Starting January 1, 2025, a significant change will take effect: All companies in Germany must be able to receive electronic invoices (E-Invoices) – regardless of whether they're sole proprietorships, partnerships, GmbHs, or AGs. Even small entrepreneurs are not exempt.
The digital transformation in accounting doesn't spare any industry. Against this backdrop, hosts, who often rely on systems like WHMCS, must adapt their processes. However, there are industry-specific nuances that provide some exceptions for hosting providers.
Electronic Invoice: What's Coming?
From January 1, 2025, the obligation comes into force for all companies in business transactions to receive E-Invoices. This new system is intended to promote transparency, efficiency, and error reduction in accounting.
Regardless of the size of the company – even small entrepreneurs can no longer rely on paper. For hosts, this means: billing systems must be electronically compatible. A well-established example for the smooth reception and dispatch of E-Invoices is Lexware Office. More on this can be found at Try Lexware Office. (Advertisement)
Exceptions for Hosts – What Specifically Applies?
Hosting providers are generally subject to the E-Invoice obligation. However, the legislature has created transitional arrangements that give smaller providers and companies with lower annual turnover time to implement the changes.
Starting January 1, 2025, all companies in Germany are required to be able to receive and process E-Invoices – without the invoice recipient's prior consent. This applies regardless of industry or company size, thus also affecting hosting providers.
The obligation to issue E-Invoices also applies from January 1, 2025. However, special regulations apply for the transitional period between 2025 and 2027, especially with regard to format and type of transmission.
What Does This Mean Specifically for Hosts Regarding Invoice Dispatch?
From 01.01.2025:
- Mandatory receipt of E-Invoices (according to EN 16931) for all companies – including small entrepreneurs.
- Dispatch possible as:
- Paper invoice
- PDF or other formats – but only with the recipient's consent
From 2026:
- No changes in dispatch possibility compared to 2025
- Receiving obligation remains
From 2027:
- Only companies with a previous year's turnover of < 800,000 € may continue to send invoices as PDF/paper (with consent).
- All others must already issue structured E-Invoices.
From 2028:
- All companies must use E-Invoices in the EN 16931 format.
- PDF, paper, and other formats are no longer permissible – regardless of turnover.
These transitional arrangements mainly offer small hosts and freelancers the opportunity to gradually switch their systems to E-Invoices. However, all affected companies should start adapting early to be fully compliant by the deadline in 2028.
Important for Small Entrepreneurs:
Small entrepreneurs who are exempt from sales tax must receive E-Invoices but can continue to use PDFs for dispatch, as their invoices are formally considered "Other Invoices." These remain permissible until 2027, provided the recipient consents.
Exceptional Cases:
- Invoices under 250 € gross can be permanently issued in other forms (paper, PDF, etc.).
- The paper invoice is still formally permitted but plays virtually no role in the hosting industry.
Implementing the E-Invoice Obligation in WHMCS
WHMCS does not offer native support for implementing the E-Invoice obligation, so additional modules are necessary to meet legal requirements. Below are two implementation paths.
Lexware Office WHMCS Integration (Becker Software)
The module from Becker Software provides a seamless connection between WHMCS and Lexware Office. Invoices created in WHMCS are automatically transferred to Lexware Office, where they are generated as E-Invoices in ZUGFeRD or XRechnung format in compliance with legal requirements. These invoices are then dispatched directly from WHMCS using the original PDFs from Lexware Office. Since Lexware Office meets the legal E-Invoice requirements, all legal obligations are automatically covered.
E-Invoice WHMCS Module from Plambee
The E-Invoice module from Plambee for WHMCS enables the creation and dispatch of electronic invoices directly from WHMCS. The ZUGFeRD format is used, a hybrid data format combining a human-readable PDF file with machine-readable XML data. This facilitates electronic invoice data exchange and complies with legal E-Invoice requirements.
A special feature of the module is the caching function: invoices are stored on the webspace, allowing customers to download the original invoice at a later date, even if layout or product name changes have occurred in the meantime.
Rental Version (annually) - 79.95 € - Rental Version (monthly) - 8.99 € (Affiliate Links)
Have we missed something? Feel free to contact us via email: info [a-t] becker-software [dot] de.
Conclusion
Anyone issuing invoices through WHMCS or other systems must be fully transitioned to structured E-Invoices (according to EN 16931) by 2028 at the latest – regardless of turnover. The obligation to receive begins as early as 2025.
Disclaimer
The content of this post has been researched and compiled with the utmost care. Nevertheless, Becker Software assumes no guarantee for the accuracy, completeness, or timeliness of the provided information. This article does not constitute tax or legal advice and cannot replace individual consultation with a tax advisor, lawyer, or other qualified professional. Particularly regarding changing legal frameworks – such as E-Invoice requirements – we recommend seeking legal or tax advice in case of specific need for action. Becker Software does not accept liability for direct or indirect damages arising from the use of the content.
Transparency Notice / Affiliate Links
Some links in this post are so-called affiliate links. If you purchase a product or service through one of these links, we receive a small commission. The price for you does not change. The recommendation is made solely if we are convinced of the product's quality and benefits. Revenue from these links helps us operate this blog and regularly publish new content.