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E-invoicing (E-Rechnung) for subscription providers | Figures checked on 11.10.2026

How do you turn subscription invoices into an e-invoice (XRechnung or ZUGFeRD)?

You issue the invoice as a structured data record instead of a plain PDF file: as XRechnung (pure XML) or as ZUGFeRD (PDF with embedded XML). Since 01.01.2025, a simple PDF is only an “other invoice”. Between domestic businesses, according to the BMF FAQ (March 2026): receiving since 01.01.2025, issuing from 01.01.2027 for prior-year revenue above €800,000, from 01.01.2028 for everyone; B2C and invoices up to €250 gross are exempt.

Illustration of a scan frame around lines of text in wals.pro red as a symbol for structured invoice data

PDF or e-invoice: what is the difference?

Since 01.01.2025, the BMF (German Federal Ministry of Finance) distinguishes two types. An e-invoice is issued, transmitted and received in a structured electronic format. Everything else, including a simple PDF by email, is an “other invoice” (BMF FAQ, as of March 2026, question 2). A PDF is not an e-invoice within the meaning of § 14 UStG. Check the documentation of your billing or payment tool to see which format it produces.

weclapp creates outgoing invoices in the ZUGFeRD profile EN 16931 (Comfort); in the global settings you enable ZUGFeRD data for all PDF invoice documents. You generate XRechnung via an optional workflow action. If there are discrepancies with ZUGFeRD, the structured part prevails.

This does not replace tax advice.

Graphic on e-invoicing in Germany: receiving mandatory since January 1, 2025, issuing from January 1, 2027 for prior-year revenue above €800,000, from January 1, 2028 below that as well, small amounts up to €250 gross exempt; fictional sample calculation with 1,200 subscription invoices per month. Source: BMF FAQ

PDF, XRechnung and ZUGFeRD compared

MerkmalPDF-RechnungXRechnungZUGFeRD
DatenformatLesbare Darstellung, keine strukturierten DatenReines XML (EN 16931)PDF mit eingebettetem XML
Gilt seit 2025 als E-RechnungNein, „sonstige Rechnung“JaJa, ab Version 2.0.1 ohne Profile MINIMUM und BASIC-WL
FĂĽhrender TeilDas PDFDas XMLDas XML, nicht das PDF-Bild
MenschenlesbarJaNur mit ViewerJa, ĂĽber den PDF-Teil

Which deadlines apply to subscription providers in Germany?

The obligation applies to transactions between domestic businesses (BMF FAQ, as of March 2026, question 3). For subscription providers, that means:

  • Receiving: since 01.01.2025 for everyone, an email inbox is enough.
  • Issuing from 01.01.2027: for prior-year revenue above €800,000. Up to €800,000, the transition period runs until the end of 2027, after which the obligation applies to everyone.
  • Decisive is the total revenue of the prior year (§ 27 para. 38 UStG in conjunction with § 19 para. 2 UStG), so for the 2027 deadline that is the year 2026. How you calculate it is something your tax advisor will clarify.

For subscriptions, the small-amount rule matters most: invoices up to €250 gross do not need an e-invoice; this relief does not apply to services to companies in other EU countries where the recipient is liable for the tax, which you clarify with your tax advisor. Also exempt are B2C invoices, services by small businesses, services to legal entities that are not businesses, and many tax-exempt transactions.

This does not replace tax advice.

The deadlines for subscription invoices in four figures

01.01.2025
Receiving e-invoices is mandatory (BMF FAQ, question 12)
01.01.2027
Issuing obligation for prior-year revenue above €800,000 (BMF FAQ, question 11)
01.01.2028
Issuing obligation for all domestic businesses, including those below €800,000 prior-year revenue (BMF FAQ, question 11; exceptions question 4)
€250
Small-amount threshold gross per invoice, no e-invoice needed (BMF FAQ, question 4)

Source: BMF, questions and answers on e-invoicing, as of March 2026. This does not replace tax advice.

Which license do you need for subscription invoices?

E-invoicing and API. Writing and capturing e-invoices is included in all weclapp packages, the REST API from ERP Dienstleistung (ERP Services) upwards. According to the weclapp list price, as of October 2026, ERP Dienstleistung costs €86 (annual payment) or €95 (monthly payment) per user per month, net. weclapp has no document or transaction fees.

Individual invoices via API. With the REST API, you create invoices from your billing system in weclapp. Your customers should receive only one invoice per service: if weclapp issues it, you switch off invoice dispatch in the billing or payment tool. How format generation behaves in a large API run, we clarify with you in advance.

