Key takeaways
- Germany is moving toward mandatory e-invoicing, with full implementation planned between 2027 and 2028.
- From January 2025, all businesses must be able to receive e-invoices — even a standard email inbox qualifies for compliance.
- E-invoices must follow EN 16931 standards (structured or hybrid formats with readable PDFs).
- The mandate applies to domestic transactions between German-based businesses.
- Exemptions: tax-free services, invoices up to €250, and tickets.
- Non-resident companies without a German establishment are not affected.
- Once mandatory, input VAT deductions will only be possible with compliant electronic invoices.
In short: Germany's Ministry of Finance published draft guidance on the German e-invoicing mandate. From January 2025, businesses must be able to receive e-invoices, and an email inbox is enough. Issuing e-invoices becomes mandatory in phases between 2027 and 2028. The rules cover domestic transactions by businesses based in Germany.
Update (October 2026): The German Ministry of Finance published the final version of this guidance letter on October 15, 2024. It largely kept the content of the draft. Since January 1, 2025, businesses in Germany must be able to receive e-invoices. From January 1, 2027, businesses with turnover above €800,000 can no longer issue paper invoices. From January 1, 2028, the obligation extends to all businesses.
What does the German e-invoicing guidance say?
The German Ministry of Finance has published a draft letter with more guidance on the coming e-invoicing mandate. The main points are as follows:
The current rules do not yet include e-reporting, but it is expected later. By January 2025, businesses must be ready to receive electronic invoices. An email inbox is enough to comply. Other electronic channels can also be used if both parties agree.
Issuing electronic invoices will become mandatory in phases between 2027 and 2028. These invoices must use one of two formats. The first is a structured format that complies with EN 16931, or allows accurate and complete extraction under this standard.
The second is a hybrid format. It includes both structured data and a PDF that people can read.
Who must follow the German e-invoicing rules?
The German e-invoicing rule will apply to all domestic transactions. The exceptions are tax-free service invoices, invoices up to €250, and tickets. Only businesses based in Germany must follow the e-invoicing rules. Non-residents without a German office or residence are exempt.
Finally, once e-invoicing becomes mandatory, businesses can only claim input VAT deductions through electronic invoices.
Can businesses still send paper or PDF invoices during the transition?
Yes, until the issuing obligation applies to them. Every business must be able to receive e-invoices from January 1, 2025, but issuing is phased in.
- 2025 and 2026: paper invoices are still allowed. PDF and other non-structured electronic invoices need the recipient’s consent.
- 2027: businesses with previous-year turnover above €800,000 must issue B2B e-invoices. Smaller businesses can still send paper or PDF invoices.
- EDI: EDI invoices remain possible where the parties have a bilateral agreement.
These rules are summarised in the European Commission’s eInvoicing country sheet for Germany.
What are XRechnung and ZUGFeRD?
They are two common German e-invoice formats. XRechnung is a structured XML format used for invoices to public authorities. ZUGFeRD is a hybrid format: a PDF with an embedded XML file, so people and software can both read it.
What does this mean for businesses?
If your business is established in Germany and sells to other German businesses, plan in two steps: receiving now, issuing later.
- Receiving: make sure you can accept e-invoices in an EN 16931 format. An email address is enough, so you do not need a special mailbox.
- Issuing: check your turnover. Above €800,000, paper invoices stop from January 1, 2027. Every other business follows from January 1, 2028.
- Format: choose a structured or hybrid format that meets EN 16931, and check your invoicing software supports it.
- Input VAT: once the obligation applies, check that incoming invoices are valid e-invoices before you claim input VAT.
Foreign businesses without a German establishment are outside the mandate. They still need to follow normal German VAT invoicing rules, which our Germany VAT guide covers.
Key dates
- October 15, 2024: final guidance letter published by the German Ministry of Finance.
- January 1, 2025: all businesses in Germany must be able to receive e-invoices.
- January 1, 2027: businesses with turnover above €800,000 can no longer issue paper invoices.
- January 1, 2028: the obligation to issue e-invoices extends to all businesses.
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 32 countries from one integration. The VAT returns those invoices feed into are filed through CrossTax on the same platform.
Related guides
Frequently asked questions
1. When does e-invoicing become mandatory in Germany?
Mandatory issuance will be introduced in phases from 2027 to 2028. However, all businesses must be ready to receive e-invoices by January 1, 2025.
2. What formats are acceptable for e-invoices?
Invoices must comply with EN 16931 standards — either fully structured (machine-readable) or hybrid (structured data plus a human-readable PDF).
3. Can I receive e-invoices by email?
Yes. A simple email inbox is sufficient for receiving e-invoices under the 2025 readiness requirement.
4. Who must comply with the e-invoicing rules?
The mandate applies to businesses established in Germany for domestic B2B transactions.
5. Are there any exemptions?
Yes — tax-free service invoices, invoices up to €250, and tickets are excluded from the e-invoicing obligation.
6. Are foreign companies affected?
No. Non-resident businesses without a German office or permanent establishment are exempt from the mandate.
7. How does this impact VAT deductions?
Once e-invoicing becomes mandatory, businesses can only claim input VAT deductions through electronic invoices.
8. Which businesses must issue e-invoices from 2027?
From January 1, 2027, businesses with turnover above €800,000 can no longer issue paper invoices. From January 1, 2028, the obligation extends to all businesses in Germany.
9. Can I still send paper invoices in Germany in 2026?
Yes. Paper invoices remain allowed in 2025 and 2026. PDF invoices need the recipient’s consent, and every business must be able to receive e-invoices.
10. What is ZUGFeRD?
ZUGFeRD is a hybrid e-invoice format: a PDF with an embedded XML file. People can read the PDF, while software reads the XML data.
