Key takeaways
- Mandatory rollout began in 2025: All businesses in Germany must be able to receive structured e-invoices as of January 1, 2025, with full B2B issuance required by 2028.
- Only structured formats are accepted: Valid e-invoices must comply with EN 16931 and use formats like XRechnung or ZUGFeRD, not PDFs or Word files.
- Preparation is essential: Businesses need to update ERP systems, choose compliant transmission methods (e.g., Peppol or EDI), and ensure data accuracy for seamless electronic processing.
In short: E-invoicing in Germany is now mandatory for domestic B2B transactions. Since January 1, 2025, all businesses must be able to receive structured e-invoices. From 2027, businesses with turnover over €800,000 must issue them, and from 2028 all German-established businesses must. Valid e-invoices must meet EN 16931, for example XRechnung or ZUGFeRD.
Updated November 2026: The deadlines are unchanged. From 1 January 2027, businesses whose total turnover in 2026 exceeded €800,000 must issue e-invoices for domestic B2B sales, and all other businesses must do so from 1 January 2028 (Source).
Germany is changing how businesses issue and receive invoices. Since 2025, mandatory e-invoicing has been rolling out across domestic B2B transactions. This is part of a wider European push to modernize VAT compliance, improve efficiency and reduce fraud.
For businesses in Germany, this means preparing for structured electronic invoices. You also need to adapt your software and make sure invoice data can be processed electronically.
If your company issues or receives invoices in Germany, you need to understand the new rules. This guide covers the core concepts, deadlines, accepted formats and more.
Why is Germany mandating e-invoicing?
Germany is mandating e-invoicing to reduce tax evasion and make business processes faster and more accurate. The German government passed the Growth Opportunities Act (Wachstumschancengesetz) in 2024. It introduced a phased rollout of e-invoicing for domestic B2B transactions. We cover this in more detail in E-Invoicing Updates: Germany and France.
The reform aligns German tax policy with the EU’s VAT in the Digital Age (ViDA) initiative. ViDA is a broad effort to standardize VAT rules and increase transparency across member states.
E-invoices also give businesses tools for automation and better data accuracy. ERP systems can process structured invoices directly. This removes many of the problems that come with paper or PDF invoices.
What are the key dates for mandatory e-invoicing in Germany?
Mandatory e-invoicing in Germany is being introduced in three phases between 2025 and 2028. This gives businesses time to adapt:
- January 1 2025: All businesses must be able to receive structured e-invoices. Until 31 December 2026, any business may still issue paper invoices, or PDFs and other electronic invoices if the buyer agrees.
- January 1 2027: Businesses with an annual turnover over €800,000 must issue structured e-invoices.
- January 1 2028: E-invoicing becomes mandatory for all German-established businesses in B2B transactions.
Note: These rules only apply to domestic B2B transactions for now. B2C and cross-border invoicing are not affected yet, though changes are expected later.
What exactly do the transitional rules allow?
The transitional rules let businesses keep sending non-structured invoices for a limited time. They are set out in section 27(38) of the German VAT Act (UStG):
- Supplies made in 2025 and 2026: any business may issue a paper invoice, or another electronic invoice such as a PDF if the buyer agrees. Source: § 27(38) no. 1 UStG.
- Supplies made in 2027, smaller businesses: the same options remain if the supplier's total turnover in the previous calendar year was €800,000 or less. Source: § 27(38) no. 2 UStG.
- Supplies made in 2027, EDI users: invoices sent by electronic data interchange (EDI) in a non-EN 16931 format stay valid until 31 December 2027. This needs the buyer's agreement and applies regardless of turnover. Source: § 27(38) no. 3 UStG.
- Supplies made from 1 January 2028: no transitional option is left. Every domestic B2B invoice must be a structured e-invoice unless an exemption applies.
Worked example: a German wholesaler had €1.2 million total turnover in 2026. From 1 January 2027 it must send e-invoices to its German business customers. A supplier with €500,000 turnover in 2026 may still send PDFs, with consent, until the end of 2027.
