A structured invoice is a file whose invoice data — parties, lines, amounts, VAT — is stored as machine-readable fields, typically XML, so that the receiver's software can book it without anyone reading it. A PDF, however neatly laid out, is a picture of an invoice: it carries no fields, only text and graphics. European law defines an e-invoice by the structured data, which is why a plain PDF is not an e-invoice in Germany, France, Belgium or Poland, while a hybrid PDF with an embedded XML is.
What makes an invoice "structured"
An invoice is structured when every business term has a defined place in the file that software can address directly — a seller VAT identifier, a line quantity, a VAT rate — rather than being inferred from position on a page.
Directive 2014/55/EU puts it as an invoice "issued, transmitted and received in a structured electronic format which allows for its automatic and electronic processing". Three words carry weight. Issued: the file leaves the seller's system as data. Transmitted: the data itself travels, not a rendering of it. Received: the buyer takes in the data, not a printout. The standard behind the definition is EN 16931, which fixes the elements and their meaning; the file formats that carry them are UBL and CII XML.
What is not structured: paper; a scanned image; a PDF produced from a word processor or an invoicing tool's print function; a PDF with "text layer" that OCR can read; a PDF whose fields were extracted by an AI service on the receiving side. In every one of these the data has to be reconstructed, and the reconstruction can be wrong. The legal test is not whether a machine could read it but whether the file is structured data.
Hybrid formats: a PDF that is also an e-invoice
A hybrid invoice is a PDF/A-3 file with an XML invoice embedded as an attachment. It is an e-invoice because the XML is present and complete; the PDF page is a convenience for people. ZUGFeRD (Germany) and Factur-X (France) are the same technical specification under two names.
The XML inside a hybrid is a UN/CEFACT CII document. FNFE-MPE describes Factur-X as "a Franco-German hybrid electronic invoice standard (PDF for users and XML data for automated processing)"; the current release is Factur-X 1.09.2 / ZUGFeRD 2.5.2, published on 4 August 2026. Two points matter for compliance:
- The XML is the invoice. The German administration's guidance states that in a hybrid format the structured part takes precedence over the image. If the PDF page and the XML disagree, the XML counts.
- The profile decides conformance. ZUGFeRD and Factur-X come in profiles from MINIMUM to EXTENDED. Only profiles that carry the EN 16931 core — BASIC as a subset, EN 16931, EXTENDED — produce a conformant EN 16931 invoice; MINIMUM and BASIC WL do not carry the required line data.
The practical advantage of a hybrid is that a buyer who has no software can still open and read it, while a buyer who has software books it automatically. The disadvantage is size and the temptation to treat the PDF as the document and discard the XML. Details on ZUGFeRD and Factur-X.
What counts as an e-invoice in each country
All four countries agree that a plain PDF is not an e-invoice; they differ on which structured formats qualify and whether hybrids are accepted.
| Country | E-invoice means | Hybrid PDF accepted? | Plain PDF status |
|---|---|---|---|
| Germany | A structured electronic format that complies with EN 16931 or an interoperable format agreed between the parties (§ 14 UStG). XRechnung, ZUGFeRD, Factur-X and Peppol BIS are named by the BMF. | Yes — ZUGFeRD/Factur-X in a conformant profile; the XML part is leading. | "Other invoice" (sonstige Rechnung). Allowed only under the transitional rules and, in some cases, with the recipient's consent. |
| France | An invoice in one of the three formats of the "socle minimal": Factur-X, UBL or CII, exchanged through an approved platform (plateforme agréée). | Yes — Factur-X is one of the three mandatory-reception formats. | Not an e-invoice. Cannot be used to meet the issuing obligation once it applies to the company. |
| Belgium | A structured electronic invoice exchanged between the parties' systems; Peppol BIS Billing 3.0 over the Peppol network by default. | Only by mutual agreement — Peppol BIS is UBL, not a hybrid. | Not an e-invoice for domestic B2B since 1 January 2026. |
| Poland | A structured invoice (faktura ustrukturyzowana) in the FA(3) schema issued through KSeF, which assigns the KSeF number. | No — KSeF accepts only the FA(3) XML; a PDF is at most a visualisation. | Not an e-invoice. Outside the mandate only for the excluded cases (consumer sales, certain foreign entities, special procedures). |
Two things the table cannot capture. First, exclusions: Germany's guidance keeps small-amount invoices (up to €250) and certain tickets outside the e-invoice duty; Poland excludes sales to consumers and some foreign businesses; France's reform covers domestic B2B while B2C and cross-border transactions fall under e-reporting. Second, consent: in Germany a non-e-invoice during the transition needs the recipient's agreement, whereas ViDA lets Member States drop recipient consent for mandated e-invoices. Which case applies to a given company requires professional confirmation. The country hubs go deeper: Germany, France, Belgium, Poland.
