Legally allowed — that really is true
Let's start fair: whoever accepts an e-invoice by e-mail meets the legal access requirement. No Peppol connection, no portal, no special software is needed just because the law would require it. It does not.
That is the half-truth that reassures many. The other half decides whether it holds up in practice.
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Where the collective mailbox tips over
An XRechnung arrives as an inconspicuous .xml file in the attachment. In a shared info@ or accounting@ mailbox what typically happens is: the mail is read, the attachment not understood, the message ticked off or forwarded.
No one checks the file systematically. No one ensures the original is preserved. And the mailbox itself can be changed and emptied — it is not an audit-proof archive. Three gaps at once: checking, traceability, retention.
The difference between access and process
Here lies the fallacy. The law governs access — how the invoice reaches you. It does not govern that an inbox is already an intake process.
A process has stations: acceptance, checking, making visible, approval, archiving. A mailbox has exactly one of them: acceptance. The other four it does not do — and those are exactly the ones that become relevant in a tax audit.
When a mailbox is still okay — and when not
It depends on volume and risk, not on ideology:
- Very few invoices, one responsible person, disciplined filing → tolerable short-term.
- Several people with access to the same mailbox → responsibility blurs, risk rises.
- Growing volume, several suppliers, mixed formats → a mailbox alone becomes a source of error.
- Once a tax audit becomes realistic → the original must be demonstrably unchanged.
The pragmatic middle way
You do not have to abolish e-mail — it is a convenient access route. It makes sense to put a real process behind the address: a dedicated invoice address suppliers send to, and behind it automatic validation, readable presentation and an archive that keeps the original unchanged.
For the supplier it remains “one e-mail to one address”. For you it becomes an intake that survives an audit. That is exactly what an inbox solution is for — it does not replace e-mail, it refines it.