Which invoices are exempt from the e-invoicing mandate?
Some invoices may still be issued on paper or as PDFs after the transition ends. The BMF letter of 15 October 2025 lists these cases:
- Small invoices: invoices with a total amount up to €250. Above €250, an e-invoice is required.
- Passenger tickets: treated the same way as small invoices.
- Small businesses (Kleinunternehmer): invoices from businesses using the small business scheme are treated the same way.
- B2C sales: invoices to private consumers are outside the mandate. An e-invoice to a consumer needs their consent.
- Cross-border sales: the mandate applies only when both supplier and customer are established in Germany.
What qualifies as an e-invoice?
An e-invoice in Germany is an invoice in a structured electronic format that systems can process automatically. It is more than just a digital document. An e-invoice must:
- Be issued, transmitted and received in a structured electronic format.
- Comply with the EU standard EN 16931, which defines the essential content and layout of invoice data.
- Allow the full invoice lifecycle to be automated, from issuance to validation and archiving, with no manual steps.
This means Word documents or simple PDFs no longer meet the legal definition of an e-invoice, even when sent by email. Instead, Germany requires machine-readable, XML-based formats. These let systems read and process the data directly.
Which e-invoice formats are accepted in Germany?
Germany accepts any e-invoice format that complies with EN 16931, such as XRechnung and ZUGFeRD. The approach is technology-neutral but format-specific. You have some flexibility, as long as you use an accepted standard. The main formats include:
- XRechnung, a structured XML format developed for the German public sector. It’s already mandatory for B2G (business-to-government) invoices. It's expected to play a key role in the B2B rollout too.
- ZUGFeRD, a hybrid format that combines a human-readable PDF/A-3 with an embedded XML data file. People can read it, and systems can process it. Current versions of ZUGFeRD are fully EN 16931-compliant.
- Factur-X, the French equivalent of ZUGFeRD. It works with German standards and is widely used in cross-border invoicing.
- Other structured XML formats, such as UBL or Peppol BIS Billing 3.0. These are allowed if both sender and receiver agree to use them and they meet the required content standard.
These formats enable electronic data interchange (EDI). Accounting systems can talk to each other smoothly while meeting legal and audit requirements.
Does every ZUGFeRD file or PDF count as an e-invoice?
No. A plain PDF is never an e-invoice, and not every ZUGFeRD file qualifies either. The BMF letter of 15 October 2025 sets these rules:
- XRechnung: meets the EN 16931 standard and is always accepted.
- ZUGFeRD: accepted from version 2.0.1, except the MINIMUM and BASIC-WL profiles.
- Other EN 16931 formats: accepted without a special agreement.
- Agreed formats such as EDI: allowed if all VAT-relevant data can be extracted into an EN 16931-compliant format without loss of information.
- Hybrid invoices: if the XML data and the PDF image differ, the XML data prevails.
- Format errors: a file that does not meet the technical specification is not an e-invoice. It is treated as another electronic invoice.
The same rules apply to credit notes issued by the buyer (self-billing). Mandatory VAT details must be in the structured data, not only in an attached PDF.
How will invoices be transmitted?
German e-invoices can be sent in several ways, depending on the format and what trading partners agree. Traditional electronic data interchange is still an option, as long as the content meets the EN 16931 standard.
Businesses can also use the Peppol network, an EU-backed network for the secure, standard exchange of electronic documents. Peppol is already used for B2G transactions in many EU countries. It offers a scalable way to handle both cross-border and domestic invoicing.
You can also use third-party service providers or e-invoicing platforms. They can create, send and receive e-invoices for you. They can also help convert old PDFs into structured formats during the transition and offer compliance and archiving tools.
What do you need to receive and store e-invoices?
To receive e-invoices, a normal email inbox is enough. The BMF confirms that no separate inbox just for e-invoices is needed.
For storage, you must keep at least the structured part of each e-invoice in its original form. The tax authorities must be able to evaluate it by machine. Keeping only a printout or the PDF view is not enough. For Germany's wider VAT rules, see our VAT in Germany guide.
