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Germany's e-invoicing mandate 2025–2028: who has to do what, and when?

With the Growth Opportunities Act (Wachstumschancengesetz), electronic invoices are gradually becoming mandatory for domestic business-to-business (B2B) transactions in Germany. Here are the deadlines, the exemptions and what you need to do.

Deadlines at a glance

What counts as an e-invoice?

Under German VAT law, an e-invoice is an invoice in a structured electronic format that complies with the European standard EN 16931 and allows automatic processing. In practice that means:

• XRechnung – a pure XML file, Germany's national standard (mandatory for invoices to public authorities).
• ZUGFeRD (version 2.0.1 or later) / Factur-X – a PDF with an embedded XML file. The MINIMUM and BASIC WL profiles do not qualify; BASIC, EN 16931 (COMFORT) and EXTENDED do.

A regular PDF, a scanned invoice or a Word document is not an e-invoice, even when sent by e-mail. See XRechnung vs. ZUGFeRD for the differences.

Receiving: mandatory since 1 January 2025

Since the start of 2025, every business in Germany must accept e-invoices – including small businesses under the Kleinunternehmer scheme, freelancers and landlords with VAT-able income. You cannot refuse an e-invoice from a supplier.

An e-mail inbox is enough to receive them. But you must also be able to read, check and archive them in their original format. An XRechnung is an XML file that looks like code in a browser. Our free e-invoice viewer turns it into a readable invoice in seconds – without uploading the file.

Retention: the XML file is the original and must be kept unchanged and machine-readable (8 years for accounting records). A printout or PDF copy is not sufficient.

Issuing: 2027 and 2028

• Until 31 December 2026, all businesses may still issue paper invoices and – with the recipient's consent – PDF invoices.
• During 2027, this only applies to businesses whose total turnover in 2026 was €800,000 or less.
• From 1 January 2028, all businesses must issue e-invoices to other domestic businesses.

The obligation only applies to transactions between businesses that are both established in Germany. Invoices to consumers (B2C) and to foreign customers are not affected.

Exemptions

• Small businesses (Kleinunternehmer, § 19 UStG) are permanently exempt from issuing e-invoices (§ 34a UStDV) – but must still be able to receive them.
• Small-amount invoices up to €250 gross may still be issued on paper or as PDF.
• Travel tickets are exempt.
• Certain VAT-exempt supplies under § 4 nos. 8–29 UStG (e.g. medical treatment, some rentals) are exempt.

What about foreign businesses?

The German mandate applies to businesses established in Germany. If you are based abroad and invoice German customers, you are not obliged to issue XRechnung or ZUGFeRD – but many German companies and all federal authorities increasingly expect structured e-invoices because their accounting processes are built around them. Sending a ZUGFeRD PDF keeps you on the safe side: it is a normal PDF for humans and a valid e-invoice for software.

Other EU countries are moving the same way: France is introducing mandatory e-invoicing based on Factur-X (technically identical to ZUGFeRD), and the EU's ViDA package will require e-invoicing for cross-border B2B sales from 2030.

Checklist

1. Receiving: set up a dedicated e-mail address for invoices and tell your suppliers.
2. Reading: keep a viewer for XRechnung and ZUGFeRD at hand – e.g. E-Rechnung Pilot (free).
3. Archiving: store the original XML files in an audit-proof way.
4. Issuing: choose a solution for writing e-invoices by the end of 2026 (turnover above €800,000) or 2027. If you only write a few invoices, you don't need expensive software – an online generator is enough.
5. Master data: collect your customers' e-mail addresses and, for public authorities, their Leitweg-ID.

Note: this article is a general overview and not tax advice. Based on the Growth Opportunities Act and the German Federal Ministry of Finance's guidance on e-invoicing. Last updated: September 2026.