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.
The German Ministry of Finance has published a draft letter offering further guidance on the forthcoming e-invoicing mandate. The main points covered are as follows:
While the existing requirements do not yet include e-reporting, this is expected to be introduced at a later stage. Also, by January 2025, businesses must be prepared to receive electronic invoices, with an email inbox being a sufficient method for compliance. However, other electronic transmission channels can also be used by mutual agreement.
The issuance of electronic invoices will become mandatory in phases between 2027 to 2028. These invoices must be in either a structured format, which complies with EN 16931 or allows for accurate and complete extraction according to this standard, or a hybrid format that includes both structured data and a human-readable PDF.
The e-invoicing requirement will apply to all domestic transactions, with exceptions for tax-free service invoices, invoices up to €250, and tickets. Only businesses based in Germany will be subject to e-invoicing requirements. Non-residents without a German office or residence are exempt.
Finally, businesses will only be able to claim input VAT deductions through electronic invoices once e-invoicing becomes mandatory.
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-invo
