Example project plan

Project plan for the switch to e-invoicing

The project plan for the switch to e-invoicing organizes compliance, process design, system integration, testing, training, archiving and go-live into a controlled schedule. This example for a 70-employee wholesaler spans 16 weeks, seven phases and 39 tasks, with an approximate €58,500 budget. It covers XRechnung, ZUGFeRD, ERP and accounting integration, GDPR requirements, GoBD archiving, risks and stakeholders.

  • 16 Weeks
  • 7 Phases
  • 39 Tasks
  • Budget approx. €58,500

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Example plan

Electronic Invoicing and ERP/Accounting Integration

The project will introduce electronic invoice receipt and transmission using XRechnung and ZUGFeRD. It will integrate invoice processing with the existing ERP and accounting systems, including validation, approval, posting, reconciliation, and exception handling. Invoices and related evidence will be retained in an audit-proof archive that meets German GoBD requirements. GDPR requirements, including the Art. 28 data processing agreement and the Art. 30/35 assessments, will be completed before applicable processing and go-live activities, while accounting users will receive role-specific training.

Total Progress0%
16Weeks
0/7Phases
0/39Tasks
€58,500Budget
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Phases

1

Phase 1: Initiation and Current-State Assessment

Pending · 2W · 0/4
Managing Director or Executive Sponsor
0

Establish project governance and document the current invoice, ERP, accounting, and archiving landscape. This creates the baseline for scope, volume estimates, compliance planning, and the four-month delivery schedule.

