Germany's E-Invoicing Mandate 2025–2028: What Foreign and Local Businesses Need to Know

Germany is moving business-to-business (B2B) invoicing to structured electronic invoices in stages. Since 1 January 2025, businesses established in Germany must be able to receive e-invoices. Between 2027 and 2028, they will also have to issue them. This guide explains the timeline, who is in scope, which formats are accepted and what the rules mean if your company is based outside Germany or you run a business in Germany as an expat.

The mandate at a glance

• Since 1 January 2025: every business established in Germany must be able to receive and store e-invoices from other domestic businesses.
• Until 31 December 2026: suppliers may still issue paper or PDF invoices for domestic B2B supplies. PDF and other electronic formats need the recipient's consent.
• During 2027: paper and PDF invoices remain allowed only for suppliers whose total turnover in the previous year (2026) was €800,000 or less.
• From 1 January 2028: all domestic B2B invoices in scope must be issued as e-invoices.

The legal basis is § 14 of the German VAT Act (Umsatzsteuergesetz, UStG), as amended by the Growth Opportunities Act (Wachstumschancengesetz). The Federal Ministry of Finance (BMF) has explained the details in two official guidance letters, dated 15 October 2024 and 15 October 2025.

What counts as an e-invoice in Germany?

Under German VAT law, an e-invoice is an invoice issued, transmitted and received in a structured electronic format that allows automatic processing. The format must comply with the European standard EN 16931. A PDF, a scanned paper invoice or a picture of an invoice is not an e-invoice, even if you send it by email. In German law, these are called "other invoices" (sonstige Rechnungen).

All mandatory invoice details must be in the structured data. For hybrid formats such as ZUGFeRD, only the embedded XML counts for tax purposes; the visible PDF is just a readable copy.

Who is in scope?

The mandate applies to domestic B2B supplies: the supplier and the customer must both be businesses established in Germany. A business is generally established in Germany if it has its registered office, its place of management or a fixed establishment (Betriebsstätte) in Germany that is involved in the supply, or, for sole traders, its residence there.

Being registered for VAT in Germany is not the same as being established there. A foreign company that only has a German VAT number, for example because it holds stock in a German warehouse, is generally not treated as established in Germany for the e-invoicing rules. The BMF guidance also says that, as a supplier, you may rely on information from your customer, for example the VAT identification number they give you.

Invoices to private consumers (B2C) are not covered. Invoices to public authorities follow separate rules, explained below.

What the mandate means for foreign businesses

You sell to customers in Germany

If your company is not established in Germany, the German obligation to issue e-invoices does not apply to you, even when your customer is a German business. You may continue to invoice according to the rules that apply to your supply, for example as a PDF.

In practice, however, many German customers are automating their accounts payable around XRechnung and ZUGFeRD. Some will ask you to send a structured invoice because it is faster to process. Sending a ZUGFeRD or XRechnung file voluntarily can make it easier to get paid on time. The differences between the two formats are explained in our guide XRechnung vs ZUGFeRD.

You have a German subsidiary or fixed establishment

A German subsidiary is a German business. It must receive e-invoices now and issue them according to the timeline above. The same can apply to a fixed establishment in Germany that makes or receives the supply. Check with your tax adviser how your structure is treated.

You receive e-invoices from German suppliers

German suppliers are not required to send you an e-invoice if you are established abroad. Some still do, because their invoicing system creates XRechnung or ZUGFeRD files by default. If you receive an XML file you cannot read, our guide How to open and read an XRechnung explains your options.

Which invoices are exempt?

Even between two German businesses, some invoices do not have to be e-invoices:

• Small-value invoices with a gross total of up to €250.
• Tickets that serve as invoices, for example for passenger transport.
• Certain VAT-exempt supplies under § 4 Nr. 8 to 29 UStG, such as many financial, insurance and medical services.
• Invoices from businesses that use the Kleinunternehmer scheme (the small business exemption under § 19 UStG).

These exemptions only cover issuing. Every business established in Germany, including small businesses using the Kleinunternehmer scheme, must still be able to receive e-invoices.

Accepted formats

• XRechnung: the German XML implementation of EN 16931 and the standard for invoices to public authorities.
• ZUGFeRD 2.0.1 or later: a hybrid PDF with embedded XML. All profiles except MINIMUM and BASIC-WL qualify, because those two do not contain all the data an invoice needs.
• Factur-X: the French–German equivalent of ZUGFeRD, technically aligned with it.
• Other formats: other EN 16931-compliant formats, and by agreement between the parties, formats such as EDI, as long as the required data can be extracted correctly.

