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Germany, France, Austria

What each country requires of an invoice issuer, and what euinvoice does and does not cover. Checked 2026-10-28. This page is not tax advice. It records what the cited sources say, so you can check them; confirm your own case with a tax adviser.

Fact markers: unmarked facts were read in the official source linked next to them. Facts marked (secondary) were read in a tax-firm or vendor page, not in an official text. Facts the sources did not settle are listed as unconfirmed.

Germany

Mandate and dates.

  • An E-Rechnung is a structured invoice that conforms to EN 16931, or to an agreed format that can be converted into it (§14 Abs. 1 UStG).
  • The E-Rechnung duty applies to supplies between businesses that are both established in Germany (§14 Abs. 2 S. 2 Nr. 1 UStG), except supplies exempt under §4 Nr. 8 to 29. Supplies to non-business legal persons need an invoice, not an E-Rechnung. Apart from land-related work (Nr. 3), there is no invoice duty towards private consumers.
  • The E-Rechnung rules apply to supplies made since 2025-01-01, so receiving E-Rechnungen has been required since then. Issuing is in transition, and each step requires the invoice to be sent by the end of the stated year (§27 Abs. 38 UStG):
    • supplies made in 2025 or 2026: paper, or another electronic format with the recipient's consent, if the invoice is sent by 2026-12-31 (Nr. 1);
    • supplies made in 2027: the same, if the invoice is sent by 2027-12-31, but only for issuers whose prior-year Gesamtumsatz (§19 Abs. 2 UStG) was at most 800 000 EUR (Nr. 2). Any other issuer may use a non-EN 16931 electronic format only via EDI (Recommendation 94/820/EC) and with the recipient's consent (Nr. 3);
    • supplies made from 2028: E-Rechnung for everyone.
  • Invoices up to 250 EUR gross may stay "sonstige Rechnungen". The test applies to the whole invoice total. It does not apply to supplies under §§3c, 6a and 13b UStG (§33 UStDV).
  • Small businesses (Kleinunternehmer, §19 UStG) may always send their invoices for exempt supplies as "sonstige Rechnungen", with no end date (§34a UStDV).
  • Federal public buyers: e-invoices are required, normally XRechnung (other EN 16931-conformant standards are allowed, §4 Abs. 1 ERechV) with a Leitweg-ID (§5); direct orders up to 1 000 EUR are exempt (§3 Abs. 3) (ERechV). The Leitweg-ID goes in BT-10, Buyer reference (e-rechnung-bund.de). ZRE was merged into OZG-RE (final migration 2025-09-19, platform consolidation); OZG-RE is the federal portal, though indirect federal bodies may run their own (e-rechnung-bund.de).

Accepted formats.

  • Per the BMF letter of 2025-10-15 (secondary; the BMF site was not reachable on 2026-10-28; summaries: taxpunk synopsis, Haufe): for example XRechnung, and ZUGFeRD 2.0.1 or later except MINIMUM and BASIC-WL; any EN 16931-conformant format qualifies (secondary). In a hybrid PDF the XML prevails.
  • XRechnung 3.0.2 is the current version. A 4.0 final is expected in spring 2027, driven by EN 16931-1:2026 (xeinkauf.de, outlook).

Delivery.

  • B2B: per the BMF letter (secondary), e-mail is enough. There is no clearance step.
  • B2G: OZG-RE web form, upload, Peppol or e-mail (e-rechnung-bund.de). The Peppol recipient id is 0204:<Leitweg-ID> (Peppol guide).

euinvoice today. XRechnung 3.0.2 in UBL and CII, validated against the KoSIT rules; Factur-X EN 16931 and XRECHNUNG levels (both qualify under the BMF letter, secondary); the BT-10 Leitweg-ID pre-flight check for XRechnung. Not covered: sending (e-mail, OZG-RE, Peppol; see #114); Factur-X-level Schematron rules (#42); XRechnung 4.0 and EN 16931-1:2026 (#180).

Unconfirmed: the primary text of the BMF letter, and the rules of the individual Länder portals.

France

Mandate and dates. The reform is in force since 2026-09-01: every company in scope of the reform (taxable persons established in France) must be able to receive e-invoices, and large companies and mid-sized companies (ETI) must issue e-invoices and e-report. SMEs and micro-enterprises follow on 2027-09-01 (DGFiP guide, July 2026). The guide mentions a start-up tolerance without sanctions; the official text gives no end date.

