Germany's e-invoicing mandate, 2025–2028
The E-Rechnungspflicht makes structured e-invoices mandatory for domestic B2B sales in Germany. Here is what applies when, who is affected, and which formats count.
By Peppol Validator · Updated
The short version
- •Every German business must be able to receive e-invoices since 1 January 2025.
- •Issuing becomes mandatory in two steps: 2027 for businesses above €800,000 turnover, 2028 for everyone.
- •An e-invoice is structured data that complies with EN16931. A PDF is not an e-invoice.
- •Only domestic B2B supplies are covered. B2C and cross-border invoices are outside the mandate.
Legal basis
The mandate comes from the Growth Opportunities Act (Wachstumschancengesetz, March 2024), which amended §14 of the German VAT Act (UStG). The Federal Ministry of Finance (BMF) explained how to apply it in a first letter dated 15 October 2024. A second BMF letter dated 15 October 2025 replaced it and added detail, including a distinction between format errors (the invoice is then not an e-invoice) and business-rule errors.
Germany introduced the mandate under its own national rules, ahead of the EU's ViDA package. It does not include a real-time reporting or clearance system: invoices go directly from supplier to customer.
Timeline and transition rules
| From | Must receive | Issuing |
|---|---|---|
| 1 January 2025 | All businesses | Paper still allowed for everyone; PDF and other e-formats need the customer's consent; EDI allowed with consent. |
| 1 January 2027 | All businesses | E-invoice required if prior-year (2026) total turnover > €800,000. At or below €800,000: paper or PDF (with consent) still allowed. EDI with consent still allowed for all. |
| 1 January 2028 | All businesses | E-invoice required for all businesses. EDI only if the data can be converted into an EN16931-compliant format. |
The €800,000 threshold is the supplier's total turnover in the previous calendar year, so for 2027 it is the 2026 figure. It only decides when the issuing obligation starts. The receiving obligation has applied to everyone since 2025, and the BMF accepts a plain email inbox as a way to receive.
Who is in scope
The mandate covers invoices between businesses that are both established in Germany. For foreign suppliers without a German establishment, issuing e-invoices is not mandatory, but German customers increasingly expect them, and the receiving obligation means your customer can process them.
Not required to issue e-invoices:
- •Small businesses under the §19 UStG small-business scheme (§34a UStDV). They must still be able to receive.
- •Small-amount invoices up to €250 gross (§33 UStDV).
- •Tickets for passenger transport (Fahrausweise).
- •Certain tax-exempt supplies under §4 Nos. 8–29 UStG, for example many financial and insurance services.
- •B2C invoices to private consumers, which are outside the mandate.
Accepted formats
German law is format-neutral, but the invoice must comply with the European standard EN16931. These formats meet that bar:
| Format | Syntax | Notes |
|---|---|---|
| XRechnung | UBL 2.1 or UN/CEFACT CII | German CIUS of EN16931; standard for invoices to public authorities. |
| ZUGFeRD 2.0.1+ / Factur-X | PDF/A-3 with embedded CII XML | Accepted except the MINIMUM and BASIC WL profiles. |
| Peppol BIS Billing 3.0 | UBL 2.1 | EN16931-compliant; used on the Peppol network. |
| EDI (e.g. EDIFACT) | bilateral | Allowed if both parties agree; from 2028 only when convertible to EN16931. |
ZUGFeRD and Factur-X are the same hybrid format under two names. See ZUGFeRD explained for the profiles, and ZUGFeRD vs Factur-X vs XRechnung for a side-by-side comparison.
Invoices to public authorities (B2G)
B2G e-invoicing in Germany predates the B2B mandate. Suppliers to federal authorities have had to send e-invoices since 27 November 2020, through the federal portals (ZRE and OZG-RE) or Peppol. The states have their own rules and timelines. B2G invoices are normally XRechnung and must carry the buyer's Leitweg-ID in BT-10.
What to do now
1. Check your receiving channel
Make sure e-invoices that arrive by email, Peppol or a portal reach accounts payable and can be read, not just archived as XML attachments.
2. Know your 2026 turnover
If it is above €800,000, you must issue e-invoices from 1 January 2027.
3. Pick a format with your software vendor
XRechnung for pure XML workflows and public customers; ZUGFeRD when customers still want a readable PDF.
4. Validate before you send
Since the 2025 BMF letter, an invoice with format errors does not count as an e-invoice. Run your output through a validator during testing and after every software update.
5. Archive correctly
Store the structured XML itself in line with the GoBD, not only a printed or PDF view of it.
Free validator
Check your e-invoice against EN16931
Drop an XRechnung, Peppol BIS or other UBL / CII XML invoice to check it against the EN16931 Schematron rules. Peppol BIS invoices also get the Peppol BIS Billing 3.0 rules; an XRechnung gets the German KoSIT BR-DE rules instead. No signup.
Drag and drop XML invoices
or click to browse · UBL and CII / Factur-X supported
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Frequently asked questions
Does the German e-invoicing mandate apply to foreign companies?
Only if both supplier and customer are established in Germany (head office, management, a fixed establishment involved in the supply, or residence). A company with no German establishment that invoices a German customer is not obliged to issue an e-invoice under the mandate, although its customers may still ask for one. Invoices to public authorities follow the separate B2G rules (XRechnung).
Since when must German businesses be able to receive e-invoices?
Since 1 January 2025, with no transition period and no size threshold. According to the Federal Ministry of Finance (BMF), an email inbox that can receive the invoice is enough. This also applies to small businesses under the §19 UStG small-business scheme.
When do German businesses have to issue e-invoices?
Until the end of 2026, every business may still send paper invoices, or PDF and other electronic invoices if the customer agrees. In 2027 businesses whose total turnover in the previous year exceeded €800,000 must issue e-invoices; smaller businesses may keep the old options for one more year. From 1 January 2028 every business must issue e-invoices for domestic B2B supplies.
Is a PDF invoice an e-invoice in Germany?
No. Under the Growth Opportunities Act (Wachstumschancengesetz) an e-invoice is issued, transmitted and received in a structured electronic format that allows automatic processing and complies with EN16931. A PDF, even when sent by email, is an "other invoice" (sonstige Rechnung) and is only allowed during the transition period.
Which formats are accepted?
The law does not mandate one format, but the invoice must comply with EN16931. In practice that means XRechnung (UBL or CII) and ZUGFeRD from version 2.0.1, except the MINIMUM and BASIC WL profiles. Peppol BIS Billing 3.0 is EN16931-compliant too. Other formats such as EDI are allowed if the data can be correctly converted into an EN16931-compliant format and both parties agree.
Who is exempt from issuing e-invoices?
Small businesses under §19 UStG (§34a UStDV), invoices up to €250 gross (§33 UStDV), tickets (Fahrausweise) and certain tax-exempt supplies under §4 Nos. 8–29 UStG. B2C invoices are out of scope. The exemptions cover issuing only: every business must still be able to receive e-invoices.
Do I need Peppol to comply?
No. The German mandate does not prescribe a transmission channel; email is allowed. Peppol is optional but useful when you exchange invoices with many partners or with public authorities, whose federal invoice portals are reachable through Peppol. For invoices to public authorities you also need the buyer's Leitweg-ID.
What did the BMF letter of 15 October 2025 change?
It replaced the first BMF letter of 15 October 2024 and clarified practical questions. One key point: it distinguishes format errors from business-rule errors. An invoice with format errors is not an e-invoice at all but an "other invoice". Validating invoices before sending them is therefore more than good practice.