Conduct the project kickoff and approve decision rights, escalation paths, reporting cadence, and the Week 16 cutover target
Oct 6 – Oct 6 1 day
Managing Director or Executive Sponsor
Inventory incoming and outgoing invoice volumes, current XRechnung/ZUGFeRD capabilities, ERP and accounting modules, interfaces, approval steps, and manual workarounds
Oct 6 – Oct 10 5 days
IT/ERP Administrator
Interview Accounts Payable and Accounts Receivable representatives to document invoice receipt, validation, exception handling, payment, dispatch, and reconciliation procedures
Oct 6 – Oct 8 3 days
Head of Accounting
Approve the project charter, initial scope, success criteria, stakeholder register, and phase-gate calendar
Oct 7 – Oct 8 2 days
Managing Director or Executive Sponsor
Conduct requirements workshops for incoming and outgoing invoices, approval routing, posting, rejection handling, partner communication, reporting, and month-end reconciliation
Oct 20 – Oct 23 4 days
Head of Accounting
Create a compliance requirements register covering mandatory tax invoice fields, XRechnung and ZUGFeRD profiles, German GoBD controls, retention, audit trails, and retrieval requirements
Oct 20 – Oct 23 4 days
Tax and Compliance Lead or External Tax Adviser
Perform the initial GDPR data-flow assessment for invoice data, provider processing, ERP interfaces, user access, retention, and cross-system transfers; identify the Art. 30 and Art. 35 actions required before go-live
Oct 20 – Oct 22 3 days
Data Protection Officer or Privacy Counsel
Review the provider’s security, subprocessor, hosting, deletion, support, and audit documentation and prepare the GDPR Art. 28 DPA for negotiation and signature
Oct 23 – Oct 29 5 days
Data Protection Officer or Privacy Counsel
Approve the prioritized requirements backlog, compliance checklist, test-data rules, and the prohibition on real-data testing or migration before the DPA is signed
Oct 20 – Oct 21 2 days
Managing Director or Executive Sponsor
Design target workflows for incoming and outgoing XRechnung and ZUGFeRD invoices, including validation, approval, posting, rejection, correction, resubmission, and exception ownership
Nov 3 – Nov 6 4 days
Head of Accounting
Create the field-mapping specification between ERP, accounting, e-invoicing services, and archive, including supplier/customer identifiers, tax codes, invoice references, payment terms, line items, and attachments
Nov 3 – Nov 7 5 days
ERP Integration Partner or Implementation Consultant
Define supported XRechnung versions, ZUGFeRD profile requirements, XML/PDF consistency checks, transmission statuses, partner-specific rules, and validation error handling
Nov 3 – Nov 5 3 days
Tax and Compliance Lead or External Tax Adviser
Design the GoBD archive control model for immutability, completeness, indexing, retention, audit trail, access segregation, retrieval, export, and evidence of procedural controls
Nov 3 – Nov 6 4 days
IT/ERP Administrator
Produce the integration test strategy, synthetic-data set, reconciliation control totals, migration approach if legacy invoices are in scope, and defect-severity criteria
Nov 10 – Nov 12 3 days
ERP Integration Partner or Implementation Consultant
Provision and configure the development, test, and controlled production environments, including module licences, technical users, API credentials, backups, and access roles
Nov 17 – Nov 19 3 days
IT/ERP Administrator
Build and configure the inbound interface for receiving XRechnung and ZUGFeRD invoices, including format detection, validation responses, document capture, duplicate checks, and ERP hand-off
Nov 17 – Nov 24 6 days
ERP Integration Partner or Implementation Consultant
Build and configure the outbound interface for generating, validating, transmitting, and tracking XRechnung and ZUGFeRD invoices from the ERP and accounting system
Nov 25 – Dec 2 6 days
ERP Integration Partner or Implementation Consultant
Configure field mappings, tax codes, account assignment, cost centers, payment terms, buyer/supplier identifiers, invoice references, and posting logic
Nov 17 – Nov 21 5 days
Head of Accounting
Configure approval workflows, segregation of duties, exception queues, rejection notifications, resubmission rules, and duplicate-invoice controls
Nov 24 – Nov 28 5 days
Head of Accounting
Execute the GDPR Art. 28 DPA with the e-invoicing and archive provider no later than Week 10, approximately six weeks before the planned Week 16 production cutover; prohibit real-data processing until execution is confirmed
Nov 17 – Nov 18 2 days
Data Protection Officer or Privacy Counsel
Configure partner endpoints, certificates, transmission channels, delivery-status handling, and representative XRechnung and ZUGFeRD test connections
Nov 17 – Nov 19 3 days
E-Invoicing and Archive Provider
Execute unit tests using synthetic or anonymized data only until the DPA signature is confirmed, covering mappings, validation, posting, approvals, transmission, and error handling
Dec 3 – Dec 9 5 days
ERP Integration Partner or Implementation Consultant
Validate master data for customers, suppliers, tax codes, bank details, invoice numbering, and mandatory recipient identifiers, and prepare the controlled migration and reconciliation file
Nov 20 – Nov 24 3 days
IT/ERP Administrator
Resolve integration defects from unit testing and repeat failed mapping, posting, transmission, and status-processing tests
Dec 10 – Dec 12 3 days
ERP Integration Partner or Implementation Consultant
Configure GoBD archive retention, immutability, completeness controls, indexing, version and change protection, audit trails, export, and retrieval for invoice records and related evidence
Dec 15 – Dec 19 5 days
E-Invoicing and Archive Provider
Configure role-based access, accounting and administrator segregation, access reviews, backup procedures, incident logging, and archive availability monitoring
Dec 15 – Dec 17 3 days
IT/ERP Administrator
Create the operating procedure for archive capture, failed ingestion, corrections, retention exceptions, retrieval requests, audit exports, and periodic control reviews
Dec 15 – Dec 17 3 days
Head of Accounting
Execute end-to-end tests for incoming and outgoing XRechnung and ZUGFeRD invoices, including validation, approval, posting, transmission, rejection, correction, archiving, retrieval, and status reconciliation
Dec 15 – Dec 19 5 days
ERP Integration Partner or Implementation Consultant
If required, migrate the approved legacy invoice population using controlled batches, record counts, checksums, retention metadata, and reconciliation to accounting records
Dec 18 – Dec 22 3 days
IT/ERP Administrator
Review test evidence, reconcile document and posting totals, classify remaining defects, and confirm that no critical GoBD, tax, format, or reconciliation issue remains open
Dec 18 – Dec 22 3 days
Head of Accounting
Conduct user acceptance testing with Accounts Payable, Accounts Receivable, and accounting users across normal invoices, rejected invoices, corrections, exceptions, approvals, postings, and month-end reconciliation
Dec 29 – Jan 2 5 days
Head of Accounting
Resolve UAT findings, retest corrected workflows, and obtain written acceptance from the Head of Accounting and designated AP/AR representatives
Dec 29 – Dec 31 3 days
ERP Integration Partner or Implementation Consultant
Update the GDPR Art. 30 record of processing activities with provider details, invoice data categories, purposes, recipients, retention, security measures, and transfer flows; document the Art. 35 DPIA necessity decision and complete a DPIA if required
Dec 29 – Jan 1 4 days
Data Protection Officer or Privacy Counsel
Deliver role-based accounting training by the end of Week 13, approximately three weeks before the planned Week 16 cutover, covering invoice handling, exceptions, approvals, posting, archive retrieval, and escalation procedures
Jan 5 – Jan 7 3 days
Head of Accounting
Approve the cutover checklist, support roster, user access list, open-issue disposition, communications, rollback conditions, and final go-live recommendation
Dec 29 – Dec 30 2 days
Managing Director or Executive Sponsor
Execute the production cutover in Week 16, including final configuration promotion, access activation, opening control totals, invoice-number control, archive verification, and rollback readiness
Jan 12 – Jan 13 2 days
IT/ERP Administrator
Monitor incoming and outgoing XRechnung and ZUGFeRD transmissions, validation results, delivery statuses, rejected invoices, posting errors, and archive ingestion throughout the hypercare period
Jan 12 – Jan 16 5 days
E-Invoicing and Archive Provider
Perform daily reconciliation between transmitted invoices, ERP postings, accounting records, and archived documents and resolve priority incidents within agreed response times
Jan 12 – Jan 15 4 days
Head of Accounting
Verify production retrieval, audit-trail, access-control, retention, and operating-procedure evidence and hand over support, monitoring, and control ownership to business and IT operations
Jan 14 – Jan 16 3 days
IT/ERP Administrator

