Self-billing for charging infrastructure and platforms

Self-billing for charging networks and marketplaces: the agreement, supplier data, monthly payouts, objections, corrections and § 13b UStG.

Who settles by self-billing

Platforms often pay out many small partners: a charging network pays the hosts of its charge points, a marketplace its sellers, a booking portal its hotels. Instead of waiting for an invoice from each partner, the platform as the recipient of the supply settles itself – with a self-billed invoice (Gutschrift) under § 14(2) sentence 5 UStG. Example: Ladeplattform Muster GmbH issues Hotel Muster KG a self-billed invoice every month for the electricity guests charged at the hotel's charging station.

The agreement before the first self-billed invoice

A self-billed invoice only counts as an invoice if supplier and recipient agreed on self-billing beforehand (§ 14(2) sentence 5 UStG). The law prescribes no particular form; a framework contract or a clause in the platform's terms is common. Record when the agreement was concluded and from when it applies – a self-billed invoice issued before the agreement is not an invoice under German VAT law.

What data the platform needs

For every self-billed invoice the platform needs the details the supplier would otherwise put in their own invoice (§ 14(4) UStG):

• full name and address,
• the supplier's tax number or VAT ID,
• whether they are a small business (Kleinunternehmer): then the self-billed invoice contains no VAT but a note on § 19 UStG,
• an e-mail address for delivery and the bank account for the payout.

If something is missing or out of date, the self-billed invoice is wrong. If it shows VAT the supplier does not owe – for example for a small business – this can create a tax debt under § 14c UStG.

Monthly payout runs

Platforms usually settle in runs: once a month one self-billed invoice (type 389) per partner, with all transactions of the period as lines. Each self-billed invoice carries its own sequential number from the platform's number range and the word "Gutschrift" (§ 14(4) sentence 1 no. 10 UStG). From 2027, at the latest from 2028, it generally has to be issued as an e-invoice between domestic businesses, for example as an XRechnung or ZUGFeRD file; transitional rules apply until then (questions and answers of the Federal Ministry of Finance, German).

Delivery and objection

The self-billed invoice goes to the supplier, usually by e-mail with the e-invoice attached. The supplier can object to it; it then loses its effect as an invoice (§ 14(2) sentence 6 UStG), and the platform may no longer deduct input VAT from it. Record when each self-billed invoice was delivered and whether the partner objected or accepted it.

Corrections and cancellations

If a self-billed invoice was wrong, the platform corrects it with a self-billed correction that refers to the original; a self-billed invoice that is wrong altogether is reversed with a self-billed cancellation. If the partner objected, the platform issues a new self-billed invoice once the matter is settled.

Electricity to resellers: § 13b UStG

If a business that is itself a reseller of electricity within the meaning of § 3g UStG supplies electricity to another such reseller, the recipient owes the VAT (§ 13b(2) no. 5 letter b and (5) sentence 4 UStG). Both must therefore be resellers: businesses that resell electricity themselves and whose own use of it is minor. A host that mainly uses electricity itself and only supplies it at its charge point (such as a hotel or a retailer) and the operator of a PV system are therefore usually not resellers (sections 3g.1 and 13b.3a UStAE). Whether a charging network is itself a reseller depends on its model. Where the rule applies, the self-billed invoice shows no VAT and carries the note "Steuerschuldnerschaft des Leistungsempfängers" (reverse charge, § 14a(5) UStG). Whether this applies to your model is for you and your tax adviser to decide; Fakturnaut makes no tax assessment.

No self-billing: charging a company car at home

If an employer reimburses an employee for the electricity used to charge the company car at home, that is no exchange of supplies between businesses and therefore no self-billed invoice under § 14(2) UStG. For the employee the reimbursement is generally a tax-free reimbursement of expenses (§ 3 no. 50 EStG). Self-billing requires the supplier to be a business; Fakturnaut will therefore only accept suppliers recorded as businesses.

Self-billed invoices with the Fakturnaut API

Fakturnaut is preparing self-billing in its e-invoicing API: your platform will create suppliers and self-billing agreements, issue self-billed invoices one by one or as a monthly run, and receive validated XRechnung files or ZUGFeRD PDFs. Before each self-billed invoice Fakturnaut will check that a valid agreement exists, deliver it by e-mail on request and record objection and acceptance. Whether and in which plans this is available yet is shown right below; the interface is described in the documentation with the API reference.

Self-billing (Gutschriften): in preparation. Access on request: write to us.

Frequently asked questions

Does the self-billing agreement have to be in writing?

The law only requires that it was made before the self-billed invoice (§ 14(2) sentence 5 UStG). A written framework contract or a clause in the terms, however, helps to prove the agreement later.

Can I issue a self-billed invoice to a private host?

Self-billing requires the supplier to be a business. Whether a private host is a business for VAT purposes is for the parties to clarify with their tax advisers; Fakturnaut will only issue self-billed invoices for suppliers recorded as businesses.

What if the partner does not respond?

Silence is no objection: the self-billed invoice stays an invoice as long as the supplier does not object (§ 14(2) sentence 6 UStG). If your agreement asks for an acceptance, record whether you have it.

Sources

• § 14 UStG (self-billing, required details and objection), § 3g UStG, § 13b UStG, § 14a UStG, § 14c UStG, § 19 UStG (German)
• § 3 EStG (no. 50: reimbursement of expenses, 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.