On June 23 and 24, I had the opportunity to attend the E-Invoicing Summit 2026 in Berlin. Two days filled with presentations, discussions, and insights into the latest developments surrounding electronic invoicing in Germany and Europe. My personal takeaway: The starting light for Germany’s major e-invoicing initiative has long since turned green. While some companies are already well on their way, others are still standing on the sidelines debating the ideal approach.
The rules are in place – now it’s time to hit the road
Over the past months and years, the Federal Ministry of Finance (BMF) has answered many open questions about e-invoicing and provided numerous clarifications. At the summit, it once again became clear what role the government plays in this process: It defines the racetrack, sets the rules, and marks the guardrails. What the BMF does not do, however, is get behind the wheel of the race car itself.
The actual implementation is up to the companies. Each company must find its own optimal path, establish the appropriate processes, and create the technical prerequisites. The regulatory framework is being further refined, but no one can or will relieve companies of their responsibility for implementation.
This is precisely where an interesting area of tension is currently emerging. While some companies are already actively sending and receiving electronic invoices, others are still engaged in fundamental discussions: What exceptions exist? Which transmission channel will prevail? What industry-specific requirements must be taken into account? Which transitional provisions still apply? Which tool should I use?
These are all valid questions. At the same time, it became clear on multiple occasions at the summit: The real challenge no longer lies in the discussion, but in implementation.
The era of email will come to an end
Even though email is currently still by far the dominant transmission method, it is becoming increasingly clear that the email channel will no longer play a central role for structured electronic invoicing in the long term. E-invoicing will only realize its full potential when structured data is exchanged automatically and without media discontinuity between companies.
This is precisely where a key difference lies between a PDF invoice sent via email and a “true” e-invoice. Email remains a communication medium. For an end-to-end invoicing process, however, it represents a media discontinuity. Secure networks with no risk of phishing are the future.
Companies therefore face the challenge of consistently evolving their processes toward structured, digital exchange methods while simultaneously preparing their ERP systems for this shift. Regulatory requirements set the direction, but each company determines the pace of implementation itself.
The Real Opportunity Lies in the Process
Of course, formats such as XRechnung or ZUGFeRD are frequently discussed in Germany. But the crucial question should not be: Which format is used? Rather, the discussion should focus on whether companies are using the introduction of e-invoicing to fundamentally improve their processes, or simply to fulfill a tedious obligation as quickly as possible. Unfortunately, the latter is the norm, which means that many opportunities fall by the wayside.
Those who merely digitize existing workflows are only partially tapping into the potential. The real opportunity lies in rethinking processes, eliminating media breaks, and automatically processing data – thereby improving data quality.
Thanks to structured invoice data, information will be significantly more consistent, complete, and machine-readable in the future. Sources of error that currently arise from manual entries, PDFs, or email-based processes will be significantly reduced. The more closely companies are connected to digital networks, the greater this effect will be.
Looking to the Future: What Happens After 2030?
In light of European developments surrounding VAT in the Digital Age (ViDA), the question already arises today as to how a national reporting system will impact existing processes. You can read more about ViDA here in another blog post. Should a corresponding reporting system become mandatory starting in 2030, this could require further adjustments.
Among other things, the discussion centered on whether existing models – such as the so-called 5-Corner Model – might gain importance in the future. Many details remain unclear, but one thing is already evident today: E-invoicing is not a completed project, but rather part of a long-term evolution toward fully digital business processes. By the time the reporting system is implemented, at the latest, email will no longer have a future.
EN 16931-1:2026 – Progress and Remaining Gaps
The new version of the European standard EN 16931-1:2026 has received a great deal of attention. Parts of the new European standard have already been published and incorporated into the new e-invoicing standards. The final announcement of all specifications has not yet taken place and is expected this year. What everyone can look forward to is a significantly expanded semantic model with 52 new business terms (an increase from 164 to 216) and 7 new business groups (from 32 to 39). This will enable significantly greater depth of detail and flexibility.
The revision brings numerous improvements and makes e-invoicing ViDA-ready. Nevertheless, a few remaining gaps were also discussed at the summit. For example, there are still more dedicated Invoice Type Codes needed for specific processes in the construction sector. Furthermore, certain information – such as commercial register entries – has not yet been provided for in a structured manner within the invoice data.