Scope.

  • E-invoicing covers domestic B2B between taxable persons established in France. A foreign company with no French permanent establishment is not subject to e-invoicing; only e-reporting may apply (impots.gouv.fr).
  • E-reporting for such a company covers transactions in France subject to French VAT. It does not apply to transactions with non-taxable persons if the seller is registered in the EU VAT One Stop Shop (impots.gouv.fr).
  • A third party may issue invoices on the supplier's behalf (mandat de facturation, CGI 289 I-2). The invoice stays the supplier's and goes through the platform under the supplier's SIREN (secondary: guide-plateforme-agreee.fr).

Accepted formats. Factur-X, UBL (EN 16931 France CIUS) and UN/CEFACT CII (EN 16931 France CIUS) (peppol.org). The profiles are defined by AFNOR XP Z12-012, the platform APIs by XP Z12-013 and use cases by XP Z12-014 (AIFE). The current external specifications are v3.2 of 2026-04-30 (impots.gouv.fr). The French business rules (BR-FR) come on top of EN 16931 (France_RFE, #178).

Delivery. Issuing goes through a Plateforme Agréée (PA); the list is linked from impots.gouv.fr. The public portal (PPF) is the directory and concentrator (AIFE). DGFiP has been the French Peppol Authority since 2025-07-08, and Peppol can carry B2B flows between platforms (peppol.org).

euinvoice today. UBL, CII and Factur-X output under EN 16931, and a Peppol profile that already accepts the two French process ids in BT-23. Not covered:

  • a French profile with the BR-FR rules (SIREN and endpoint identifiers, the restricted BT-3 list, the BT-23 frame codes, the payment-recovery note): planned, see #178;
  • the Factur-X Schematron, which the French rule set pin also delivers: #42;
  • French CII: which CII version (D16B or D22B) XP Z12-012 requires is not yet confirmed, see #179. Our CII writer is D16B;
  • e-reporting, lifecycle statuses and the platform API client. These are outside the library.

Unconfirmed: the Légifrance texts (CGI 289 bis and 290, décret 2026-677), the application dates of the four new invoice mentions, the penalty amounts, and per-platform adoption of the XP Z12-013 API.

Austria

Mandate and dates. Electronic invoices (IKTKonG §5 Abs. 1) to federal bodies, in the structured formats of the e-rechnung.gv.at guide, have been required since 2014-01-01 (IKTKonG §5, e-rechnung.gv.at guide). No B2B or B2C mandate and no date were found. Under §11 Abs. 2 UStG, an electronic invoice needs the recipient's consent. Invoices up to 400 EUR gross may be simplified (Kleinbetragsrechnung, §11 Abs. 6 UStG, same source).

Accepted formats. The federal portal accepts ebInterface 4.3, 5.0, 6.0, 6.1 and UBL 2.1. The Peppol route takes UBL only (e-rechnung.gv.at). Federal invoices must carry an order reference and a supplier number. In UBL these are BT-13 (/Invoice/OrderReference/ID) and BT-29 (/Invoice/AccountingSupplierParty/Party/PartyIdentification[1]/ID) (e-rechnung.gv.at).

Delivery. Portal form, upload, web service, or Peppol. E-mailed PDFs are not e-invoices for the federal government. Over Peppol all federal recipients share the id 9915:b, and the invoice is routed by the order reference, BT-13 (e-rechnung.gv.at).

euinvoice today. UBL 2.1 under the Peppol BIS Billing 3.0 profile covers the Peppol route. BT-13 and the other terms are plain EN 16931 fields. Not covered: ebInterface. It is not planned, because the federal portal accepts UBL 2.1; it would be revisited on demand (#182). Sending is outside the library (#114).

Unconfirmed: which BT carries the order position for the federal service, and whether the government plans a B2B mandate.

Simplified and small invoices

EN 16931 has no simplified profile. The German 250 EUR and Austrian 400 EUR thresholds, and any French rule for low-value consumer receipts, are the caller's concern. euinvoice always writes full EN 16931 invoices; whether a simplified document is allowed is outside the library.

Sources were last checked on the date at the top; open an issue if something has changed.