Timeline

Timeline 7 PhasesStart: Oct 6, 2026
Phase / Task
Oct 2026
Nov 2026
Dec 2026
Jan 2027
W 1Oct 6
W 3Oct 20
W 5Nov 3
W 7Nov 17
W 9Dec 1
W 11Dec 15
W 13Dec 29
W 15Jan 12
Initiation and Current-State AssessmentOct 6 – Oct 19 · 2 wk · 0/4
Initiation and Current-State Assessment
Requirements, Compliance and Provider ReadinessOct 20 – Nov 2 · 2 wk · 0/5
Requirements, Compliance and Provider Readiness
Target Process and Technical DesignNov 3 – Nov 16 · 2 wk · 0/5
Target Process and Technical Design
ERP, Accounting and E-Invoicing IntegrationNov 17 – Dec 14 · 4 wk · 0/10
ERP, Accounting and E-Invoicing Integration
GoBD Archive Setup and End-to-End TestingDec 15 – Dec 28 · 2 wk · 0/6
GoBD Archive Setup and End-to-End Testing
User Acceptance, GDPR Finalization and TrainingDec 29 – Jan 11 · 2 wk · 0/5
User Acceptance, GDPR Finalization and Training
Go-Live and HypercareJan 12 – Jan 25 · 2 wk · 0/4
Go-Live and Hypercare
PlannedIn progressCompletedBlockedMilestones