Recurring invoices from weclapp itself require the Contract Management add-on. If weclapp is to generate subscription invoices itself on a fixed schedule, this requires the add-on. List price weclapp, as of October 2026: €55 per person per month. For each contract, you choose whether weclapp creates a sales order or an invoice, and whether the invoice is created before or after the billing period (in the first case at the time of billing, in the second one day afterwards).

How do payouts and payments get into accounting?

weclapp reads transactions from payment service providers such as PayPal, finAPI and Tink, Stripe and Klarna only on request, and matches payments to open items. For collective payouts from a payment provider, there is no native weclapp standard. wals.pro uses Zahlungsabgleich 4 weclapp for this: it breaks down collective remittance advices, for example from Stripe, Mollie, PayPal or American Express, into individual payments and fees, matches them to the invoices and can be extended with further advice sources; a five-stage scoring match rates every hit. Clear matches are booked, uncertain cases go to review.

Connection. We support the setup as a project. wals.pro AI 4 weclapp helps with the Setup Center for connection, skills and the first read access; the AI does not take over the accounting setup itself.

Three tasks around the subscription invoice

Icon: Document

Issue

ZUGFeRD via a global setting for all PDF invoices, XRechnung via workflow action; the REST API is available from ERP Dienstleistung (ERP Services), and we clarify format generation for invoices via API in advance.

Icon: Import

Receive and archive

Upload e-invoices, capture PDF and paper via OCR. You must retain them for eight years, and the structured part must remain unchanged.

Icon: Matching

Match payments

Zahlungsabgleich 4 weclapp breaks down collective remittance advices, for example from Stripe, Mollie, PayPal or American Express, into individual payments and fees and matches them to open items; further advice sources can be added.

Example calculation: SaaS with 1,200 subscription invoices per month

A fictional example. A SaaS company based in Germany issues 1,200 subscription invoices per month: 840 to private customers, 300 to business customers in Germany as a monthly subscription at €29 net, 60 to business customers in Germany as an annual subscription at €480 net.

  • Private customers: 840 invoices. B2C is exempt from the obligation.
  • Monthly subscriptions to businesses: 300 invoices at €34.51 gross. These are small amounts up to €250 gross, so the obligation does not apply.
  • Annual subscriptions to businesses: 60 invoices per month at €571.20 gross. Only these are above €250 gross and fall under the obligation once it applies.
  • Deadline: For 2027, the 2026 revenue counts. Simplified assumption (invoiced net amounts): (840 Ă— €29 + 300 Ă— €29 + 60 Ă— €480) Ă— 12 = €742,320. That is below €800,000; whether your total revenue is actually below it is something your tax advisor will clarify. Plug in your own values.
  • Ongoing costs: ERP Dienstleistung (ERP Services) plus add-on. Example with one user and an annually booked license: €86 + €55 = €141 net per month, list price weclapp, as of October 2026.

This does not replace tax advice.

The example in four figures

840
Invoices to private customers per month, B2C is exempt
300
Monthly subscriptions to businesses at €34.51 gross, small amount, no e-invoice needed
60
Annual subscriptions to businesses at €571.20 gross, e-invoice needed
€742,320
assumed invoiced net amounts 2026, below €800,000

Fictional example with a simplified assumption. This does not replace tax advice.

What a subscription invoice must contain

A subscription invoice above €250 gross needs the mandatory information under § 14 para. 4 UStG. This includes, among other things, full names and addresses, tax number or VAT ID, a consecutive invoice number, type and scope of the service, time of the service, the consideration broken down by tax rates including agreed reductions, as well as tax rate and tax amount. For an e-invoice, all mandatory information must be in the structured part; a reference to a PDF in the attachment is not enough (BMF FAQ, as of March 2026, question 7a).

For invoices up to €250 total, simplified information is sufficient (§ 33 UStDV): name and address of the supplier, issue date, type and scope of the service, and consideration and tax amount in one sum with the tax rate or an exemption notice. This applies to the monthly subscriptions in the example.

For subscriptions, the service period is the crux. The law requires the time of the service (§ 14 para. 4 no. 6 UStG). For a monthly subscription, you state the calendar month; according to the BMF, this is also sufficient in an e-invoice (question 7b, there for the collective invoice). For advance payments, the invoice states the time the consideration was received, provided it is fixed and differs from the issue date (§ 14 para. 4 no. 6 in conjunction with para. 5 UStG). For quarterly and annual subscriptions, you clarify the period and when the VAT arises with your tax advisor.

This does not replace tax advice.

