E-invoicing in logistics: freight invoices, self-billing and deadlines
E-invoicing in logistics means that freight invoices, self-billing invoices and outgoing invoices between domestic forwarders, carriers and shippers run as a structured file under the EN 16931 standard, received since 2025 and issued from 2027 or 2028.
The self-billing procedure is particularly affected, the method many forwarders use to settle with their subcontractors: a self-billing invoice is also an invoice and must be issued as an e-invoice between domestic businesses. AWP Consult implements the receiving side with enaio and prepares your own outbound issuing from TMS and ERP together with you.
- 1<InvoiceType>389 Self-billing
- 2<Seller>Carrier
- 3<Buyer>Forwarder
- 4<LineItem>per shipment
- 5<Attachment>Proof of delivery
- Format valid under EN 16931
- “Self-billing” indication included
- Reconciliation with order and proof of delivery
- Original XML in the forwarding file
Key points at a glance
- E-invoicing in logistics is an invoice or self-billing invoice for transport, forwarding or warehousing services between domestic businesses, issued, transmitted and received in a structured format under EN 16931 such as XRechnung or ZUGFeRD.
- Since 1 January 2025, all domestic businesses must be able to receive e-invoices. From 1 January 2027, companies with more than 800,000 euros in prior-year turnover must issue e-invoices, and from 1 January 2028 all of them.
- Self-billing invoices under the self-billing procedure pursuant to section 14 (2) of the German VAT Act (UStG) are also subject to the e-invoicing obligation. They must contain the “Self-billing” indication and are marked in the XRechnung with invoice type 389.
- There is no e-invoicing obligation where one party is not established in Germany, for example a foreign carrier without an involved permanent establishment, and for small-value invoices up to 250 euros under section 33 UStDV.
- All mandatory VAT details must appear in the structured part. Attachments such as proofs of delivery do not replace a mandatory detail.
- Invoices and self-billing invoices are accounting vouchers and must be retained for eight years under section 147 of the German Fiscal Code (AO), the e-invoice in the structured format in which it was received.
We will show you what that looks like with enaio in your company.
What does e-invoicing in logistics mean?
E-invoicing in logistics means that every settlement between domestic logistics companies, that is a freight invoice, self-billing invoice, warehousing or forwarding invoice, arrives and is sent as a machine-readable data record under EN 16931 rather than as paper or a simple PDF. Under section 14 (1) UStG, a PDF sent by email is not an e-invoice.
For forwarders this is more than a change of format, because an unusually large number of invoice types with their own rules meet here. How e-invoices are received, validated and archived in general is described on our page Receiving and processing e-invoices. This page is about what is different in forwarding and logistics.
A domestic carrier invoices its transport service. From its issuing obligation it arrives as an XRechnung or ZUGFeRD.
The forwarder settles the carrier's service itself. This self-billing invoice is also an invoice within the meaning of the UStG.
The forwarder invoices the shipper or warehousing customer, usually from the transport management system (TMS).
Fuel, parking and workshop receipts, often small amounts up to 250 euros, for which other invoices remain permitted.
In the e-invoicing check we record your document types, formats and settlement channels with carriers and shippers and show what needs to be done by your deadline.
Which deadlines apply to e-invoicing in logistics?
The same staggered deadlines apply to e-invoicing in logistics as to all domestic companies: you have had to receive since 1 January 2025, issue from 1 January 2027 if your prior-year turnover exceeded 800,000 euros, and from 1 January 2028 at the latest. What matters for forwarders is that incoming and outgoing must be switched over at different points in time.
All domestic businesses must be able to receive e-invoices. An email inbox is enough for this.
Companies with more than 800,000 euros in prior-year turnover must issue e-invoices and self-billing invoices as e-invoices. Until the end of 2026, paper and, with consent, PDF are permitted.
The issuing obligation applies to all domestic businesses. Smaller carriers up to 800,000 euros in prior-year turnover may still send other invoices until 31 December 2027.
In practice, your incoming invoices will see a mix of formats in 2026 and 2027: large carriers send e-invoices, small subcontractors still send PDF or paper. For your self-billing invoices to these subcontractors, however, your own turnover threshold applies, not theirs. If it is over 800,000 euros, self-billing invoices go out as e-invoices from 2027.