When PDF-only stops being compliant
PDF-only invoicing stops being compliant on the day a company's issuing obligation starts. Receiving obligations come first and are broader; issuing obligations are phased by size.
| Country | Must be able to receive structured invoices | Must stop issuing PDF-only (domestic B2B) |
|---|---|---|
| Germany | 1 January 2025 (every domestic business) | Transitional rules end 31 December 2026; businesses with prior-year turnover up to €800,000 may continue until 31 December 2027; EDI arrangements likewise until 31 December 2027 |
| France | 1 September 2026 (all VAT-registered businesses) | 1 September 2026 for large and mid-sized companies; 1 September 2027 for SMEs and micro-enterprises |
| Belgium | 1 January 2026 | 1 January 2026 |
| Poland | 1 February 2026 (KSeF 2.0) | 1 February 2026 (2024 sales above PLN 200 million); 1 April 2026 (all others); 1 January 2027 (monthly sales up to PLN 10,000) |
Two consequences follow. A German supplier who sends a PDF to a Belgian business customer after 1 January 2026 is not in breach of German law, but the Belgian customer cannot accept it as the invoice the Belgian mandate requires — cross-border cases are on the cross-border page. And a receiving obligation is not satisfied by "we can open XML in a browser": the guidance in Germany, France and Belgium expects the structured file to be processed and archived as the invoice. The full date list is on the timeline.
What a receiver should do with each kind of file
Book the structured file, keep the structured file, and treat the PDF page as an aid.
- Detect the type. An XML attachment (or a PDF with an embedded XML) is an e-invoice; a PDF without one is not. Check the customization ID inside the XML to know the specification.
- Validate before booking. Run the file through the schema and business rules of its specification. A file that fails is not a valid invoice, whatever the PDF page shows.
- Book from the data. Take amounts, VAT breakdown and payment details from the XML, not from OCR of the page.
- Archive the XML. The structured file is the original. Keep it unchanged for the national retention period; keep the PDF rendering alongside it if you like.
- Handle the non-structured remainder. During the transitional periods you will still receive PDFs and paper; book them as before, but do not archive a PDF rendering in place of an XML you received.
The Germany hub has a dedicated page on receiving e-invoices.
How KRONENWERK handles this
KRONENWERK issues structured invoices for its European countries and reads structured invoices it receives; a plain PDF is produced only where no structured mandate exists.
- Germany — XRechnung (XML) and ZUGFeRD (hybrid PDF/A-3 with embedded CII), validated with the KoSIT Schematron rules and cross-checked with the Mustang library: SUPPORTED.
- France — Factur-X hybrid generation SUPPORTED; transmission through an approved platform NOT YET READY.
- Belgium — Peppol BIS Billing 3.0 UBL SUPPORTED WITH LIMITATIONS: sent and received over Peppol through an accredited access point provider (Storecove) once the company is connected in Settings → Delivery.
- Poland — FA(3) XML generation SUPPORTED WITH LIMITATIONS; KSeF transmission NOT YET READY.
- Canada and the United States — PDF invoices with national tax rules; no structured mandate exists there.
- Receiving — incoming XRechnung, ZUGFeRD/Factur-X and UBL files are read into bills; the free checker validates any file against a country's rules without storing it: SUPPORTED.
Plain PDFs and paper you receive are recorded as bills and expenses in the ledger in the usual way; only structured files are read automatically. Product details on the e-invoicing page; formats compared in the format guide. Back to the Europe hub.
Frequently asked questions
Is a PDF sent by e-mail an electronic invoice?
Not in the legal sense used in Germany, France, Belgium or Poland. It is electronic in transport but not structured. It counts as an "other invoice" in Germany and does not satisfy any of the four mandates.
Is a PDF with an embedded XML an e-invoice?
Yes, if the XML is a conformant invoice — ZUGFeRD or Factur-X in the BASIC, EN 16931 or EXTENDED profile. The XML is the invoice; the page is a rendering.
Can I keep sending PDFs to customers who prefer them?
In Germany only until the transitional period that applies to you ends, and only with the recipient's consent. A hybrid ZUGFeRD or Factur-X file gives such customers a readable PDF while remaining an e-invoice.
If I receive an XRechnung, can I archive the PDF I generated from it?
Keep the XML. It is the original invoice; a rendering you produced is not. Retention rules are national and require professional confirmation for your case.
Does OCR make a PDF compliant?
No. OCR reconstructs data on the receiving side; the law asks for an invoice issued, transmitted and received as structured data.
Sources
- Directive 2014/55/EU on electronic invoicing in public procurement — read on
- BMF — Einführung der obligatorischen elektronischen Rechnung (UStAE amendment, 15 October 2025) — read on
- European Commission — 2025 Germany eInvoicing Country Sheet — read on
- economie.gouv.fr — Tout savoir sur la facturation électronique — read on
- impots.gouv.fr — Facturation électronique et plateformes agréées — read on
- European Commission — eInvoicing in Belgium — read on
- Ministry of Finance (Poland) — Zakres obowiązkowego KSeF — read on
- Ministry of Finance (Poland) — FA(3) information brochure — read on
- FNFE-MPE — Factur-X — read on