Correction, refund and retention

Correction: Anyone who corrects an invoice must also do so as an e-invoice where the obligation applies, using the invoice type for a correction (BMF FAQ, as of March 2026, question 7b). During the transition periods, this is still possible without an e-invoice. You may correct individual items in a follow-up e-invoice if it clearly refers to the original.

Refund and credit note: In VAT law, a “Gutschrift” (self-billing credit note) is an invoice issued by the recipient of the service that carries this designation (§ 14 para. 4 no. 10 UStG). A refund or price reduction to your customers is something different. How you document it, you agree with your tax advisor; for details, the BMF FAQ refers to the BMF letters of 15.10.2024 and 15.10.2025.

Retention: eight years, at least the structured part intact in its original form (question 13).

This does not replace tax advice.

When is this not a fit?

Good fit

  • You bill B2B subscriptions to business customers in Germany.
  • Your invoices are often above €250 gross, for example annual subscriptions.
  • You want invoicing, open items, dunning run and DATEV export in one system.

Not a good fit

  • You are purely B2C: private customers are exempt from the obligation.
  • You issue only a few invoices: then a lean invoicing tool is often simpler.
  • You have no business in Germany: the German obligation applies only between domestic businesses.
  • You are looking for a tool that handles payment and invoice in one step: payment processing stays with your payment provider.
  • You bill based on usage or pro rata by the day: check in advance whether a contract's billing cycle can map that.

Frequently asked questions

Does the obligation apply to B2C subscriptions?

No. The BMF explicitly exempts invoices to end consumers (B2C). Small amounts up to €250 gross, services by small businesses and many tax-exempt transactions also do not need an e-invoice. If you have a mix of private and business customers, the obligation only affects the B2B part with domestic recipients. Also check with your tax advisor how to classify mixed cases.

Is a PDF from my billing or payment tool enough?

Only temporarily. Since 01.01.2025, a simple PDF is an other invoice. Until 31.12.2026, you may still issue it, by email with the recipient's consent. With prior-year revenue up to €800,000, this applies until the end of 2027. After that, you need XRechnung or ZUGFeRD. Check the current manufacturer documentation of your tool to see which format it produces.

Do I already have to be able to receive e-invoices?

Yes. Since 01.01.2025, all domestic businesses must be able to receive e-invoices, including small businesses. According to the BMF, an email inbox is enough for that. In weclapp, you upload incoming e-invoices in purchasing; PDF and paper invoices you capture via OCR. The functions are included in all packages. You must retain the structured part unchanged for eight years.

XRechnung or ZUGFeRD for my B2B subscriptions?

According to the BMF, both meet the requirements. ZUGFeRD additionally includes a readable PDF. Legally, you only need a Leitweg-ID (routing ID) for invoices to public authorities; for XRechnung in weclapp, according to the weclapp documentation, it is required on the customer record. In B2B, according to the BMF (question 6), a placeholder is sufficient for VAT purposes. For business customers, ZUGFeRD is usually the more convenient choice; you mainly need XRechnung for public authorities.

Does the German obligation also apply to customers abroad?

The German obligation applies under § 14 para. 2 UStG when the issuer and the recipient are both established in Germany. For invoices to companies in other countries, their rules and deadlines apply. For Austria, the current status is on the page E-invoicing in Austria. For every country you sell subscriptions to, check the local obligation and deadlines there, ideally together with your tax advisor.

Do I need the Contract Management add-on for subscriptions in weclapp?

If weclapp is to generate recurring invoices itself on a fixed schedule, yes. The add-on costs €55 per person per month (list price weclapp, as of October 2026). If your billing system generates the invoices and hands them to weclapp via REST API, you do not create contracts in weclapp for that. The REST API is available from ERP Dienstleistung (ERP Services).

How long do I have to retain e-invoices?

Eight years (§ 14b UStG). For an e-invoice, at least the structured part must be available intact in its original form. For VAT purposes, according to the BMF, archiving outside a GoBD-compliant system is generally not a breach of § 14b para. 1 UStG; for bookkeeping, the GoBD (principles of proper accounting) continue to apply. An archive PDF alone is not enough for an e-invoice. This does not replace tax advice.

Further reading

  • E-invoicing in Austria: whether there is a B2B obligation in Austria, what ebInterface is and what the EU requires from 2030.
  • DATEV handover from weclapp: Rechnungsdatenservice, Buchungsdatenservice or CSV: which route to the accounting firm suits you.

Set up your subscription invoices as e-invoices.

In a call, we clarify formats, add-on and payment routes for your billing system. Over 125 companies have registered for wals.pro AI 4 weclapp.