How can you prepare your business for mandatory e-invoicing?
To prepare for e-invoicing in Germany, check your systems, choose a transmission method and train your team. The change touches finance, IT, legal and compliance teams. To get ready:
- Review your ERP or accounting system. Can it export invoices in XRechnung or ZUGFeRD format?
- Make sure you can receive and import structured e-invoices automatically. This is mandatory as of 2025.
- Decide whether direct EDI, Peppol or a third-party provider suits your invoice flows best.
- Train your staff on the new formats, validation steps and how to handle exceptions.
- Set up secure e-archiving that meets Germany’s GoBD rules on data integrity, retention and auditability.
- Clean up your master data. Customer information, VAT IDs and product details must be accurate to avoid validation errors.
If you send a lot of invoices, investing early in automation will pay off quickly. Once invoices flow straight into your system with no manual steps, you'll cut delays, errors and reconciliation issues.
What about the electronic reporting system?
Germany has not yet rolled out a full electronic reporting system, but one is expected in the future. The current e-invoicing mandate is seen as a first step toward real-time invoice reporting to the tax authorities. Countries like Italy and France already have similar rules. For a closer look, see VAT Data Automation for CTC and E-Invoicing: Near-Real-Time Reporting.
Building e-invoicing capabilities now will make it much easier to comply with future e-reporting rules. See how Taxually e-invoicing connects to each country's tax authority through one API.
Conclusion
Germany’s move to mandatory e-invoicing is more than a compliance update. It’s a shift toward faster, more efficient business processes. Structured electronic invoices help you cut manual work, improve accuracy and prepare for future rules like real-time reporting. Related reading: E-Invoicing Belgium: Everything You Need to Know.
Updating your invoicing systems now will keep you compliant. It will also set your company up for long-term digital success in the German market.
Do you need help with your VAT compliance? Book a free call with one of our VAT experts to find bespoke solutions for your business, optimize your VAT costs, and reach millions of new potential customers with our automated VAT solutions.
How Taxually handles this
Taxually’s e-invoicing API sends structured invoices to each country’s clearance platform, such as Italy’s SDI, Poland’s KSeF and Peppol networks, covering 39 countries from one integration. The VAT returns those invoices feed into are filed through CrossTax on the same platform.
Related guides
Frequently asked questions
Who is affected by the e-invoicing mandate in Germany?
All businesses established in Germany that issue or receive B2B domestic invoices will be affected, with requirements phased in from 2025 to 2028.
What formats are accepted for e-invoices?
Accepted formats include XRechnung, ZUGFeRD from version 2.0.1 (except the MINIMUM and BASIC-WL profiles), Factur-X, and other EN 16931-compliant formats. Other formats such as EDI are allowed by agreement if the data can be converted to EN 16931 without loss.
When do I need to start issuing e-invoices?
- From 2025, you must be able to receive e-invoices.
- From 2027, if your total turnover in the previous calendar year exceeded €800,000, you must issue them.
- From 2028, issuing becomes mandatory for all domestic B2B transactions.
Is cross-border or B2C invoicing included?
Not yet. The current mandate applies only to domestic B2B transactions, but expansion to other areas is likely in the future.
What is the purpose of the mandate?
The goal is to modernize VAT reporting, reduce fraud, improve efficiency, and prepare for real-time electronic reporting to tax authorities.
Can I still send PDF invoices in Germany?
Yes, for a limited time. Until 31 December 2026 any business may send PDF invoices with the buyer's consent. In 2027 only businesses with previous-year turnover of €800,000 or less may do so, and from 2028 PDFs are no longer valid for domestic B2B invoices unless an exemption applies.
Are small invoices exempt from e-invoicing in Germany?
Yes. Invoices with a total amount up to €250 and passenger tickets may still be issued on paper or as other electronic invoices. Invoices from businesses using the small business scheme (Kleinunternehmer) are also exempt.