Budget

Budget: €58,500
ERP, Accounting & Interface Integration · €16,250Software & E-Invoicing Licences · €11,700GoBD Archive Implementation · €11,050Data Preparation, Migration & Reconciliation Testing · €7,800Training, Cutover & Hypercare · €7,800GDPR, Tax & Legal Compliance · €3,900
ERP, Accounting & Interface Integration€16,250
ItemQtyUnit priceTotal
Integration architect: interface and posting design5 Person days€1,100€5,500
ERP integration developer: APIs, mappings and transmission workflows10 Person days€900€9,000
Posting logic, approval workflow and error-handling configuration2 Person days€875€1,750
Software & E-Invoicing Licences€11,700
ItemQtyUnit priceTotal
E-invoicing module activation and tenant setup1 Flat rate€7,000€7,000
XRechnung and ZUGFeRD format handling and validation package1 Flat rate€2,500€2,500
E-invoice transaction capacity and service subscription4 Person days€550€2,200
GoBD Archive Implementation€11,050
ItemQtyUnit priceTotal
GoBD archive configuration, retention rules and immutability setup1 Flat rate€6,000€6,000
Audit trail, access control and retrieval validation2 Person days€1,100€2,200
GoBD procedural documentation and audit evidence package3 Person days€950€2,850
Data Preparation, Migration & Reconciliation Testing€7,800
ItemQtyUnit priceTotal
IT/ERP administrator: master-data and tax-field cleansing5 Person days€600€3,000
AP/AR key users: approved test datasets and business scenarios6 Person days€350€2,100
Migration and reconciliation consultant: archive and accounting reconciliation2 Person days€900€1,800
End-to-end defect retesting and test evidence pack1 Flat rate€900€900
Training, Cutover & Hypercare€7,800
ItemQtyUnit priceTotal
Accounting training workshops for AP, AR and accounting staff16 Person days€180€2,880
Operating instructions, exception procedures and user support materials2 Person days€835€1,670
Production cutover and go-live support2 Person days€1,000€2,000
Post-go-live monitoring, incident triage and stabilization support1 Flat rate€1,250€1,250
GDPR, Tax & Legal Compliance€3,900
ItemQtyUnit priceTotal
GDPR Art. 28 DPA review, provider negotiation and execution before real-data testing or migration (Phase 2)15 Person days€1,000€1,500
GDPR Art. 30 record of processing activities update (initial review in Phase 2, finalization in Phase 6)1 Flat rate€900€900
GDPR Art. 35 DPIA necessity assessment and documented decision (initial review in Phase 2, finalization in Phase 6)1 Flat rate€900€900
Tax adviser validation of mandatory invoice fields, tax coding and format requirements75 Person days€800€600

Risks

High

Incorrect Tax Data or Mandatory Invoice Fields

If ERP mappings for VAT codes, buyer identifiers, invoice references, totals, payment terms, or other mandatory fields are incomplete by the design sign-off in Week 6, XRechnung or ZUGFeRD invoices may be rejected, posted incorrectly, or create tax and audit findings during Weeks 10–16.

Countermeasure: The Head of Accounting and Tax/Compliance Lead will approve the invoice-field and tax-code mapping by Week 6; the IT/ERP Administrator will implement automated validation and complete unit testing by Week 10; accounting will verify representative invoices during UAT in Weeks 13–14.
High

GDPR Article 28 DPA Not Executed Before Real-Data Processing

If the provider’s data processing agreement is not signed before any real invoice data is used for testing, migration, or production preparation, processing may begin without the required GDPR Art. 28 contract.

Countermeasure: The Data Protection Officer or Privacy Counsel will review the provider terms in Week 3, negotiate and approve the DPA in Week 4, and require execution before real-data testing or migration begins. The IT/ERP Administrator will use synthetic or anonymized test data until written confirmation is received.
High

Incomplete RoPA Update or DPIA Necessity Assessment

If the new provider, invoice data flows, retention activities, access roles, or transfer arrangements are not documented by Week 12, the project could reach go-live without a complete GDPR Art. 30 record or a documented Art. 35 DPIA decision.

Countermeasure: The DPO or Privacy Counsel will complete the initial processing assessment in Weeks 3–4, record the DPIA necessity decision, and finalize the RoPA and any required DPIA in Weeks 13–14 before the Week 15 go-live approval.
High

GoBD Archive Is Not Audit-Proof

If the archive cannot demonstrate immutability, completeness, traceability, retention, access history, original-format preservation, or timely retrieval during testing in Week 12, invoices may not be sufficiently verifiable during a German tax audit.