The BMF (Federal Ministry of Finance) refined its interpretation in letters dated 15 October 2024, 2025 and 2026. E-invoices issued by 31 December 2026 that comply with the two earlier letters will not be objected to even if they do not yet meet the additional requirements of the new letter.
Which logistics documents are subject to the e-invoicing obligation?
In logistics, the e-invoicing obligation covers all invoices and self-billing invoices for taxable services between two businesses established in Germany, above all freight invoices from domestic carriers, self-billing invoices to subcontractors and outgoing invoices to shippers. Exempt are small amounts up to 250 euros, travel tickets, invoices from small businesses and services involving foreign parties without a domestic permanent establishment.
| Document | Typical issuer | E-invoice mandatory? | What to watch for |
|---|---|---|---|
| Freight invoice | Domestic carrier | Yes, from its deadline | Until the end of 2027, PDF and paper still arrive from small carriers |
| Self-billing invoice under the self-billing procedure | Forwarder for the carrier | Yes, from your deadline | Prior agreement, “Self-billing” indication, invoice type 389 |
| Outgoing invoice to the shipper | Forwarder from TMS or ERP | Yes, from your deadline | Service description per shipment in the structured part |
| Monthly invoice for contract logistics | Logistics service provider | Yes | For a continuing service that remains the same, one e-invoice for the first period is enough |
| Invoice from a foreign carrier | Business without a registered office or involved permanent establishment in Germany | No | Paper or, with consent, electronic; an e-invoice is still possible |
| Fuel, parking and workshop receipts up to 250 euros | Petrol station, car park, workshop | No | Total amount over 250 euros, then the obligation applies |
| Travel tickets | Rail, ferry in passenger transport | No | Applies only to travel tickets that count as an invoice |
| Invoice from a small business | Small subcontractor | No | Small businesses must receive as well |
Not tax advice. The basis is section 14 UStG, sections 33 to 34a UStDV and the BMF letters on e-invoicing. Discuss special cases with your tax adviser.
Not sure where to start? We will assess your situation.
Arrange an initial consultation +49 6104 94738-13How does the self-billing procedure work with the e-invoice?
In the self-billing procedure with the e-invoice, the forwarder as the recipient of the service issues the settlement for the carrier itself, by prior agreement, as an XRechnung or ZUGFeRD with invoice type 389 and the “Self-billing” indication, transmits it electronically and archives it in its original format. If the carrier objects, it loses its effect as an invoice.
01
Record the self-billing agreement
Under section 14 (2) UStG, the recipient of the service may only settle if this was agreed in advance. The agreement belongs in the framework contract with the carrier or in a separate arrangement and is filed in the partner's file.
02
Settlement after delivery
The TMS generates the self-billing data as soon as the proof of delivery is available and surcharges, waiting times and deductions have been clarified. The basis is the order, the freight rate and the service actually performed.
03
Generate and validate the e-invoice
The self-billing invoice is created as an XRechnung or ZUGFeRD with invoice type 389. The carrier is the service provider, the forwarder is the issuer. The carrier's tax number or VAT ID comes from the checked partner master data, not from free-text entry.
04
Transmit and monitor objections
The self-billing invoice goes to the carrier by email or via a network such as Peppol. Queries and objections are recorded on the transaction so that a disputed self-billing invoice no longer serves as a document for the input VAT deduction.
05
Archive in the forwarding file
The XML file, the validation report and the proof of dispatch sit unalterably next to the order and proof of delivery. This way it is traceable at every audit which service was settled with which self-billing invoice.
Do you settle your subcontractors by self-billing? We check with you whether your TMS or ERP generates the self-billing invoice in the right format and how it reaches the file.
Have your self-billing procedure checkedWhat should forwarders note about e-invoicing in technical terms?
For e-invoicing, forwarders should note six points: the self-billing procedure, mandatory details on collective invoices, the establishment of foreign carriers, the three error types, existing EDI connections and retention of the structured original. These sections do not replace tax advice.
We go through self-billing invoices, collective invoices, foreign partners and EDI connections with you and define the validation rules for incoming documents.