If you want to see what these files look like inside, read our German e-invoice example with the XML explained.

Receiving e-invoices: what you need

According to the BMF, an email inbox is enough as a minimum to receive e-invoices. You also need a way to read the structured file, check it and store it. Because an XRechnung is a pure XML file, it is hard to read without a tool. Our free XRechnung viewer shows the invoice in a readable layout, and the free XRechnung validator checks a file against the standard. Neither requires an account.

Storage and retention

You must keep e-invoices in their original structured format; a printout is not enough. Since 2025, the retention period for invoices as accounting records in Germany is eight years. The 2025 BMF letter states that, for VAT purposes, storing the unchanged structured part is sufficient. Your storage should also meet the German bookkeeping principles known as GoBD; ask your tax adviser how this applies to your systems.

Invoicing German public authorities (B2G)

Separate rules apply to invoices sent to the public sector. Suppliers to federal authorities have generally had to send e-invoices since 27 November 2020, under the federal E-Invoicing Ordinance (E-Rechnungsverordnung). In practice this means XRechnung, sent through the federal invoice portals and including the Leitweg-ID, the routing number that identifies the receiving authority. The federal states and municipalities have their own rules, so check the requirements in your contract. These B2G rules can also apply to foreign suppliers.

What happens if an invoice does not meet the rules?

Once the transition period has ended for you, an invoice in the wrong format is not a correct invoice under German VAT law. According to the 2025 BMF letter, if the file does not meet the EN 16931 syntax, it is not an e-invoice, and your customer may lose the right to deduct input VAT. Customers will therefore usually reject such invoices and ask for a correct one, which can delay payment.

Looking ahead: the EU's ViDA package

Germany's mandate is part of a wider European development. In March 2025, the EU adopted the VAT in the Digital Age (ViDA) package. Among other things, it allows member states to introduce domestic e-invoicing mandates without special approval and plans e-invoicing with digital reporting for intra-EU B2B transactions from July 2030. If you trade across several EU countries, it makes sense to choose processes and tools based on EN 16931 now.

How to prepare

1. Check whether you are established in Germany and whether your customers are.
2. Make sure you can receive, read and store XRechnung and ZUGFeRD files.
3. Find out which date applies to you for issuing: 2027 or 2028, based on your previous year's turnover.
4. Choose a format with your customers and set up software that creates EN 16931-compliant invoices.
5. Review your archiving with your tax adviser.

XRechnungs.de is a web app that creates, converts and validates XRechnung, ZUGFeRD and Factur-X invoices, with hosting in the EU. If you still create invoices as PDFs, the PDF to XRechnung/ZUGFeRD converter turns them into structured e-invoices; our guide on converting a PDF invoice to ZUGFeRD or XRechnung explains how this works.

Frequently asked questions

Is e-invoicing mandatory in Germany?

Partly. Since 1 January 2025, businesses established in Germany must be able to receive e-invoices. The obligation to issue them applies from 2027 to businesses with previous-year turnover above €800,000 and from 1 January 2028 to all businesses in scope.

Do foreign companies have to send e-invoices to German customers?

No. The German B2B mandate only applies when both the supplier and the customer are established in Germany. A foreign supplier without a German establishment may still send an e-invoice voluntarily, and some German customers prefer it.

Does a German VAT number make my company subject to the mandate?

Generally not. Being registered for VAT in Germany is not the same as being established there. What matters is a registered office, place of management or fixed establishment in Germany. Ask your tax adviser if you are unsure.

Is a PDF invoice an e-invoice?

No. A PDF has no structured data that can be processed automatically. It is allowed for domestic B2B invoices only during the transition period, and only with the recipient's consent.

Which formats are accepted?

Formats that comply with EN 16931, in particular XRechnung and ZUGFeRD from version 2.0.1 (except the MINIMUM and BASIC-WL profiles), as well as Factur-X. Other formats such as EDI are possible by agreement if the required data can be extracted correctly.

Do small businesses have to issue e-invoices?

Businesses using the Kleinunternehmer scheme under § 19 UStG do not have to issue e-invoices. Like all businesses established in Germany, they must still be able to receive them.

How long must e-invoices be kept?

Invoices must generally be kept for eight years in Germany, and e-invoices must be kept in their original structured format.

Next step

Whether you must issue e-invoices yourself or simply want to make life easier for your German customers, it pays to start early. You can try XRechnungs.de free for 14 days, with up to 50 documents and no credit card required. Plans and limits are listed on the pricing page. This guide is general information, not tax advice.