Germany's E-Invoicing Mandate: Deadlines, Scope and Exemptions (2026)

Germany's e-invoicing mandate applies to B2B supplies between businesses established in Germany. Since 1 January 2025, every domestic business must be able to receive e-invoices. For issuing, § 27(38) UStG sets transition periods: paper remains allowed for supplies through 2026, and in 2027 only for issuers with prior-year turnover up to €800,000. From 1 January 2028, it applies to everyone.

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

What counts as an e-invoice under German law?

The Wachstumschancengesetz (Growth Opportunities Act, Federal Law Gazette BGBl. 2024 I No. 108 of 27 March 2024) rewrote § 14 of the German VAT Act (Umsatzsteuergesetz, UStG). Since 1 January 2025, the law recognises only two kinds of invoice:

• E-invoice (E-Rechnung): an invoice "issued, transmitted and received in a structured electronic format" that allows electronic processing. The format must comply with the European standard EN 16931. The parties may also agree on another format such as EDI if the invoice data can be extracted correctly and completely.
• Other invoice (sonstige Rechnung): everything else, meaning paper, a plain PDF, a scanned image or invoice text in the body of an email.

A PDF invoice is therefore not an e-invoice, even if created on a computer and sent by email. With hybrid formats such as ZUGFeRD, the embedded XML is what counts. A qualified electronic signature is not required. You can read the wording in § 14 UStG on gesetze-im-internet.de (opens in a new tab).

Who is affected by the mandate?

The obligation applies when three conditions are met: the supplier is established in Germany, the recipient is also a business established in Germany, and the supply is for the recipient's business. Legal form and size do not matter: companies, partnerships, sole traders and freelancers are all covered. For sector specifics, see our guides on e-invoicing for freelancers and e-invoicing for tradespeople; all related articles are on the e-invoicing mandate topic page.

Establishment usually depends on a registered office, place of management or an involved permanent establishment in Germany. Foreign companies that are only VAT-registered here should have their status checked.

These often-overlooked cases are also covered:

• self-billed invoices (Gutschriften), where the customer issues the invoice
• reverse-charge supplies under § 13b UStG between domestic businesses, for example construction work between contractors
• supplies under §§ 24, 25 and 25a UStG (agriculture and forestry, travel services, margin scheme)
• partly tax-exempt supplies and supplies where the supplier has opted for VAT under § 9 UStG, such as VAT-liable letting of commercial premises

Who is not affected?

• Invoices to private consumers (B2C). These can still be issued on paper or, with consent, electronically.
• Cross-border supplies where one party is not established in Germany. The other country may have its own rules.
• Tax-exempt supplies under § 4 nos. 8 to 29 UStG, for example many medical treatments or residential lettings. There is no obligation to invoice them; an e-invoice requires the recipient's consent.
• Property-related work for private individuals. The rule in § 14(2) UStG to invoice within six months still applies, but there is no e-invoicing obligation.

Invoices to public authorities (B2G) follow separate rules: federal suppliers have invoiced electronically since 27 November 2020, usually as an XRechnung via the OZG-RE platform, and states and municipalities run their own portals. See What is XRechnung? for details.

Germany's e-invoicing timeline: when does it become mandatory?

The transition rule is tied to two dates: when the supply is made and when the invoice is issued. Under § 27(38) no. 1 UStG, a paper or PDF invoice (an "other invoice") for a supply made in 2025 or 2026 must be issued by 31 December 2026. If you only invoice a December 2026 service in January 2027, the safe choice is to issue an e-invoice.

The full wording of the transition rule is in § 27 UStG (opens in a new tab).

The transition rules in detail

2025 and 2026: paper is allowed, PDF needs consent

Contrary to some older guides, paper invoices for supplies in 2025 and 2026 need no consent. Consent is only required for other electronic formats, in practice the PDF sent by email; record it in writing, for example in your framework agreement. E-invoices can be sent to any domestic business customer without asking.

2027: the €800,000 threshold

For supplies in 2027, what matters is your total turnover (Gesamtumsatz, § 19(2) UStG) in calendar year 2026. The threshold applies to the business issuing the invoice, not to the customer, and it covers total turnover, not just the B2B share.

• 2026 total turnover of €650,000: paper, or PDF with consent, remains possible in 2027.
• 2026 total turnover of €900,000: e-invoices for domestic B2B supplies from 1 January 2027.

EDI until the end of 2027

Businesses that exchange invoices via EDI without using an EN 16931 format may keep doing so for supplies up to 31 December 2027, provided the recipient consents. This applies regardless of turnover. From 2028, an agreed EDI format is only allowed if it permits correct and complete extraction of the invoice data.

From 1 January 2028 there is no transition period left. Paper and PDF are then only allowed in the permanent exemptions.

Which exemptions apply permanently?

Three groups of invoices may still be issued as other invoices after 2027:

UStDV is the German VAT Implementing Ordinance. Even in these cases you may issue an e-invoice without the recipient's consent. Our kleinunternehmer calculator shows whether you stay under the small-business thresholds.

Which formats meet the German requirements?