Request a technical discussion +49 6104 94738-1301
Self-billing procedure between forwarder and carrier
Under section 14 (2) UStG, the recipient of the service may issue an invoice for the performing business, provided this was agreed in advance. This self-billing invoice must contain the “Self-billing” indication under section 14 (4) sentence 1 no. 10 UStG. If the recipient objects to the transmitted document, it loses its effect as an invoice.
The BMF makes clear that the e-invoicing obligation also applies to self-billing invoices. For an e-invoice, the self-billing invoice is identified via the invoice type. In the XRechnung this is code 389 for a settlement by the recipient of the service. An invoice correction, by contrast, carries code 384 with reference to the original invoice, and a credit note in the commercial sense, such as a refund, carries code 381.
- The seller in the data record is the carrier as the performing business, even though the forwarder generates the file
- The buyer in the data record is the forwarder as the recipient of the service
- The partner master data provides the address, tax number or VAT ID and the email address for receipt
Check whether your self-billing agreements are in writing and can be found. Often the procedure is established practice but the agreement is hard to locate.
02
Freight invoices with proofs of delivery and route lists
Under the BMF letter of 15 October 2025, all mandatory VAT details must appear in the structured part, including a clear and verifiable service description. A reference to an attachment or a link to a portal is not sufficient.
Supplementary documents such as proofs of delivery, route lists or timesheets may be attached to the e-invoice. They do not count towards the correctness of the invoice.
- One invoice line per shipment or tour with a shipment or order number so that reconciliation with the TMS runs automatically
- Surcharges such as toll, diesel or waiting-time surcharges as separate lines rather than as a lump sum in free text
- Service period or service date in the data record, and for collective invoices the settlement period
Agree with your most important carriers which reference appears in the data record.
03
Cross-border transport and foreign carriers
The e-invoicing obligation applies only if the performing business and the recipient of the service are established in Germany. Established means having a registered office, place of management or a permanent establishment involved in the transaction here. If at least one party is not established in Germany, there is no obligation. The invoice can then be transmitted on paper or, with consent, electronically.
For international routes this means: for each partner it must be clarified where they are established and whether a German branch is involved in the service. This determines whether incoming documents are expected to be e-invoices and in which format self-billing invoices go out.
Maintain the “established in Germany” attribute for each partner and company.
04
Format, business rule and content errors
The BMF distinguishes three error types with different consequences. Validation reports should be stored with the invoice.
A recipient exercising the care of a prudent business person may generally rely on a technical validation result. It does not, however, relieve them of checking whether the invoiced freight was actually transported. How AI and validation rules work together here is described on the page on automated invoice processing.
- Format errorThe file does not conform to the standard. It counts as another invoice, and from the issuer's deadline a correct e-invoice must be requested.
- Business rule errorThe file is technically readable but violates rules, for example missing mandatory fields or incorrectly calculated totals. Where this concerns mandatory details, the invoice must be corrected.
- Content errorThe tax rate, service or VAT ID is incorrect. Validation often does not detect this, so the factual check against order and proof of delivery remains mandatory.
05
EDI, Peppol and existing connections
Many forwarders have exchanged EDI data with shippers for years. Alongside formats under EN 16931, section 14 (1) UStG also permits formats agreed between issuer and recipient, provided the VAT details can be extracted completely and correctly. Whether an existing EDI connection meets this requirement should be clarified with your tax adviser and the partner.
E-invoices under EN 16931 are the XRechnung in the UBL and CII syntaxes as well as ZUGFeRD from version 2.0.1 in the BASIC, EN 16931, EXTENDED and XRECHNUNG profiles. MINIMUM and BASIC WL are not sufficient. Peppol is a network for transmission via certified access points. It is not mandatory for B2B.
Record the format, profile and transmission channel for each partner.
06
Retention in the forwarding file
Invoices and self-billing invoices are accounting vouchers and must be retained for eight years under section 147 (3) AO, beginning at the end of the calendar year in which they were created. For the e-invoice, the structured part must be retained unchanged in its original form and must remain machine-readable. For hybrid formats such as ZUGFeRD, the structured part takes precedence.
In logistics, proof of the service also counts. That is why we file the e-invoice, validation report and approval record in the digital forwarding file next to the order, consignment note and proof of delivery. The requirements the archive itself must meet are described on the page on the GoBD-compliant DMS.
