Self-billed invoices as e-invoices (XRechnung and ZUGFeRD)

Self-billing under § 14(2) UStG: the recipient of the supply issues the invoice. Required details, type 389, objection and checking it as an e-invoice.

What a self-billed invoice is in German VAT law

A self-billed invoice (Gutschrift) is an invoice issued not by the supplier but by the recipient of the supply – for the supplier's goods or services. This is only allowed if both agreed on it beforehand (§ 14(2) sentence 5 UStG). Typical examples: a charging platform settling with the hosts of its charge points, a publisher with its authors, a marketplace with its sellers.

The document must carry the word "Gutschrift" (§ 14(4) sentence 1 no. 10 UStG). For the supplier the self-billed invoice works as their invoice for their supply, and the recipient can deduct the input VAT from it under the usual conditions.

If the supplier does not agree with the self-billed invoice, they can object to it. With the objection it loses its effect as an invoice (§ 14(2) sentence 6 UStG). The parties settle how to go on; often the recipient issues a new self-billed invoice.

A commercial "Gutschrift" is something else

In everyday German, the correction of one's own invoice is often called a "Gutschrift" too, for example after a return. Under § 14(2) UStG that is not a self-billed invoice but a corrective invoice or a cancellation invoice. In the e-invoice it has its own type code: 381 (credit note). Calling such a correction a "Gutschrift" invites misunderstandings – a self-billed invoice in the VAT sense is always issued by the recipient of the supply.

Does the e-invoicing mandate apply to self-billed invoices?

Yes. A self-billed invoice is an invoice, so the same rules apply: since 2025 every business must be able to receive e-invoices, and from 2027, at the latest from 2028, invoices between domestic businesses generally have to be e-invoices. The Federal Ministry of Finance explains the details and transition periods in its questions and answers on the e-invoice (German). For self-billing this means: where the obligation applies, the recipient issues the self-billed invoice as an e-invoice in an EN 16931 format, for example XRechnung or ZUGFeRD; the transitional rules and exceptions are in the Federal Ministry of Finance's answers.

Type codes in XRechnung and ZUGFeRD

The e-invoice under EN 16931 has its own codes for documents the recipient of the supply issues:

XRechnung allows the code 389. For the codes 261 and 527 the KoSIT validation reports a warning (rule BR-DE-17). In its self-billing, which is in preparation, Fakturnaut therefore writes a self-billed correction and a self-billed cancellation as type 389 with negative amounts that refer to the original self-billed invoice. That is our choice for an XRechnung without warnings, not a legal requirement.

VAT in a self-billed invoice

• Small business as supplier: if the supplier is a small business (Kleinunternehmer), the self-billed invoice contains no VAT but a note on the exemption under § 19 UStG. The recipient therefore needs to know this status.
• Reverse charge: if the recipient owes the VAT under § 13b UStG, the self-billed invoice shows no VAT and carries the note "Steuerschuldnerschaft des Leistungsempfängers" (reverse charge, § 14a(5) UStG).
• Never show VAT that is not owed: whoever shows VAT in an invoice that is too high or not owed can owe it under § 14c UStG. If a self-billed invoice overstates the VAT, the supplier – not the issuer – owes the excess unless they object to it (section 14c.1(3) UStAE). The risk arises when the recipient applies a wrong rate; charging VAT for a small business is an unauthorised statement of tax (§ 14c(2) UStG). The recipient therefore checks the supplier's data before the first self-billed invoice, and the supplier checks every self-billed invoice they receive.

Checking a self-billed invoice you received

If you as the supplier received a self-billed invoice (type 389) as an XRechnung or ZUGFeRD PDF, upload it to our free check. You see it in readable form, with the roles "Supplier (you)" and "Recipient of the supply (issuer)", and learn whether it meets the official rules. The file is not stored.

Also check the content: are the supply, period, amount, VAT rate and your tax number or VAT ID right? If not, object to the issuer of the self-billed invoice (§ 14(2) sentence 6 UStG) and settle the matter with them.

As the recipient of the document: it is your sales document

For you as the supplier, a self-billed invoice is not a purchase invoice but the record of your sale. Book it like your own sales invoices and keep it the same way, as the e-invoice in the form you received it. How you keep your records properly is a matter for you and your bookkeeping or tax adviser.

Frequently asked questions

Does a self-billed invoice really have to say "Gutschrift"?

Yes. When the recipient of the supply issues the invoice, § 14(4) sentence 1 no. 10 UStG requires the word "Gutschrift". Without it the invoice is incomplete. In the e-invoice the type code 389 also marks the self-billed invoice.

What happens if I object to a self-billed invoice?

With the objection the self-billed invoice loses its effect as an invoice (§ 14(2) sentence 6 UStG). The recipient can no longer deduct input VAT from it. Usually they settle again once it is clarified, for example with a new self-billed invoice.

Is a corrective invoice a self-billed invoice?

No. When a business corrects its own invoice, that is a corrective invoice (type 381) or a cancellation invoice, even if it is colloquially called "Gutschrift" in German. A self-billed invoice under § 14(2) UStG is always issued by the recipient of the supply.

Sources

• § 14 UStG (issuing invoices, self-billing and objection), § 14c UStG, § 13b UStG, § 14a UStG, § 19 UStG (German)
• VAT Application Decree (UStAE) (Federal Ministry of Finance, German)
• Questions and answers on the e-invoice (Federal Ministry of Finance, German)

As of 29 October 2026. This guide is not tax advice.