Countermeasure: The IT/ERP Administrator and archive provider will design GoBD controls and procedural documentation by Week 6, configure them by Week 10, and complete retrieval, audit-trail, retention, and tamper-resistance tests by Week 12; the Tax/Compliance Lead will formally review the evidence before UAT approval.
High

ERP, Accounting, and Invoice Reconciliation Errors

If interface mappings, master data, posting rules, approval workflows, or retry handling are defective after integration work in Weeks 7–10, invoices may be duplicated, omitted, misposted, or approved without adequate controls.

Countermeasure: The ERP Integration Partner and IT/ERP Administrator will validate master data and complete unit tests by Week 10; Accounts Payable, Accounts Receivable, and the Head of Accounting will execute end-to-end reconciliation and exception tests in Weeks 11–12, with no unresolved critical defects permitted at go-live.
Medium

Partner Interoperability or User Adoption Failure

If key customers or suppliers cannot process the selected XRechnung or ZUGFeRD profile by Week 12, or accounting users are not trained and UAT is incomplete by Week 14, manual workarounds may delay payments, weaken controls, and disrupt month-end closing after go-live.

Countermeasure: The Accounts Payable and Accounts Receivable representatives, provider, and ERP Integration Partner will test representative partner profiles and transmission routes in Weeks 11–12; the Head of Accounting will complete UAT and train affected users by Week 14, with documented exception procedures and a controlled fallback process for hypercare.

Stakeholders

MD

Managing Director or Executive Sponsor

Owns the business case and budget, resolves scope escalations, and grants final go-live approval.

Involve: From Phase 1 through governance reviews and the go-live decision
HO

Head of Accounting

Defines posting, reconciliation, approval, exception-handling, and month-end requirements and accepts the accounting solution.

Involve: From Phase 1 through requirements, UAT, training, and go-live
AP

Accounts Payable and Accounts Receivable Representatives

Validate incoming and outgoing invoice workflows, usability, partner scenarios, and operational exception handling.

Involve: From Phase 1, with intensive involvement during design, testing, and training
IE

IT/ERP Administrator

Owns environments, configuration, interfaces, access rights, backups, deployment, monitoring, and technical cutover.

Involve: From Phase 1 through implementation, testing, cutover, and hypercare
TA

Tax and Compliance Lead or External Tax Adviser

Confirms mandatory invoice content, tax coding, format compliance, retention rules, and audit evidence.

Involve: From Phase 2 through design approval, testing, and readiness review
DP

Data Protection Officer or Privacy Counsel

Reviews data flows, approves the Art. 28 DPA, updates the Art. 30 record, and documents the Art. 35 DPIA necessity decision.

Involve: From Phase 1 and before any real-data testing, migration, or go-live
EI

E-Invoicing and Archive Provider

Provides XRechnung/ZUGFeRD processing, transmission, archive controls, service documentation, and contractual privacy commitments.

Involve: From Phase 2 through configuration, testing, go-live, and support
EI

ERP Integration Partner or Implementation Consultant

Designs and delivers interfaces, mappings, posting logic, test support, migration activities, and defect remediation.

Involve: From Phase 2 through technical design, implementation, testing, and hypercare

Compliance

Required 6

Execute a GDPR Art. 28 data processing agreement with the e-invoicing/archive provider before any processing of real invoice data, including real-data testing or migration.

Data Protection Officer or Privacy Counsel; Provider; Managing Director or Executive Sponsor Review and execute in Weeks 3–4; hard gate before real-data testing or migration in Phase 4
Required
Rule from the compliance library
GDPR (General Data Protection Regulation)(EU 2016/679)
  • Legal basis for every processing of personal data (consent, contract, legal obligation, legitimate interest)
  • Complete record of processing activities (Art. 30) for all processes
  • Data Processing Agreements (DPA) with all sub-processors
  • Data Protection Impact Assessment (DPIA) for high-risk processing
  • Technical and organisational measures (TOM) documented

If breached: Fines up to €20 million or 4% of global annual revenue, whichever is higher. Plus civil damages claims by affected individuals.

Evidence

No evidence yet. In PathHub you attach evidence to each obligation, e.g. minutes, a certificate or a link to the document, and export everything as a PDF evidence report.