At the same time, the necessary standardization enables proper preparation for upcoming innovations within the framework of EU digitization. One example of this is the Digital Product Passport as a new building block. In the future, in addition to e-invoices, significantly more product-related information could be provided in a structured format – for example, for motor vehicles, details on mileage and initial registration for the purpose of proving new-car status for value-added tax purposes in accordance with Section 1b of the German Value-Added Tax Act (UStG).
The old version of EN 16931 from 2017 will remain valid in parallel until 2029. This allows different versions of the standard to be used side by side over several years.
XRechnung 4.0: The Next Step in Development
XRechnung was originally developed as a B2G standard and has now had to be further developed in line with new legal requirements to enable broader use in the B2B environment. The upcoming version, XRechnung 4.0, will fully implement the new requirements of EN 16931. In addition, various technical enhancements are planned. There will also be adjustments to fields BT-10 (Route ID) and BT-3 (Invoice Type Code), as well as the inclusion of the mandatory specification of a delivery or service date.
The goal is to release XRechnung 4.0 for use as soon as possible – that is, in the summer of 2026. XRechnung 3.0 will remain in effect even after that and, as stipulated by the provisions of the old EN 16931, may be used in parallel until March 2029.
If you need more information about the latest innovations related to XRechnung 4.0, please read Fatih Sariarslan’s blog post on this topic here.
New ZUGFeRD Version 2.5 – and a Look Ahead to Version 3.0
There was also news regarding the German-French hybrid format ZUGFeRD / Factur-X. ZUGFeRD version 2.5 was released on June 10, 2026, and now complies with the new EN 16931 standard. New elements can be found in the EXTENDED profile, such as new grounds for tax exemption for surcharges and discounts at the document level, the inclusion of the BIC and account name for SEPA direct debits, and further updates to Business Rules (BR).
Nevertheless, this version still requires optimization, a fact of which the developers are aware. In certain scenarios—such as when processing gross invoices – net amounts must be calculated from gross prices. This can lead to significant rounding differences, particularly with quantity and price structures such as those found in oil invoices. According to those responsible, this issue is expected to be resolved by fall 2026.
Attention is already turning to the next stage of development. ZUGFeRD 3.0, the next major version, is expected next year and will incorporate all adjustments from the final published EN 16931 standard.
My personal takeaway: Too much discussion in the pit lane
While the regulatory framework is being further refined, the fundamental direction is clear. Companies should not primarily use the remaining time to discuss further exceptions, but rather consistently prepare their race cars for the digital future in order to remain competitive and capable of taking action.
Beyond the technical content, one observation in particular stood out to me from the 2026 E-Invoicing Summit: We’re still spending a great deal of time talking about the rules and highlighting their weaknesses, rather than taking action and recognizing the opportunities.
Of course, standards, norms, and legal requirements form the foundation for successful implementation. It’s obvious that the regulatory framework still has gaps. At the same time, however, one gets the impression that many stakeholders are still waiting for the final clarification, the last specification, or the final exception, rather than being part of the race.
Complete clarity is unlikely to be achieved for a long time to come. Yet, in my view, this is precisely where the fallacy lies. Anyone waiting for every question to be definitively answered will likely get a late start. The digitization of invoicing processes has never been a project that could wait for 100% regulatory perfection; rather, it has had to adapt to regulatory pressure from tax authorities. Companies should therefore be aware that there will not be 100% readiness by January 1, 2027 – and that is precisely why they must not hesitate, but take action.
My advice to you: Start driving!
Many companies are still in the pit lane, analyzing every turn on the track. Meanwhile, others have long since started their engines and are already gaining experience on the track. The track is laid out, the rules are known, the starting light has long since turned green, and some competitors are already on the track. What matters now is no longer debating the ideal line, but how quickly you’ll get out on the track yourself. Ultimately, top times are only achieved with warm tires – keep your tires warm and start driving!
If you, too, decide to pull out of the pit lane and finally put some horsepower on the road, you don’t have to do it alone. Together, we’ll identify the right ideal line for your company and ensure that you land in pole position. Feel free to reach out to me and benefit from our years of expertise in e-invoicing. Together, we can plan the perfect e-invoicing racing strategy and put it into action.
