E-Invoicing for Freelancers in Germany: What You Need to Know (2026)

Freelancers established in Germany have had to be able to receive e-invoices since 1 January 2025. They must issue e-invoices to German business clients from 1 January 2028 at the latest. With 2026 total turnover of €800,000 or less, paper invoices, or PDFs with consent, remain allowed in 2027. Small businesses (Kleinunternehmer, § 19 UStG) and private clients are exempt.

Last reviewed: September 2026. This article is general information, not tax advice.

Does the German e-invoicing mandate apply to freelancers?

Yes, as soon as you invoice other businesses in Germany. For VAT purposes, a freelancer (Freiberufler under § 18 EStG) is a business like any trader. Your legal form and the type of income do not matter for § 14 UStG. What matters is the recipient: the mandate applies when you and your client are both established in Germany and the service is supplied for the client's business.

An e-invoice (E-Rechnung) is an invoice in a structured electronic format that complies with the European standard EN 16931 and can be processed automatically. A PDF exported from a word processor or an invoicing app is not an e-invoice. German law calls it an "other invoice" (sonstige Rechnung). The main permitted formats are XRechnung and ZUGFeRD from version 2.0.1, except the profiles MINIMUM and BASIC WL.

Edge cases: VAT-exempt services and unclear clients

Some freelancers provide VAT-exempt services under § 4 Nr. 8 to 29 UStG, for example medical professions under § 4 Nr. 14 UStG. There is no obligation to issue an invoice for those services, and an e-invoice requires the recipient's consent. If one invoice combines taxable and exempt services, the BMF says the e-invoicing obligation still applies.

If you are unsure whether a client is acting as a business, ask for their VAT ID. The tax authorities will not object to a missing e-invoice if you could not have recognised, with the care of a prudent businessperson, that the service was for a business. A client quoting a VAT ID is an indication that they act as a business.

When do freelancers have to issue e-invoices?

The transition rules are in § 27 (38) UStG (opens in a new tab). They depend on two dates: when the service is performed and when the invoice is issued.

A paper or PDF invoice for a service performed in 2026 must be issued by 31 December 2026. If you only invoice December work in January 2027, issue an e-invoice to be on the safe side.

The threshold refers to total turnover (Gesamtumsatz) as defined in § 19 (2) UStG. A software developer with €140,000 of turnover in 2026 is far below it. She may keep sending PDF invoices for services in 2027 as long as her clients agree. Consent needs no particular form. It can be implied, for example when a client accepts your PDF invoices without objection.

You can switch earlier at any time. Between German businesses you may send an e-invoice without the recipient's consent, because every business must be able to receive one. Switching early gives you one process for all business clients and removes the need to track consents. The full timeline with every exemption is in our guide to Germany's e-invoicing mandate, and related articles are collected in the e-invoicing mandate category.

Receiving e-invoices: what you need today

Since 1 January 2025, every business established in Germany must be able to receive e-invoices. Your existing e-mail inbox is sufficient; you do not need a dedicated address. You do not have to agree to receive them. You also have no right to demand a PDF or paper invoice instead.

In practice, an XML file or a ZUGFeRD PDF arrives by e-mail. The XML file is the invoice itself, not a technical extra. Our XRechnung viewer makes it readable: it displays XML invoices in UBL and CII syntax and validates them against the official KoSIT rules. For a ZUGFeRD invoice, first extract the XML from the PDF, then open that file in the viewer. The XML part of a ZUGFeRD invoice is always authoritative. If the PDF view differs, the XML prevails, and input VAT can only be deducted on the basis of the XML.

According to the BMF, validation does not replace your duty to check that an invoice is complete and correct. You may rely on the technical result of a suitable validation tool, and you should keep the validation report as evidence.

Small businesses (Kleinunternehmer): permanently exempt from issuing

New thresholds apply since 2025. You are a small business if your total turnover was no more than €25,000 in the previous year and does not exceed €100,000 in the current year. Our kleinunternehmer calculator shows whether you are below both limits. Since 2025, small-business sales are VAT-exempt under § 19 (1) UStG.

Under § 34a UStDV (opens in a new tab), small businesses may always issue an "other invoice". Paper is allowed, and so is a PDF if the client agrees informally. This exemption does not end in 2028. The claim, still common online, that small businesses must issue e-invoices from 2028 is wrong.

A small-business invoice needs at least:

• the full name and address of you and your client,
• your tax number (Steuernummer), VAT ID or small-business identification number,
• the date of issue,
• the type and scope of the service,
• the price as a single amount with a note that the small-business VAT exemption under § 19 UStG applies.