File Link Note

Update the GDPR Art. 30 record of processing activities to document invoice data categories, purposes, recipients, systems, provider processing, retention, access roles, and data flows.

Data Protection Officer or Privacy Counsel; IT/ERP Administrator Initial assessment in Weeks 3–4; finalize in Weeks 13–14 before Week 15 go-live
Required
Rule from the compliance library
GDPR (General Data Protection Regulation)(EU 2016/679)
  • Legal basis for every processing of personal data (consent, contract, legal obligation, legitimate interest)
  • Complete record of processing activities (Art. 30) for all processes
  • Data Processing Agreements (DPA) with all sub-processors
  • Data Protection Impact Assessment (DPIA) for high-risk processing
  • Technical and organisational measures (TOM) documented

If breached: Fines up to €20 million or 4% of global annual revenue, whichever is higher. Plus civil damages claims by affected individuals.

Evidence

No evidence yet. In PathHub you attach evidence to each obligation, e.g. minutes, a certificate or a link to the document, and export everything as a PDF evidence report.

File Link Note

Assess whether a GDPR Art. 35 data protection impact assessment is required for the new processing, document the necessity decision, and complete a DPIA if the assessment identifies high risk.

Data Protection Officer or Privacy Counsel Initial decision in Weeks 3–4; final review and documentation in Weeks 13–14 before go-live
Required
Rule from the compliance library
GDPR (General Data Protection Regulation)(EU 2016/679)
  • Legal basis for every processing of personal data (consent, contract, legal obligation, legitimate interest)
  • Complete record of processing activities (Art. 30) for all processes
  • Data Processing Agreements (DPA) with all sub-processors
  • Data Protection Impact Assessment (DPIA) for high-risk processing
  • Technical and organisational measures (TOM) documented

If breached: Fines up to €20 million or 4% of global annual revenue, whichever is higher. Plus civil damages claims by affected individuals.

Evidence

No evidence yet. In PathHub you attach evidence to each obligation, e.g. minutes, a certificate or a link to the document, and export everything as a PDF evidence report.

File Link Note

Implement GDPR-appropriate security and access controls, including role-based access, least privilege, authentication, logging, backup protection, and controlled administrator access for ERP and archive systems.

IT/ERP Administrator; Provider Define in Weeks 5–6, configure in Weeks 7–10, verify during Weeks 11–14 and hand over at go-live
Required
Rule from the compliance library
GDPR (General Data Protection Regulation)(EU 2016/679)
  • Legal basis for every processing of personal data (consent, contract, legal obligation, legitimate interest)
  • Complete record of processing activities (Art. 30) for all processes
  • Data Processing Agreements (DPA) with all sub-processors
  • Data Protection Impact Assessment (DPIA) for high-risk processing
  • Technical and organisational measures (TOM) documented

If breached: Fines up to €20 million or 4% of global annual revenue, whichever is higher. Plus civil damages claims by affected individuals.

Evidence

No evidence yet. In PathHub you attach evidence to each obligation, e.g. minutes, a certificate or a link to the document, and export everything as a PDF evidence report.

File Link Note

Support and validate the required XRechnung and ZUGFeRD profiles, including EN 16931-relevant structured data, metadata, attachments, validation results, and customer or supplier interoperability.

E-Invoicing Provider; ERP Integration Partner; Tax and Compliance Lead Profile selection and design in Weeks 3–6; partner and end-to-end testing in Weeks 11–12
Required
Rule from the compliance library

There is no matching rule in the library for this obligation. In PathHub you can link a rule from the library if needed.

Evidence

No evidence yet. In PathHub you attach evidence to each obligation, e.g. minutes, a certificate or a link to the document, and export everything as a PDF evidence report.

File Link Note

Configure and document GoBD-compliant retention and archiving, including preservation of invoice content and original format, immutability, completeness, traceability, audit trails, retrieval, access controls, retention periods, and operating procedures.