Together with dispatch, settlement and accounting, we define when a freight invoice runs through automatically and when it lands with a person.
- Reconciliation with order and proof of delivery
- Rules per partner and format
- With process documentation
How does enaio process freight invoices from subcontractors?
enaio processes freight invoices from subcontractors in a single workflow, whether they arrive as an XRechnung, ZUGFeRD, PDF or paper: the system recognises the format, validates e-invoices, reads PDF invoices with AI, reconciles the line items with the order and proof of delivery from the TMS and files everything in the shipment file. Approval follows the incoming invoice workflow that you use for all accounts payable invoices.
XRechnung and ZUGFeRD
Structured data is taken over directly and validated against syntax and business rules. Reviewers see a readable view; the XML file is archived as the original.
XRechnung and ZUGFeRDPDF and paper with AI
As long as small carriers still send PDF or paper, enaio classify reads the documents, and the AI module enaio kairos learns new layouts without templates. After that the same workflow runs as for the e-invoice.
enaio kairosReconciliation with the transport order
The shipment or order number links the invoice line to the order, freight rate and proof of delivery. If everything matches, the invoice moves on. Discrepancies go to dispatch.
DMS for logisticsFiling in the forwarding file
The freight invoice, self-billing invoice, validation report and approval sit in the order's file. Posting goes via the enaio interfaces to SAP, DATEV, Dynamics 365 or your accounting system.
DMS for forwardersSounds right for your company? Let us talk about it.
What must forwarders prepare before their own issuing obligation?
Before their own issuing obligation, forwarders must clarify whether TMS and ERP can generate outgoing invoices and self-billing invoices as an XRechnung or ZUGFeRD, whether the partners' master data is complete, how the service per shipment is described in the structured part and through which channel each recipient receives their e-invoices. They are generated in the settlement system; the DMS links and archives them.
AWP Consult switches the incoming side over first, then the outgoing side in good time before your deadline, and checks on real settlement runs whether every self-billing invoice is correctly identified.
Can the TMS or ERP output XRechnung or ZUGFeRD in the EN 16931 profile or higher, including for self-billing invoices with invoice type 389?
Are the tax number or VAT ID, establishment and receiving address maintained for each carrier and customer?
Is there a clear line per shipment with a reference in the data record, rather than a lump sum with an attachment?
Does the e-invoice go by email, via a portal or via Peppol, and is dispatch logged verifiably?
Have customers who still receive PDF until your deadline consented to electronic transmission?
Does every outgoing e-invoice sit as an original in the archive, linked to order and proof of delivery?
What forwarders say about their invoicing process with AWP Consult
Voices from forwarding and logistics that have digitised their incoming and outgoing invoicing with AWP Consult and enaio.
With AWP's incoming invoice workflow, we standardise document processing in a secure and efficient process. Documents are checked digitally and in a personalised way, and at the end there is automatic posting in the financial accounting.
We introduced the software to greatly simplify document searches and to optimise the incoming and outgoing invoice process. We achieved both with the help of AWP. The very pleasant cooperation was and is marked by a high level of professionalism.
Which mistakes happen most often with e-invoicing in logistics?
The most common mistakes with e-invoicing in logistics are a forgotten self-billing procedure, mandatory details only in the attachment, incomplete partner master data, archived PDF views instead of XML originals and validation without a factual check.
01
Self-billing procedure overlooked
- Consequence
- From the deadline, self-billing invoices continue to go out as PDF. They are then not proper e-invoices.
- Better
- Run self-billing invoices as a separate work stream in the project and test them with invoice type 389.
02
Mandatory details only in the attachment
- Consequence
- The service description is in the route list, with only a lump sum in the data record. The e-invoice is open to challenge.
- Better
- Line items per shipment or tour in the structured part, proofs of delivery additionally as an attachment.
03
Establishment not maintained
- Consequence
- Foreign carriers are asked for an e-invoice while domestic branches are overlooked.
- Better
- Maintain the “established in Germany” attribute for each partner and evaluate it on the incoming side.
04
Only the PDF view archived
- Consequence
- The structured part is missing from the archive; retention in the received format is not met.
