# E-invoicing in Germany: who must comply and when

> Since 1 January 2025, every business established in Germany must be able to receive e-invoices. From 1 January 2027, businesses with more than €800,000 turnover in the previous year must issue them to other German businesses, and from 1 January 2028 almost everyone must. Invoices up to €250, travel tickets and invoices from small businesses stay exempt.

- URL: https://billfree.de/en/e-invoicing/e-invoicing-germany/
- Language: en
- Updated: 2026-10-19
- Publisher: Billfree (OnlineBuilders LLC, https://onlinebuilders.biz)

Germany switched to mandatory e-invoicing in steps, and many small firms have treated it as a problem for later. That worked so far, because almost anything stays allowed until the end of 2026. On 1 January 2027 the field splits. Businesses with more than €800,000 turnover in the previous year must send structured invoices to their German business customers. One year later, nearly everyone must.

## The timeline

The legal basis is the Growth Opportunities Act of 2024. The transition rules are in [§ 27(38) UStG](https://www.gesetze-im-internet.de/ustg_1980/__27.html).

**Mandatory e-invoicing between businesses in Germany**

- **1 Jan 2025:** All businesses must be able to **receive** e-invoices. Issuing on paper, or as PDF with the customer's consent, remains allowed.
- **31 Dec 2026:** End of the general transition. Paper or PDF for services in 2025 and 2026 must be **sent** by this date.
- **1 Jan 2027:** Issuing becomes mandatory for businesses with more than **€800,000** prior-year turnover. Smaller ones may still use paper or PDF.
- **31 Dec 2027:** Last sending date for paper, PDF and non-compliant EDI for services in 2027 (PDF and EDI only with consent).
- **1 Jan 2028:** E-invoices for all domestic B2B transactions, apart from the statutory exemptions.

Source: § 14(1) and (2), § 27(38) UStG

The law has a detail that is easy to miss. Each transition rule has two conditions: the service must fall into a certain period, and the invoice must be sent by a certain date. For services in 2025 and 2026, that date is 31 December 2026. If you deliver on 18 December 2026 and send a PDF invoice in January 2027, the wording of the first rule no longer covers you. The second rule, for smaller businesses, only covers services from 2027 onwards. Send your 2026 invoices in 2026, especially in December.

## Who is affected

The mandate applies when both supplier and customer are businesses established in Germany and the customer buys for their business. Industry, legal form and invoice size do not matter, except for three exemptions:

- small amount invoices up to €250 gross, see [small amount invoice](https://billfree.de/en/mandatory-details/small-amount-invoice-germany/)
- travel tickets
- invoices from small businesses under § 19 UStG, see [Kleinunternehmer invoice](https://billfree.de/en/mandatory-details/kleinunternehmer-invoice/)

Invoices to private customers and to customers abroad are not affected. Neither are foreign companies that are only registered for German VAT without being established in Germany. Take a UK software firm selling to German clients: it keeps invoicing as before, under its own rules.

Public authorities are a separate case. Suppliers to German federal authorities have been sending e-invoices since November 2020, usually through the portals ZRE or OZG-RE and with a routing ID (Leitweg-ID) from the buyer. That regime runs in parallel.

## Worked example: does 2027 apply to me?

Two invented businesses. One is a furniture workshop with eight staff and €740,000 turnover in 2026. The other is an electrical wholesaler with €1.2 million.

The workshop may keep sending paper invoices to business customers in 2027, or PDFs if the customer agrees. It needs e-invoices for services from 1 January 2028. The wholesaler must issue structured invoices from the first working day of 2027, to every electrician and engineering office among its customers.

What counts is total turnover as defined in § 19(2) UStG, not profit and not just B2B sales. Being just under €800,000 buys you one year. That is all.

Associations and foundations can be affected too, to the extent they act as businesses, for example by renting out a clubhouse. What counts is always whether supplier and customer act as businesses.

## What counts as an e-invoice

An invoice issued, sent and received in a structured electronic format that complies with the European standard EN 16931. Germany effectively uses two: XRechnung, a pure XML file, and ZUGFeRD, a PDF with embedded XML. For ZUGFeRD, the Finance Ministry accepts every profile from version 2.0.1 except MINIMUM and BASIC-WL. For everyday use, the EN 16931 profile (formerly COMFORT) is the one you can rely on. The differences are explained in [XRechnung vs ZUGFeRD](https://billfree.de/en/e-invoicing/xrechnung-vs-zugferd/).