According to the BMF letter of 15 October 2025, small-business invoices do not need a sequential invoice number. You must still be able to receive e-invoices.

If you want to send an e-invoice voluntarily, you may do so without your business client's consent. In XRechnung you would normally use VAT category code E (BT-151 and BT-118) at 0 %, the exemption reason as text in BT-120 and your tax number in BT-32 if you have no VAT ID. If the VAT breakdown for category E is missing, the validator reports rule BR-E-1.

Timesheets: what belongs in the XML and what in the attachment

Many freelancers bill by the hour and add a timesheet. The BMF letter of 15 October 2025 is clear on this. All VAT-mandatory details must be in the structured part of the e-invoice. The service description in the XML must identify the service clearly enough to be verified easily. Supplementary details may go into an attachment embedded in the e-invoice, and the BMF explicitly names a breakdown of timesheets as a PDF file as an example. A link to an external location, such as a time-tracking portal or a cloud folder, is not sufficient.

Do not leave out the date of supply. According to the BMF, a line such as "date of supply equals invoice date" is only enough on conventional invoices. In an e-invoice the date must be in the structured data, either as the actual delivery date (BT-72) or as the invoicing period (BG-14). How the attachment gets into the file via Base64 is explained in our article on XRechnung attachments.

Retainers and monthly flat fees: the recurring invoice

For fixed monthly fees, a rule from the BMF letter of 15 October 2025 helps. For a continuing obligation (Dauerschuldverhältnis), one e-invoice for the first period is enough if the contract is attached or the invoice clearly states that it is a recurring invoice (Dauerrechnung). A unique number from the contract can serve as the invoice number. If VAT-mandatory details change, for example because the fee goes up, you must issue a new e-invoice. A recurring invoice that was validly issued as a conventional invoice does not have to be reissued as an e-invoice as long as nothing changes. If your hours vary each month, normal monthly invoices are the better choice.

Agencies, platforms and clients abroad

Work for an agency based in Germany is a domestic B2B service, so once the transition periods end the agency needs an e-invoice. If the agency pays you through self-billing (Gutschrift), the agency issues the document. Self-billed invoices are covered by the mandate too; the matching type code in BT-3 is 389. You then have to receive and check that document.

The German mandate does not apply to clients in other EU countries. Services to EU businesses usually fall under the reverse charge. The invoice then needs both VAT IDs and the statement "Steuerschuldnerschaft des Leistungsempfängers" (reverse charge), and it must be issued by the 15th day of the following month. Clients outside the EU are not covered by the German mandate either, although their own country may have rules of its own.

Invoices to German federal authorities have had to be e-invoices since 27 November 2020. Since the platform consolidation on 19 September 2025, the federal government accepts invoices only via the OZG-RE. The contracting authority gives you a Leitweg-ID, which goes into BT-10. Our leitweg id validator checks its format and check digit before you submit. The background is explained in What is a Leitweg-ID?. Business clients never require a Leitweg-ID.

Which tools do freelancers need?

Many invoicing and accounting programs export XRechnung or ZUGFeRD. Before choosing one, check that it produces an EN 16931-compliant format and, for ZUGFeRD, a profile other than MINIMUM or BASIC WL. Embedded attachments and an XML export for your archive matter as well.

If you only invoice business clients occasionally, you can create an e-invoice with our online generator, which produces XRechnung (UBL) or ZUGFeRD files. Before sending, run a second check. The German invoice requirements checker reviews the mandatory details under § 14 UStG, and the viewer validates the finished XML file.

ZUGFeRD is a PDF/A-3 with embedded XML and stays readable for clients without special software. XRechnung is pure XML. Both are valid for B2B; federal authorities require XRechnung or ZUGFeRD in the XRECHNUNG profile. The comparison XRechnung vs. ZUGFeRD sets out the differences.

Since 2025, invoices must be kept for eight years, and for e-invoices at least the XML must be stored in its original form. Our article on e-invoice archiving under GoBD covers the details. Attachments, recurring invoices and error types are addressed in the BMF letter of 15 October 2025 (opens in a new tab) (German).

Freelancer checklist

1. Decide which e-mail address suppliers should use for invoices and open a test XML file.
2. Sort your clients: German businesses, private clients, clients abroad, public authorities.
3. Work out your 2026 total turnover to know which rules apply in 2027.
4. If you use the small business scheme, check both thresholds every year.
5. Pick a tool, create a test invoice and validate it.
6. Embed timesheets as PDF and keep all mandatory details in the XML.
7. Move fixed retainers to a recurring invoice.
8. Archive XML files and validation reports unaltered for eight years.