- Better
- Archive the XML file unalterably, and file the validation report alongside it.
05
Validation confused with a check
- Consequence
- Technically valid freight invoices for tours that were not driven get paid.
- Better
- After validation, always reconcile with the order, freight rate and proof of delivery.
06
Incoming ends in the inbox
- Consequence
- E-invoices land unread as an XML attachment in shared inboxes, and cash-discount deadlines expire.
- Better
- Collect the inbox automatically, recognise the format and hand it straight into the workflow.
We will show you what that looks like with enaio in your company.
How is e-invoicing in logistics implemented with enaio?
E-invoicing in logistics is implemented with enaio in five steps: taking stock of all document types and partners, a concept for incoming documents, self-billing invoices and the archive, a pilot with the freight invoices of one branch, the rollout to all companies and preparation of the outgoing side up to your own deadline.
01
Taking stock
Document types, formats, partners with their establishment, self-billing agreements and settlement systems are recorded.
02
Concept
Inbound channels, validation, validation rules against the TMS, approval matrix, file structure and process documentation.
03
Pilot
One branch starts with real freight invoices and self-billing invoices. Validation rules are refined.
04
Rollout
Further sites and companies follow; dispatch and accounting are trained.
05
Prepare the outgoing side
Outgoing invoices and self-billing invoices from TMS and ERP are tested and connected to archiving.
More on this: enaio implementation and training and DMS for forwarders
Checklist: is your forwarding company ready for the e-invoice?
With these questions you can check how well the incoming side, self-billing procedure and outgoing side of your forwarding company are prepared for the e-invoice.
01
Incoming
- E-invoices are collected from the inbox and recognised automatically
- XRechnung and ZUGFeRD are validated, and the report is stored
- Freight invoices are reconciled with the order and proof of delivery
- PDF and paper from small carriers run in the same workflow
02
Self-billing procedure
- Self-billing agreements are in place for all carriers
- The settlement system generates self-billing invoices as an e-invoice with invoice type 389
- Objections from carriers are recorded on the transaction
- Self-billing invoices sit as an original in the forwarding file
03
Outgoing and master data
- Your 2027 or 2028 deadline is determined from your prior-year turnover
- Establishment, VAT ID and receiving address are maintained for each partner
- Outgoing invoices contain line items per shipment in the data record
- The process documentation describes incoming, outgoing and archive
Frequently asked questions about e-invoicing in logistics
From when does e-invoicing apply in logistics?
All domestic logistics companies have had to receive e-invoices since 1 January 2025. Companies with more than 800,000 euros in prior-year turnover must issue from 1 January 2027, everyone else from 1 January 2028. Until the end of 2026, paper and, with consent, PDF are still permitted for everyone. For smaller companies this applies until the end of 2027.
Does the e-invoicing obligation also apply to self-billing invoices?
Yes. Self-billing invoices under the self-billing procedure pursuant to section 14 (2) UStG are invoices and are subject to the e-invoicing obligation if both parties are established in Germany. They must contain the “Self-billing” indication and are marked in the XRechnung with invoice type 389. What matters is the deadline of the issuing forwarder.
What does e-invoicing in logistics change for subcontractors?
Subcontractors have had to be able to receive e-invoices since 2025, including self-billing invoices from their clients as an XRechnung or ZUGFeRD. They must issue their own freight invoices as e-invoices from 2027 or 2028, depending on their prior-year turnover. Small businesses are exempt from the issuing obligation.
Can PDF invoices from subcontractors be processed automatically?
Yes. enaio classify reads PDF and paper invoices, and the AI module enaio kairos recognises new layouts without supplier-specific templates. After that the same reconciliation follows as for e-invoices.
Does a foreign carrier have to send an e-invoice?
No, if it has neither a registered office nor place of management nor a permanent establishment involved in the service in Germany. The e-invoicing obligation applies only between businesses established in Germany. If a German branch is involved in the service, however, the obligation applies.
What is the difference between XRechnung and ZUGFeRD?
Both implement the EN 16931 standard. The XRechnung is a pure XML data record in the UBL or CII syntax. ZUGFeRD is a PDF/A-3 file with embedded XML and counts as an e-invoice from the BASIC, EN 16931, EXTENDED and XRECHNUNG profiles.
