In short
Since 1 January 2025, every business established in Germany must be able to receive e-invoices, and an email inbox is enough. From 2027, companies with more than EUR 800,000 prior-year turnover must issue them, from 2028 all domestic businesses. Accepted formats follow EN 16931, such as XRechnung and ZUGFeRD from version 2.0.1. A plain PDF does not qualify.
Receiving: Since 1 January 2025, every business established in Germany must be able to receive e-invoices. An email inbox is enough.
Issuing in 2027: From 1 January 2027, businesses with prior-year turnover above EUR 800,000 must issue e-invoices.
Issuing in 2028: From 1 January 2028, the obligation covers all domestic B2B transactions.
Format: Structured formats under EN 16931, such as XRechnung and ZUGFeRD from version 2.0.1. A plain PDF is not an e-invoice.
Exemptions: Invoices up to EUR 250, travel tickets, small businesses under the VAT exemption scheme (for issuing) and B2C sales.
What counts as an e-invoice in Germany?
An e-invoice is an invoice issued, sent and received in a structured electronic format that allows electronic processing. That is the definition in Section 14(1) of the German VAT Act (UStG) since 1 January 2025. A plain PDF sent by email no longer qualifies. The Federal Ministry of Finance (BMF) classes it as an “other invoice”, just like paper.
The format must comply with the European standard EN 16931. Supplier and customer may agree on another format if all mandatory VAT data can be extracted into an EN 16931 format. This mainly keeps existing EDI processes usable. For a short definition, see our glossary entry e-invoice.
Who is affected?
The rules apply to transactions between businesses established in Germany. A business counts as domestic if its registered office, management or a permanent establishment involved in the supply is in Germany. Foreign companies registered for German VAT without a fixed establishment there may state this on the invoice. According to the BMF, the recipient can rely on that statement.
Which deadlines apply?
The obligation is phased in. The transition rules are in Section 27(38) UStG, and the BMF explains them in its e-invoicing FAQ (as of 29 October 2026).
Period | Receiving | Issuing |
|---|---|---|
Supplies in 2025 and 2026 | Mandatory for all domestic businesses | Paper always allowed, PDF or other formats with the recipient's consent |
Supplies in 2027 | Mandatory | E-invoice mandatory above EUR 800,000 prior-year turnover. Below that, paper or PDF with consent. EDI with consent still allowed. |
Supplies from 2028 | Mandatory | E-invoice for all domestic B2B supplies |
The 2027 threshold refers to total turnover under Section 19(2) UStG in the previous calendar year, not only B2B sales. A company with more than EUR 800,000 turnover in 2026 must issue e-invoices from January 2027.
XRechnung or ZUGFeRD?
Both formats meet the legal requirements. The BMF explicitly names XRechnung and ZUGFeRD from version 2.0.1, except the ZUGFeRD profiles MINIMUM and BASIC-WL.
Feature | XRechnung | ZUGFeRD |
|---|---|---|
Structure | pure XML file | PDF with embedded XML (hybrid) |
Human-readable | only with a viewer | directly as PDF |
Maintained by | KoSIT (German IT standards body) | FeRD (Forum elektronische Rechnung Deutschland, AWV) |
Prevails if data differ | XML | XML part, not the PDF |
For hybrid invoices the XML data now prevail if PDF and XML differ. XRechnung files need a viewer, and the tax administration offers a free one in its ELSTER portal (so nobody has to buy software just to read them).
All mandatory VAT details must sit in the structured part. A reference to a PDF attachment is not enough. Supporting documents such as timesheets may be embedded as attachments.
Who is exempt?
According to the BMF, an “other invoice” (paper or PDF) remains permitted for:
small-amount invoices up to EUR 250 gross
travel tickets that count as invoices
supplies by small businesses using the VAT exemption scheme
sales to consumers and many VAT-exempt supplies
supplies to legal entities that are not businesses, such as many associations
Small businesses must still be able to receive e-invoices. The exemption only covers issuing them.
What happens if you do not comply?
According to the tax administration, issuing a non-compliant invoice is currently not an administrative offence under Section 26a UStG. The main risk lies with the recipient. An invoice in the wrong format is not a proper invoice and, in principle, does not entitle the recipient to deduct input VAT. The BMF allows corrections: the supplier can issue a corrective e-invoice later. Recipients also have a civil-law claim to receive an e-invoice.
What businesses should do now
Check your 2026 turnover. Above EUR 800,000, you must issue e-invoices from 1 January 2027.
Set up receiving. Use one dedicated email address for incoming invoices and tell your suppliers.
Check your software. Can it create and read XRechnung and ZUGFeRD? Our accounting software comparison shows the differences.
Sort out archiving. Keep the XML part unaltered for eight years (Section 14b UStG). Details are in GoBD explained.
Align with partners. Agree on format, channel and fields such as the buyer reference (BT-10). In B2B a placeholder is sufficient, according to the BMF.
Review contracts. If a cloud service processes your invoices, you need a data processing agreement.
Then run a test with a regular customer and confirm that your e-invoice arrives and is readable.
What comes after 2028?
Germany plans a transaction-based reporting system that will build on e-invoices. The BMF says the government will propose the necessary legislation “in due course”, and there is no date yet. At EU level, the VAT in the Digital Age (ViDA) package was adopted in 2025. From 1 July 2030, cross-border B2B supplies within the EU will be subject to digital reporting based on e-invoices.
Frequently asked questions
Is a PDF invoice by email still allowed in Germany?
Until the end of 2026, yes, if the recipient agrees. For supplies in 2027 only businesses with prior-year turnover up to EUR 800,000 may still use it. From 2028, a plain PDF is no longer a valid invoice between domestic businesses.
Do foreign companies have to issue German e-invoices?
The obligation applies to businesses established in Germany. A company registered for German VAT without a fixed establishment there may state this on its invoice, and the recipient can rely on it.
Do I need new software to receive e-invoices?
According to the BMF, an email inbox is enough to receive them. To read an XRechnung you need a viewer, for example the free one in the ELSTER portal. Accounting software that processes XML invoices makes booking and archiving easier.
Does the EUR 800,000 threshold refer to B2B turnover only?
No. It refers to total turnover under Section 19(2) UStG in the previous calendar year.
Sources
- Fragen und Antworten zur Einführung der obligatorischen (verpflichtenden) E-Rechnung zum 1. Januar 2025 , Bundesministerium der Finanzen , 2026-10-29
- § 27 UStG Allgemeine Übergangsvorschriften (Abs. 38) , Bundesministerium der Justiz / gesetze-im-internet.de
- § 14 UStG Ausstellung von Rechnungen , Bundesministerium der Justiz / gesetze-im-internet.de
- § 14b UStG Aufbewahrung von Rechnungen , Bundesministerium der Justiz / gesetze-im-internet.de
- VAT in the Digital Age (ViDA) , European Commission, Taxation and Customs Union