IT/ERP Administrator; Archive Provider; Tax and Compliance Lead Design in Weeks 5–6; configuration in Weeks 7–10; evidence and acceptance in Weeks 11–12
Required
Rule from the compliance library
GoBD and e-invoicing(AO §§ 146, 147; GoBD (BMF); UStG § 14)
  • Process documentation for all tax-relevant systems and procedures
  • Complete and unalterable records, changes are logged
  • Retention of tax-relevant documents for the statutory period (generally 8 or 10 years)
  • Data access for tax audits possible (Sec. 147(6) German Fiscal Code)
  • Receipt of structured e-invoices (XRechnung, ZUGFeRD) since 1 Jan 2025
  • Issuing e-invoices to domestic businesses: from 2027 for prior-year turnover above EUR 800,000, from 2028 generally for all (exceptions incl. small-amount invoices, small businesses)

If breached: Formal defects can lead to the bookkeeping being rejected and the tax base being estimated (Sec. 162 German Fiscal Code); refusing data access can trigger a delay penalty (Sec. 146(2c)).

Evidence

No evidence yet. In PathHub you attach evidence to each obligation, e.g. minutes, a certificate or a link to the document, and export everything as a PDF evidence report.

File Link Note
Important 1

Train accounting users on electronic invoice receipt and dispatch, validation, approvals, exception handling, archive retrieval, privacy controls, and month-end reconciliation, with attendance and operating instructions documented.

Head of Accounting; Accounts Payable and Accounts Receivable Representatives Materials and UAT support in Weeks 11–13; training completed by Week 14
Important
Rule from the compliance library
Industrial Safety Ordinance (BetrSichV)
  • Risk assessment before work equipment is used (Sec. 3)
  • Inspection of assembly-dependent equipment by a competent person before first commissioning (Sec. 14)
  • Intervals for recurring inspections defined and documented
  • Installations requiring monitoring inspected before commissioning and periodically, by an approved inspection body where required (Secs. 15, 16)
  • Operating instructions and employee instruction (Sec. 12)

If breached: Administrative offences under Sec. 22 BetrSichV with fines under Sec. 25 ArbSchG; endangering life or health is a criminal offence under Sec. 23 BetrSichV.

Evidence

No evidence yet. In PathHub you attach evidence to each obligation, e.g. minutes, a certificate or a link to the document, and export everything as a PDF evidence report.

File Link Note

Milestones

  1. Week 2

    Approved project charter and documented current-state assessment covering invoice processes, systems, interfaces, volumes, and archive requirements.

    Depends on: Sponsor alignment and access to current process, system, interface, volume, and archive information
  2. Week 4

    Approved requirements and compliance register, completed initial GDPR assessment, and DPA package ready for execution.

    Depends on: Approved charter, current-state assessment, provider participation, and privacy review
  3. Week 6

    Signed-off target process model, interface and mapping specification, format rules, GoBD control design, and test strategy.

    Depends on: Approved requirements, compliance register, and confirmed provider capabilities
  4. Week 10

    Configured and unit-tested ERP/e-invoicing integration, validated master data, and executed Art. 28 DPA before any real-data testing or migration.

    Depends on: Signed-off technical design, available environments, provider access, clean master data, and executed DPA before real-data use
  5. Week 12

    GoBD archive controls operational and documented, end-to-end test evidence complete, and all critical defects resolved or formally blocked from go-live.

    Depends on: Completed integration, configured archive, approved test data, and successful unit testing
  6. Week 14

    UAT acceptance completed, RoPA and Art. 35 assessment finalized, accounting users trained, and formal readiness approval issued for Week 16 cutover.

    Depends on: Successful end-to-end testing, resolved critical defects, completed privacy documentation, and trained users
  7. Week 16

    Production invoicing operational, reconciliations completed, no critical transmission or posting defects outstanding, and operational GoBD/GDPR evidence handed over.

    Depends on: Formal readiness approval, completed cutover plan, production access, and operational support coverage

How this plan was created

This plan was created by PathHub AI from a single description: “Switch to electronic invoicing at a wholesale company with 70 employees: receiving and sending in XRechnung and ZUGFeRD format, ERP and accounting integration, audit-proof archiving under German GoBD rules, training for accounting. Completion in four months.” Without company context. With your departments, approval processes and compliance requirements it becomes much more precise.