The law does not prescribe a single format. The BMF letter of 15 October 2025 (BMF: Federal Ministry of Finance) accepts:

• XRechnung in UBL or CII syntax. The current version is 3.0.2; a pre-release of XRechnung 4.0 was published in September 2026.
• ZUGFeRD from version 2.0.1 in every profile except MINIMUM and BASIC WL, meaning BASIC, EN 16931 (COMFORT), EXTENDED and XRECHNUNG. The current version is ZUGFeRD 2.5.2 from August 2026, equivalent to Factur-X 1.09.2. Profiles and versions are explained in What is ZUGFeRD?
• other formats that comply with EN 16931
• EDI formats by agreement, as long as the invoice data can be extracted correctly and completely

Which one fits depends on your customers and software; see our comparison of XRechnung vs. ZUGFeRD.

Two rules from the BMF letter matter in practice:

1. With hybrid invoices such as ZUGFeRD, the XML part is leading. If it differs from the PDF image, the XML prevails, and input VAT deduction is based only on the structured part.
2. All VAT-mandatory details must be in the structured part. A reference to an attachment that contains them is not enough. Supporting documents such as timesheets may be sent as embedded attachments. An external link satisfies neither § 14(1) sentence 3 UStG nor § 31 UStDV.

How do you receive e-invoices in practice?

The receiving obligation has applied to every domestic business since 1 January 2025, including small businesses and businesses with only tax-exempt sales, such as residential landlords. No consent to receive is needed. A recipient who cannot or will not accept e-invoices has no right to a paper or PDF invoice instead.

Technically, an existing email inbox is enough. A dedicated e-invoicing inbox, portal or Peppol connection is not required. An XRechnung is an XML file, though, and hard to read without suitable software.

To set up incoming invoices:

1. Define one central address for incoming invoices and tell your suppliers.
2. Make incoming files readable. Our xrechnung viewer displays XML invoices in UBL and CII as a readable document and validates them against the official KoSIT rules. For a ZUGFeRD invoice, first pull the embedded XML out of the PDF with the ZUGFeRD extractor, then open it in the viewer.
3. Check the content: are the VAT rate, description of services, service period and your address correct? Technical validation does not replace this check.
4. Archive the original. Under § 14b UStG, invoices must be kept for eight years; for e-invoices, at least the structured part must be kept unchanged in its original format. Our guide to e-invoice archiving under GoBD covers the setup.

What happens if an e-invoice is missing or faulty?

If an e-invoice is required but another invoice is issued, the invoice is not proper (nicht ordnungsmäßig). The recipient then in principle loses the right to deduct input VAT. The supplier can fix this by issuing an e-invoice that specifically references the original invoice.

Format errors, business-rule errors and content errors

The BMF letter of 15 October 2025 distinguishes three types of error:

A content error can exist even when technical validation passes. You may rely on the technical result of a suitable validation tool for format and business rules, but you still have to check the invoice content. Keep the validation report as evidence. Our list of xrechnung validation errors explains individual messages; causes and fixes are in our guide to fixing XRechnung errors. The German invoice requirements checker lets you review the mandatory details before an invoice goes out.

Corrections, early-payment discounts and recurring invoices

• A reduction of the taxable amount, for example through an early-payment discount (Skonto), does not require an invoice correction.
• If the scope of the service changes, for example after a revised site measurement (Aufmaß), the invoice must be corrected.
• For continuing obligations such as leases, one e-invoice for the first period is sufficient if the contract is attached or the invoice is clearly marked as a recurring invoice (Dauerrechnung).

What should businesses do now? Checklist

1. Check receiving: central address, suppliers informed, XRechnung and ZUGFeRD readable.
2. Determine your 2026 total turnover: above €800,000 means e-invoices from 1 January 2027, so finish the switch in the fourth quarter of 2026.
3. Segment customers: only domestic business customers fall under § 14 UStG; public authorities have their own rules.
4. Check your software: does it produce XRechnung or ZUGFeRD in the EN 16931 profile or higher? For individual invoices, you can create an e-invoice online, as XRechnung (UBL) or ZUGFeRD.
5. Clean up master data: tax number or VAT ID, bank details, addresses, customer references.
6. Validate test invoices: check sample invoices technically and against § 14(4) UStG, and keep the validation reports.
7. Document consent: for PDF invoices covering supplies in 2025 and 2026, record your customers' consent.
8. Define the incoming process: who checks incoming e-invoices, and what happens to PDFs that should be e-invoices from 2027 or 2028?
9. Set up the archive: keep XML originals for eight years, unaltered and machine-readable, and update your process documentation (Verfahrensdokumentation).

The e-invoicing conversion checklist gives you a template to work through.

What do the BMF letters of 2024 and 2025 say?

The BMF letter of 15 October 2024 (BStBl I p. 1320) was the first administrative guidance on mandatory e-invoicing. The letter of 15 October 2025 (reference III C 2 - S 7287-a/00019/007/243) amends it and the VAT Application Decree (Umsatzsteuer-Anwendungserlass). On retention it clarifies: eight years under § 14b UStG, at least the structured part kept unchanged in its original format, and storage outside a GoBD-compliant system is not in itself a breach of § 14b UStG.

The letter is available for download on the Federal Ministry of Finance website (opens in a new tab) (in German).