E-invoicing guide
Germany's e-invoicing mandate: what applies since 2025, and what comes in 2027 and 2028
Since 1 January 2025 businesses in Germany must be able to receive e-invoices. Issuing them becomes mandatory after transition periods that end in 2028. This guide explains who is affected, the deadlines and the exceptions, each with the provision behind it.
In short
- Receiving: since 1 January 2025 every business established in Germany must be able to receive e-invoices, small businesses included. An email inbox is enough.
- Issuing: invoices between businesses that are both established in Germany must in principle be e-invoices (section 14(2) sentence 2 no. 1 UStG).
- Transition: for supplies in 2025 and 2026, paper and, with the customer's consent, other electronic formats such as a PDF are still allowed. For supplies in 2027 this applies only if the supplier's total turnover in the previous year was at most EUR 800,000. From supplies on 1 January 2028 the transition ends (section 27(38) UStG).
- Exceptions: invoices up to EUR 250, tickets and invoices from small businesses may always be sent on paper or as a PDF.
- Format: an e-invoice is structured and machine-readable, such as XRechnung or a ZUGFeRD PDF from version 2.0.1. An ordinary PDF is not an e-invoice.
The timeline: 2025, 2027, 2028
The obligation comes from the Growth Opportunities Act of 27 March 2024, which rewrote section 14 of the German VAT Act (UStG) and set transitional rules in section 27(38). What counts is when the supply was made.
| Supply made in | Receiving | Issuing | Provision |
|---|---|---|---|
| 2025 and 2026 | mandatory for all | e-invoice, or still paper; another electronic format such as PDF with the customer's consent | § 27(38) no. 1 UStG |
| 2027 | mandatory for all | e-invoice; paper or PDF only if the previous year's total turnover was at most EUR 800,000; EDI with consent | § 27(38) nos. 2 and 3 UStG |
| from 2028 | mandatory for all | e-invoice, except in the exempted cases | § 14(2) sentence 2 no. 1 UStG |
To use a transitional rule, the invoice has to be sent by the end of the respective period: by 31 December 2026 for supplies in 2025 and 2026, by 31 December 2027 for supplies in 2027. There was no transition for receiving.
Who is affected
The obligation covers invoices for supplies to another business for its business, when both the supplier and the customer are established in Germany (section 14(2) sentence 2 no. 1 UStG). Established means having the seat, the management or a fixed establishment involved in the supply there.
According to the Federal Ministry of Finance, it does not matter whether the customer is a small business or makes only VAT-exempt supplies, such as a landlord (circular of 15 October 2025). Not affected are:
- Invoices to consumers. Paper and PDF remain fine.
- Cross-border invoices. If either business is not established in Germany, the obligation does not apply.
- VAT-exempt supplies under section 4 nos. 8 to 29 UStG, such as many medical services and lettings, for which there is no obligation to issue an invoice at all.
What foreign suppliers need to know
- No B2B obligation without a German establishment. A supplier that has no seat, management or involved fixed establishment in Germany does not fall under the mandate, even when invoicing German customers. Customers may still ask for XRechnung or ZUGFeRD, and their accounting software may prefer it.
- Public authorities are different. The federal E-Invoicing Ordinance requires suppliers to invoice federal contracting authorities electronically since 27 November 2020, usually as XRechnung and always with the authority's Leitweg-ID (sections 3 to 5 ERechV). Direct orders up to EUR 1,000 are exempt. The federal states have their own rules.
- Formats are European. XRechnung and ZUGFeRD implement EN 16931, the same standard behind Factur-X in France and Peppol BIS Billing. A ZUGFeRD invoice in the EN 16931 profile is technically a Factur-X invoice.
Receiving: what every business in Germany must manage since 2025
Businesses must be technically able to receive e-invoices. An email inbox is enough; a separate one only for e-invoices is not required. A business that cannot or will not accept an e-invoice has no right to a paper invoice instead (circular of 15 October 2025).
- Reading: an XRechnung is an XML file that is hard to read without a viewer. The free e-invoice viewer shows it as an invoice in the browser (interface in German).
- Checking: the recipient still has to check an invoice for correctness. A validation helps and does not replace that; the recipient may rely on the technical result of a suitable validation and should keep the report.
- Keeping: invoices are kept for eight years (section 14b(1) UStG). For an e-invoice, at least its structured part must be kept intact in its original form; a printout is not enough.
In a ZUGFeRD invoice the XML leads: where the structured data and the visible PDF differ, the structured data prevails.
Exceptions and small businesses
Three kinds of invoices may always be sent as an "other invoice", on paper or as an ordinary PDF, even after 2027: invoices with a total of up to EUR 250 (section 33 UStDV), tickets (section 34 UStDV) and invoices from small businesses under section 19 UStG (section 34a UStDV).
A small business in this sense had a total turnover of at most EUR 25,000 in the previous year and does not exceed EUR 100,000 in the current year (section 19(1) UStG). It never has to issue e-invoices, but it has to be able to receive them since 1 January 2025.
Frequently asked questions
When does the e-invoicing mandate start in Germany?
Receiving has been mandatory since 1 January 2025. Issuing becomes mandatory for supplies from 1 January 2027 for businesses with more than EUR 800,000 total turnover in the previous year, and for supplies from 1 January 2028 for everyone else (section 27(38) UStG).
Does the mandate apply to foreign companies?
Only if they are established in Germany. The obligation applies when both supplier and business customer have their seat, management or an involved fixed establishment in Germany.
Is a PDF invoice by email still allowed?
For supplies in 2025 and 2026, yes, with the customer's consent. For supplies in 2027 only for businesses with at most EUR 800,000 turnover in the previous year, and not from 2028. Invoices up to EUR 250, tickets and invoices from small businesses are exempt.
Which formats count as an e-invoice?
Structured formats that follow EN 16931, such as XRechnung and ZUGFeRD from version 2.0.1 except the profiles MINIMUM and BASIC WL, or a format agreed between the parties that allows the required data to be extracted.
Sources
- Growth Opportunities Act (Wachstumschancengesetz) of 27 March 2024 Federal Law Gazette 2024 I no. 108, in German
- § 14 UStG (German VAT Act), issuing invoices in German
- § 27 UStG, transitional rules, paragraph 38 in German
- § 14b UStG, keeping invoices in German
- § 19 UStG, small businesses in German
- §§ 33, 34 and 34a UStDV, small-amount invoices, tickets and small businesses in German
- Federal Ministry of Finance, circular of 15 October 2025 on mandatory e-invoicing in German; revises the circular of 15 October 2024
- E-Invoicing Ordinance of the Federation (ERechV) in German
Tools for the job
- E-invoicing in Germany the tools and a glossary of their German terms
- XRechnung or ZUGFeRD? the two formats compared
- Create an e-invoice XRechnung and ZUGFeRD in the browser (in German)
- View an e-invoice read an incoming XRechnung (in German)