Obligations

Obligations with lead time: what many think of too late

These obligations are typically triggered by the switch to e-invoicing (example: Germany). PathHub AI schedules them with lead time, warns when the schedule is too tight and shows the rule with its criteria under “Rule & evidence”, which you tick off and back with evidence. Not legal advice.

Implement receiving and sending e-invoices, update GoBD process documentation and archiving
Required 4–8 weeks before go-livestatutory
Rule & evidence

Why: Invoices are tax-relevant; format and archiving change with the switch.

Legal basis: Since 1 Jan 2025 domestic businesses must be able to receive e-invoices; issuing obligation from 2027 above EUR 800,000 prior-year turnover, from 2028 generally for all (Sec. 14 UStG). Process documentation and archiving under GoBD.

Rule from the compliance library
GoBD and e-invoicing
Criteria
  • Process documentation for all tax-relevant systems and procedures
  • Complete and unalterable records, changes are logged
  • Retention of tax-relevant documents for the statutory period (generally 8 or 10 years)
  • Data access for tax audits possible (Sec. 147(6) German Fiscal Code)
  • Receipt of structured e-invoices (XRechnung, ZUGFeRD) since 1 Jan 2025
  • Issuing e-invoices to domestic businesses: from 2027 for prior-year turnover above EUR 800,000, from 2028 generally for all (exceptions incl. small-amount invoices, small businesses)

If breached: Formal defects can lead to the bookkeeping being rejected and the tax base being estimated (Sec. 162 German Fiscal Code); refusing data access can trigger a delay penalty (Sec. 146(2c)).

Evidence: In PathHub you tick off the criteria and attach evidence to each item as a file, link or note. Everything exports as a PDF evidence report.
Sign a data processing agreement with the e-invoicing or accounting service
Important 2–6 weeks before go-livestatutory
Rule & evidence

Why: Invoices contain personal data of contacts and sole traders.

Applies: if an external service or portal processes invoice data

Legal basis: GDPR Art. 28: contract before processing starts.

Rule from the compliance library
Cloud Contract Law
Criteria
  • Data Processing Agreement (DPA) with cloud provider
  • SLA with availability, RPO, RTO
  • Exit and portability clause
  • Data localisation and transfer mechanism (SCC / adequacy)

If breached: Civil claims for data loss; recourse depends on contract. GDPR fines for non-compliance.

Evidence: In PathHub you tick off the criteria and attach evidence to each item as a file, link or note. Everything exports as a PDF evidence report.
All typical initiatives and their obligations: planning internal projects

Frequently asked questions

How long does the switch to e-invoicing take?
In the example plan, the switch to e-invoicing takes 16 weeks in 7 phases. The actual duration depends on company size, starting point and available resources. With your company context PathHub adjusts the schedule accordingly.
What does the switch to e-invoicing cost?
The example plan estimates about €58,500, split into 21 budget line items with quantity and unit price. The largest items are ERP, Accounting & Interface Integration, Software & E-Invoicing Licences. This is an AI estimate as a starting point, not a quote.
What are the risks of the switch to e-invoicing?
The plan lists 6 risks with countermeasures. Rated highest: Incorrect Tax Data or Mandatory Invoice Fields; GDPR Article 28 DPA Not Executed Before Real-Data Processing; Incomplete RoPA Update or DPIA Necessity Assessment.
Who needs to be involved in the switch to e-invoicing?
Among others, the plan includes these people: Managing Director or Executive Sponsor, Head of Accounting, Accounts Payable and Accounts Receivable Representatives, IT/ERP Administrator, Tax and Compliance Lead or External Tax Adviser, Data Protection Officer or Privacy Counsel. For each role it states why and from when to involve them.
Can I adapt the plan to my company?
Yes. Open the plan in PathHub without signing up, adjust phases and tasks or describe your own initiative: with company context (departments, approval processes, works council, compliance requirements) every further plan gets more precise.

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