Your Supplier Still Sends PDFs: The Input VAT Risk After the Transition Periods
Under German law a plain PDF invoice is not an e-invoice. During the transition you can still deduct input VAT from it. Once your supplier crosses into the mandate, that protection ends. Here is the buyer's checklist.
Your Supplier Still Sends PDFs: The Input VAT Risk After the Transition Periods
German law draws a hard line between an e-invoice and everything else. An e-invoice is a structured, EN 16931-compliant data record. Everything else, including the PDF attachment your supplier has sent for a decade, is a "sonstige Rechnung": an invoice in another format. The legal consequence sits with the buyer: input VAT deduction (Vorsteuerabzug) depends on receiving a proper invoice.
Why the Buyer Carries the Risk
Section 15 UStG conditions input VAT deduction on holding an invoice that meets the requirements of Section 14 UStG. When a mandated issuer sends a plain PDF instead of a structured e-invoice, the document fails Section 14 (1) sentence 6. The issuer has committed the compliance failure, but the deduction problem lands in your VAT return.
During the transition periods, the law tolerates other-format invoices with the recipient's consent:
| Period | Tolerance |
|---|---|
| Until 31 December 2026 | Paper and PDF acceptable from all issuers, with recipient consent |
| Until 31 December 2027 | Paper and PDF acceptable from issuers below the 800,000 EUR threshold, with recipient consent |
| From 1 January 2028 | No tolerance for in-scope domestic B2B invoices |
The tolerance has a quiet condition: your consent. Consent given by silence is still consent, but it is also your only legal bridge. Once the relevant transition period ends for your supplier, the bridge is gone.
The Three Checks for Every Incoming Invoice
Check 1: Is it a structured e-invoice?
A compliant invoice arrives as XRechnung (XML in UBL or CII syntax) or ZUGFeRD 2.0.1+ with the EN 16931 or Extended profile. A PDF alone, a scan, a Word file, or a ZUGFeRD Minimum/Basic-WL hybrid is not compliant. If you cannot tell, run the file through the KoSIT validator.
Check 2: Which mandate date applies to your supplier?
Ask, or estimate from public data. A supplier above 800,000 EUR total turnover must issue structured e-invoices from 1 January 2027. Below the threshold, from 1 January 2028. Their 2026 Gesamtumsatz decides the 2027 status, and it counts all revenue, not just what they bill you.
Check 3: Are you inside a transition period, and did you consent?
If yes to both, deduction survives for now. Treat it as borrowed time, not a solution. Every PDF you accept today trains a supplier process you will have to untrain.
What To Do When a PDF Arrives From a Mandated Supplier
- Do not book it silently. Flag it in your intake workflow.
- Notify the supplier in writing. Reference their issuance obligation and request re-issuance as a compliant e-invoice. The BStBK FAQ explicitly contemplates this: when a received invoice fails the format requirements, the recipient contacts the issuer.
- Keep the evidence. Your notification and their response document that you did not consent to the other-format invoice.
- Escalate repeat offenders. A supplier who cannot produce XRechnung or compliant ZUGFeRD after their mandate date has a software problem. Your deduction should not fund it.
The Buyer's Intake Workflow
Build three gates into invoice receipt:
- Gate 1: Channel. E-invoices arrive through a defined channel: a dedicated mailbox, a Peppol endpoint, a platform. PDFs by email go to a review queue, not straight to booking.
- Gate 2: Validation. Every structured invoice is validated (syntax, business rules) on arrival. Every other-format invoice is checked against the supplier's mandate status.
- Gate 3: Exception handling. Non-compliant invoices from mandated suppliers generate a re-issuance request within days, not at month-end.
Common Misreadings
"The supplier's problem is the supplier's problem." The deduction requirement makes it yours. You are the one claiming Vorsteuer on a document that may not support the claim.
"PDFs are banned already." They are not, until the relevant transition period ends. Receipt of a PDF is not illegal; relying on it after your supplier's mandate date is where deduction risk starts.
"A ZUGFeRD file is always safe." Only the EN 16931 and Extended profiles qualify. Minimum and Basic-WL do not.
"We consented, so we are fine forever." Consent bridges the transition periods only. It has no effect after they close.
This material is information of a general nature and does not constitute legal or tax advice. For a specific situation, verify the current rules or consult a qualified adviser.