E-invoicing in Switzerland: eBill, obligations and the e-invoice mandates in Germany and France

Is e-invoicing mandatory in Switzerland?

No, not between private companies. The VAT Act only provides that the supplier issues an invoice “on request” of the recipient of the supply (Art. 26 para. 1 VAT Act), with specific mandatory details (para. 2), without imposing a format. Electronic supporting documents are accepted on the conditions of the Swiss Code of Obligations (CO) and of the Ordinance on the Keeping and Retention of Accounting Records (GeBüV in German, OLICO in French) (Art. 122 VAT Ordinance, in the version in force since 1 January 2018).

A PDF received by email can therefore serve as a supporting document, provided it contains the details required by Art. 26 para. 2 VAT Act and is retained in line with the GeBüV. Nor does the Federal Tax Administration (FTA, ESTV in German) require a qualified electronic signature on e-invoices: see our guide to electronic signatures.

The Confederation requires e-invoices from its suppliers

Since 1 January 2016, the federal administration has required an electronic invoice from its suppliers for contracts worth more than CHF 5,000. Two channels are accepted:

• a PDF sent by email to the address of the administrative unit concerned (25 MB at most, free of charge);
• structured data sent through a service provider: PostFinance, Swisscom, the interconnected networks of ABACUS, io-market, PENTAG or StepCom.

Since 30 June 2023, the federal administration no longer accepts PDF invoices sent through a service provider: by that route, only structured data gets through.

eBill: what it is and who it is for

eBill is the Swiss digital invoice: the payer receives it directly in their e-banking, where they pay, and checks and approves it in a few clicks. For a recurring invoice, they can give standing approval.

The infrastructure is provided by SIX (“powered by SIX”). The eBill website reports 4 million registered users and 95% of Swiss financial institutions connected (operator's figures, viewed on 27 September 2026).

Who is it for? On the payer's side, anyone who pays their bills through e-banking. On the issuer's side, eBill makes sense above all when you invoice many payers of this kind: subscriptions, rents or membership fees, for example. The issuer goes through a network partner, and a QR-bill can serve as the basis for an eBill.

On the software side: KLARA mentions sending via eBill in its API; bexio offers a third-party app, “eBill von iomarket AG”; Proffix states that it reads incoming eBills in its accounts payable module.

PDF, QR-bill, ZUGFeRD, XRechnung: what are the differences?

An e-invoice in the strict sense is a structured data file that software reads without interpreting an image. A PDF is a page layout: it has to be read, by hand or by OCR, to feed the accounting system.

The European standard EN 16931 is the reference: in Germany, an E-Rechnung must comply with it, “in particular” as XRechnung or as ZUGFeRD from version 2.0.1. In France, the DGFiP (the French tax authority) points out that “a plain PDF sent electronically is not an electronic invoice within the meaning of the scheme”.

The QR-bill remains first and foremost a payment slip, with some optional invoice data: see our QR-bill guide. To check the code on an invoice you have received, use our QR-bill validator.

France: e-invoicing mandatory since 1 September 2026

Since 1 September 2026, “all businesses, whatever their size and legal form”, within the scope of the reform described below, have had to receive their e-invoices through an approved platform. Issuing follows in two stages.

Scope. E-invoicing applies to transactions (i) carried out between VAT-registered businesses established in France, (ii) that fall within the scope of French VAT and (iii) to which French invoicing rules apply. For a customer established outside France, there is no e-invoicing obligation; the issuer does, however, send the transaction data to the tax authority: this is e-reporting (Art. 290 I of the French General Tax Code, CGI).

E-reporting. It concerns VAT-registered businesses established in France, for their transactions with private individuals or foreign operators. Some foreign businesses not established in France may be subject to it when the transaction is deemed to take place in France and is subject to VAT: most often sales to non-taxable persons, such as distance sales.

What this means for a Swiss SME

A Swiss SME with no establishment in France that invoices a French business customer falls outside the scope of mandatory e-invoicing: criterion (i) is not met. It is the French customer who reports the purchase through e-reporting. The other way round, a French supplier invoicing you is not required to send you an e-invoice; it transmits the transaction data through e-reporting.

Germany: E-Rechnung received since 2025, issued from 2027 or 2028

In Germany, the obligation covers transactions between “inländisch” businesses, that is, businesses established in Germany. Since 1 January 2025, all of them have had to be able to receive an E-Rechnung; an email inbox is enough. Issuing becomes mandatory in stages.

Exceptions: invoices to consumers, small amounts up to EUR 250 and many exempt supplies. Accepted formats: compliant with EN 16931, in particular XRechnung and ZUGFeRD from version 2.0.1, excluding the MINIMUM and BASIC-WL profiles.

What this means for a Swiss SME

A business is “inländisch” if its registered office, its management or a permanent establishment involved in the transaction is located in Germany. A Swiss SME with none of these is therefore not required to issue E-Rechnungen to its German customers. If it is registered for German VAT without a fixed establishment, the BMF states that it may mention this on its invoice to justify the absence of an E-Rechnung.

Incoming structured invoices: what to prepare

Nothing obliges your French or German suppliers to send you a structured format. But their invoicing software now has to produce one for their domestic customers: expect to receive some, and prepare five things.

1. Accept XML files. An XRechnung can arrive without a PDF; without a viewer, it is hard for a human to read.
2. Read the data in a ZUGFeRD PDF rather than its text: the data is already structured, no OCR needed.
3. Keep your checks. Supplier IBAN, duplicates, amounts, VAT: a structured format avoids re-keying, not errors or fraud.
4. Retain the file as received with the integrity safeguards of the GeBüV: see our record retention guide.
5. Check what your software reads. Proffix states that it reads ZUGFeRD and eBill; DeepO (Abacus ecosystem) gives priority to the data in a QR code or a ZUGFeRD file; Infoniqa ONE 200 reads ZUGFeRD 2.0 through a separate product, Infoniqa X.

To organise the receipt and entry of these invoices, whatever their format, see our guide to supplier invoice capture.

What Dossivio does

Dossivio Capture receives your supplier invoices by email, portal or scan, assigns them to the right file, extracts the data, flags duplicates and IBAN changes, and prepares the entry for your accounting software. An authorised person approves before any payment, and the data is hosted in Switzerland.

Dossivio does not replace a tax adviser's opinion on your obligations in France or Germany.