providers. The system automatically reads the XML data, assigns it, and prepares it for accounting. This way, you also benefit from digitalization on the receiving side.
Tip: AutoPult offers not only e-invoicing functions but a complete invoicing software for car dealers that covers all invoice types in the automotive business – from vehicle invoices to workshop invoices to commission statements.
Frequently Asked Questions About the E-Invoicing Mandate
When does the e-invoicing mandate 2025 take effect?
The receiving obligation has been in effect since January 1, 2025. From this date, every company must be able to receive e-invoices. The sending obligation is being introduced in stages: Until the end of 2026, all companies may still send paper or PDF invoices. From 2027, only companies under €800,000 in annual revenue. From January 1, 2028, the full e-invoicing mandate applies to all.
As a small used car dealer, do I also need to create e-invoices?
Yes, if you issue invoices to other companies (B2B transactions). The e-invoicing mandate applies regardless of company size. As a small business, however, you benefit from the transitional period until the end of 2027 (with revenue under €800,000). Invoices to private individuals (B2C) are not affected.
Does the e-invoicing mandate also apply to workshop invoices?
Yes, if the workshop customer is a company (e.g. a company car). Workshop invoices to private customers remain exempt from the mandate. In practice, it is therefore important that your system automatically distinguishes between B2B and B2C customers.
What do I do with margin taxation for e-invoices?
Margin taxation per § 25a UStG must be correctly represented in the e-invoice format. The XML must contain appropriate indicators, and VAT must not be openly displayed. Specialized software like AutoPult E-Invoice handles this automatically.
Is an email inbox sufficient for receiving e-invoices?
Technically yes – the law does not prescribe a specific transmission method. A simple email inbox is fundamentally sufficient for receiving. However, you must then also be able to process and archive the received e-invoices in a GoBD-compliant manner. A simple email inbox without further software will therefore not be sufficient in practice.
What is the difference between ZUGFeRD and XRechnung?
XRechnung is a pure XML format – machine-readable but without a human-readable representation. ZUGFeRD (from version 2.0) combines a PDF/A-3 document with embedded XML data – making it readable for both humans and machines. Both formats meet the EN 16931 standard and are suitable for the e-invoicing mandate. For car dealers, we generally recommend ZUGFeRD as it retains the familiar PDF appearance. More details in our comprehensive format comparison.
Can I create e-invoices with my existing DMS?
That depends on your DMS provider. Many traditional Dealer Management Systems do not yet support e-invoicing, or only to a limited extent. AutoPult can be used as a supplementary solution alongside your existing DMS or fully integrated as an invoicing software.
What does the transition to e-invoices cost?
Costs vary depending on the starting situation and chosen solution. With AutoPult, the e-invoicing function is part of the overall package – there are no additional costs for individual e-invoicing modules. Also consider that digitalizing your invoicing processes saves time and money in the long run: fewer manual entries, faster processing, fewer errors, and more efficient accounting.
Checklist: Are You Ready for the E-Invoicing Mandate?
Use this checklist to assess your level of preparation:
- E-invoice receiving is technically possible (email inbox or platform)
- Software for creating e-invoices in ZUGFeRD or XRechnung format is available
- Customer master data is current (B2B/B2C classification, VAT IDs, email addresses)
- Margin taxation is correctly represented in the e-invoice format
- GoBD-compliant archiving for incoming and outgoing e-invoices is set up
- DATEV interface for the tax advisor is configured
- Staff in accounting, sales, and the workshop are trained
- Process documentation is updated
- Test run with selected business partners has been successfully completed
- Internal workflow for incoming e-invoices is defined
Conclusion: Act Now Rather Than Wait
The e-invoicing mandate 2025 is not distant future talk – it is already reality. Since January 1, 2025, you as a car dealer must be able to receive e-invoices, and by 2028 at the latest, you must also send them. The transitional periods still give you some breathing room, but experience shows: the earlier you transition, the better.
Early transition brings tangible benefits: You avoid last-minute stress, gain experience handling e-invoices, benefit from more efficient processes, and position yourself as a modern, reliable partner to business associates.
AutoPult E-Invoice makes getting started as easy as possible. As an industry-specific solution for the German automotive trade, AutoPult covers all requirements – from format generation to margin taxation to GoBD-compliant archiving and DATEV integration.
Ready for the e-invoicing mandate? Discover how AutoPult E-Invoice makes your automotive business fit for the digital future. Or learn about our complete invoicing software for car dealers, which unifies all your invoicing processes in one solution.