Exported Word PDFs are not e-invoices. Scans are not either. Both are „other invoices“ and will not be allowed for domestic B2B transactions from 2028.

## What happens to faulty e-invoices

The Finance Ministry's second guidance letter on e-invoicing, dated 15 October 2025, distinguishes three kinds of errors. Format errors break the technical specification. Business rule errors violate the standard's logical checks. Content errors are wrong information, such as a wrong VAT rate.

During the transition, an e-invoice with a format error still counts as an „other invoice“, and the customer can deduct input VAT as long as the mandatory details are correct. Once the supplier is subject to the mandate, that safety net disappears. Anyone receiving e-invoices from 2027 or 2028 should validate them automatically and keep the validation report.

## Three common misunderstandings

„We need Peppol.“ No. German law does not prescribe how the file travels. Email with the XML attached is enough. Peppol is a network some large customers use, and you can join it, but nobody can force you to.

„From 2025, every invoice must be an e-invoice.“ Also no. The years 2025 and 2026 are only about receiving. Sending a PDF until the end of 2026 is perfectly legal, as long as the customer agrees to PDFs.

„This applies to my clients abroad too.“ Not under German law. The mandate covers only transactions between businesses that are both established in Germany. Other EU countries have their own plans, and the EU reform package known as ViDA will eventually bring e-invoicing to cross-border trade within the EU as well. That is a separate timetable.

## Will it be postponed?

The German Confederation of Skilled Crafts (ZDH) called in June 2026 for the 2027 stage to be pushed back to 2028. Its reasoning: many e-invoices in circulation do not fully meet the standard, and smaller firms struggle with receiving them. Nothing has been decided, and the law is unchanged as of October 2026. Any postponement would only give businesses above €800,000 one more year. The 2028 stage would stay. Switching now costs you nothing either way.

## What to do now

**Getting ready to issue e-invoices**

- [ ] Check your 2026 turnover: above or below **€800,000**?
- [ ] Ask your invoicing software whether it creates XRechnung or ZUGFeRD in the EN 16931 profile
- [ ] Filter your customer list for German business customers
- [ ] Ask each business customer for their e-invoice address
- [ ] Create a test invoice and run it through a validator
- [ ] Set up storage for XML files, kept for eight years
- [ ] Inbox side: a dedicated mailbox for incoming e-invoices and a review routine

Mainstream invoicing and bookkeeping tools already include most of this, you just have to switch it on. It gets harder when invoices come from your own software, an online shop or an industry tool. Then someone has to build the XML export and map it to the standard. [OnlineBuilders](https://onlinebuilders.biz/solutions/saas) develops billing and e-invoicing features for that kind of platform.

Receiving is the half nobody escapes. How to handle it without new software is covered in [receive e-invoices in Germany](https://billfree.de/en/e-invoicing/receive-e-invoices-germany/). For storage, the XML is the original, as the article on [how long to keep invoices](https://billfree.de/en/e-invoicing/keep-invoices-germany/) explains.

Not sure whether a particular customer already needs an e-invoice? The [invoice checker](https://billfree.de/en/invoice-checker/) tells you after you tick the boxes.

## FAQ

### Is a PDF invoice an e-invoice in Germany?

No. German law defines an e-invoice as structured data that follows the European standard EN 16931, such as XRechnung or ZUGFeRD from the BASIC profile up. A PDF is an „other invoice“, even when sent by email.

### Does the mandate apply to foreign companies selling to Germany?

Only if both supplier and customer are established in Germany. A company based in Austria or the UK that is merely registered for German VAT is not obliged to issue e-invoices under the German rule.

### Do I need Peppol?

No. German law does not prescribe a transmission channel. Emailing the XML file is enough. Peppol is one network some large companies use, but it is not mandatory in Germany.

### Will the 2027 deadline be postponed?

The German Confederation of Skilled Crafts called for the 2027 stage to be pushed back a year in June 2026. As of October 2026, the law has not changed. Plan with the current dates.

Photo: Håkan Dahlström from Malmö, Sweden, CC BY 2.0 (https://commons.wikimedia.org/wiki/File:My_view_090909,09_09_(3902571235).jpg)