E-Rechnung means an invoice issued, transmitted and received in a structured electronic format that a machine can read and process without anyone retyping it. The format is the whole point, so three familiar documents do not satisfy the obligation:
- A PDF sent by email is an electronic document rather than an electronic invoice.
- A scan of a paper invoice has the same problem, because only a person can read it.
- An invoice written into the body of an email does not satisfy it either.
The obligation applies between businesses in Germany, so it is not triggered at the counter. Selling a service to a private customer stays where it was, and ordinary Rechnungsstellung an Selbstzahler or Privatliquidation against a consumer is outside it.
A pharmacy meets the requirement from the other direction, when it invoices another business:
- A partner practice can be invoiced for a service performed for its patients.
- An employer can be invoiced for a health day at the company.
- A care home can be invoiced in the same way.
The receiving side counts as well, since a pharmacy has to be able to accept a structured invoice from a supplier even where it is not yet obliged to issue one itself.
The phase in has not been stable, because the dates for issuing, the formats that count as compliant and the transitional arrangements have all shifted more than once, and trade coverage is often behind the current position. The deadline that applies to a particular pharmacy should be taken from the applicable law or from the Steuerberater rather than from an article, including this one, and that check belongs before the first business invoice goes out.
Operationally the harder part is not the format but the system around it. Whatever software issues the invoice has to produce the structured form, and the issued invoice then has to be stored in that form, which makes it a question of GoBD-konforme Kassenführung as well: complete, unaltered and producible on request. Keeping a printout of a structured invoice is not keeping the invoice.
The reimbursed side of the business is not touched in the same way, because prescription settlement is handled by the Apothekenrechenzentrum on its own data channel and under its own rules. Nothing in the electronic invoice obligation changes that route.
Whether a specific arrangement with a practice or an employer counts as a business to business invoice at all is the question to settle first, and that is a conversation with the Steuerberater.
This glossary entry is general information about German pharmacy law and practice. It is not legal advice. For binding guidance on your own pharmacy, contact your Landesapothekerkammer.
