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

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.

Obligations between businesses established in Germany, by date of supply
Supply made inReceivingIssuingProvision
2025 and 2026mandatory for alle-invoice, or still paper; another electronic format such as PDF with the customer's consent§ 27(38) no. 1 UStG
2027mandatory for alle-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 2028mandatory for alle-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:

What foreign suppliers need to know

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).

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

  1. Growth Opportunities Act (Wachstumschancengesetz) of 27 March 2024 Federal Law Gazette 2024 I no. 108, in German
  2. § 14 UStG (German VAT Act), issuing invoices in German
  3. § 27 UStG, transitional rules, paragraph 38 in German
  4. § 14b UStG, keeping invoices in German
  5. § 19 UStG, small businesses in German
  6. §§ 33, 34 and 34a UStDV, small-amount invoices, tickets and small businesses in German
  7. Federal Ministry of Finance, circular of 15 October 2025 on mandatory e-invoicing in German; revises the circular of 15 October 2024
  8. E-Invoicing Ordinance of the Federation (ERechV) in German

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