May proofs of delivery be sent as an attachment to the e-invoice?
Yes. Proofs of delivery, route lists or timesheets may be attached. However, the mandatory VAT details including the service description must appear in the structured part. A reference to the attachment or a link to a portal is not enough.
Are fuel receipts and parking tickets subject to the e-invoicing obligation?
Small-value invoices up to a total of 250 euros may still be issued as another invoice under section 33 UStDV, that is on paper or as a PDF. If the total exceeds 250 euros, the e-invoicing obligation applies. A separate exception applies to travel tickets under section 34 UStDV.
How long must e-invoices be retained in a forwarding company?
Invoices and self-billing invoices are accounting vouchers and must be retained for eight years under section 147 AO, from the end of the calendar year in which they were created. What is retained is the structured part in its original form. A PDF view generated from it is not enough on its own.
What happens if an e-invoice is faulty?
A format error makes the file another invoice, and from the issuer's deadline a correct e-invoice must be requested. If mandatory details are missing or contents are incorrect, the invoice must be corrected before the input VAT deduction is secure.
Is an email inbox enough to receive e-invoices?
Legally yes, a dedicated inbox just for e-invoices is not required. It is sensible to have an inbox that is collected automatically and hands every e-invoice, validated, into the workflow.
Not sure where to start? We will assess your situation.
Arrange an initial consultation +49 6104 94738-13Which terms about e-invoicing in logistics should you know?
The key terms that come up between dispatch, settlement, accounting and IT during the switch-over.
01
E-invoice
An invoice in a structured electronic format that enables electronic processing, generally under EN 16931. A simple PDF is not an e-invoice.
02
Self-billing procedure
Settlement by the recipient of the service instead of by the service provider, by prior agreement under section 14 (2) UStG. In logistics, common when settling with carriers.
03
Invoice type 389
Code for a self-billing invoice within the meaning of the UStG in the XRechnung. Invoice corrections carry code 384, commercial credit notes code 381.
04
Carrier
A business that undertakes, under section 407 of the German Commercial Code (HGB), to carry the goods to the destination and deliver them there to the consignee.
05
Freight invoice
An invoice from a carrier or forwarder for transport services, often as a collective invoice covering many shipments.
06
XRechnung
The German standard for e-invoices under EN 16931, as pure XML in the UBL or CII syntaxes.
07
ZUGFeRD
A hybrid format of PDF/A-3 with embedded XML. The MINIMUM and BASIC WL profiles do not count as an e-invoice.
08
Establishment
A registered office, place of management or permanent establishment involved in the transaction in Germany. It determines whether the e-invoicing obligation applies.
Begin with the freight invoices and self-billing invoices of one site and check rules and formats on real documents before further sites follow.
Related topics
Sources and legal bases
The legal and technical statements on this page are based on the following official and established sources. Status of review: October 2026.
- § 14 UStG: Issuing of invoices Definition of the e-invoice, obligation between domestic businesses, self-billing invoice
- § 33 UStDV: Invoices for small amounts Small amounts up to 250 euros as another invoice
- § 147 AO: Rules on retention Eight years for accounting vouchers
- IHK Frankfurt am Main: E-invoicing obligation from 2025 Transition rules 2026 to 2028, 800,000-euro threshold, exceptions
- IHK Köln: BMF letter on e-invoicing dated 15 October 2025 Error types, self-billing invoices, retention of the structured part
- PwC: BMF letter dated 15 October 2026 Supplementary rules and non-objection until the end of 2026
- KoSIT (xeinkauf.de): XRechnung and Peppol XRechnung in UBL and CII, self-billing invoice with invoice type 389
- E-Rechnung des Bundes: self-billing invoices and corrections Invoice types 389, 381 and 384 in the XRechnung
Your forwarding company, ready for the e-invoice
In the e-invoicing check we record the document types, partners, self-billing procedure and settlement systems of your forwarding company. You receive a recommendation for incoming documents, validation rules, the archive and preparation of your own deadline.
- In person in Dietzenbach or online
- With settlement, dispatch and accounting
- Result: a clear roadmap up to the deadline