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Rollout underway· Receive live; issue 2027/2028

E-invoicing in Germany

Since January 2025 every German business must be able to receive EN 16931 structured e-invoices. Issuance becomes mandatory on 1 January 2027 for businesses with prior-year turnover above €800k, and on 1 January 2028 for all.

MODEL · Post-audit (exchange), EN 16931FORMAT · XRechnung / ZUGFeRD 2.xAUTHORITY · BMF

01Executive overview

Germany’s B2B e-invoicing obligation, enacted in the Wachstumschancengesetz (March 2024), is deliberately phased: the receiving obligation is already live — since 1 January 2025, any domestic B2B supplier may send you a structured e-invoice and you must be able to process it — while the issuing obligation arrives on 1 January 2027 for businesses with prior-year turnover above €800,000 and on 1 January 2028 for everyone else.

Unlike Italy or Poland there is no state clearance platform (yet): Germany mandates the format and the exchange, not a government gateway. An e-invoice means a structured file conforming to EN 16931 — in practice XRechnung (pure XML) or ZUGFeRD 2.x from profile EN 16931 (hybrid PDF with embedded XML). A digital reporting layer aligned with the EU’s ViDA framework is expected to follow toward 2030. The strategic risk is quiet: paper and plain PDFs lose their legal priority, and a buyer’s input VAT deduction increasingly depends on holding a proper e-invoice.

02At a glance

Mandate status
Phasing — receive live since 2025; issue from 2027/2028
Scope
Domestic B2B between German-established businesses
Model
Decentralised exchange, post-audit — no clearance platform
Format
EN 16931: XRechnung or ZUGFeRD ≥ 2.0.1 (profile EN 16931+)
B2G
Already mandatory (federal level since Nov 2020)
Small-amount invoices
≤ €250 and passenger tickets exempt
Archiving
GoBD-compliant, 8 years (structured part is the original)
Next horizon
ViDA digital reporting & intra-EU e-invoicing by 2030

Legal basis: §14 UStG as amended by the Wachstumschancengesetz of 27 March 2024, with BMF guidance letters (notably October 2024 and subsequent updates) clarifying formats, consent, and transition rules. Transitional reliefs: through end-2026 (and end-2027 for issuers < €800k turnover) paper or — with recipient consent — unstructured formats may still be used; EDI procedures remain permissible if they can be made EN 16931-interoperable by 2028.

04Timeline

05Who and what is in scope

The obligation covers supplies between businesses established in Germany (including fixed establishments participating in the supply).

In scope

  • Domestic B2B supplies between German-established parties
  • Credit notes / self-billing (Gutschriften)
  • Supplies exempt with credit — where invoicing obligations apply

Out of scope / excluded

  • B2C transactions
  • Small-amount invoices ≤ €250
  • Passenger transport tickets
  • Certain tax-exempt supplies (§4 Nr. 8–29 UStG)
  • Cross-border invoices to non-established parties (until ViDA)

06How the system works

Exchange is bilateral: email delivery of an XML file is sufficient in law, though Peppol and EDI channels dominate at scale. There is no government platform, no clearance ID, and — for now — no real-time reporting. The compliance question is therefore evidentiary: is the structured part complete and correct (the XML is the legal invoice in hybrid formats), was it received into a process that can read it, and is it archived immutably under GoBD?

07Invoice content requirements

Content follows §14(4) UStG plus EN 16931 structure. Recurrent problem fields:

In hybrid ZUGFeRD invoices the XML — not the human-readable PDF — is legally decisive; mismatches between the two are a real audit finding.

08Penalties & enforcement

Germany enforces through consequences rather than headline fines:

Input VAT at risk
Buyers who cannot evidence a compliant e-invoice risk their deduction — making suppliers’ non-compliance a commercial problem.
Up to €5,000
Fines possible under §26a UStG for invoicing violations.
GoBD findings
Improper archiving of the structured original triggers audit sanctions and estimates.

09Common pitfalls

"We’ll deal with it in 2027"The receiving obligation is already live. Suppliers may send XRechnung today — into a shared inbox nobody parses. AP processes must handle structured input now.
PDF ≠ e-invoiceA plain PDF is an "other invoice", tolerated only transitionally and with consent. Many businesses believe they already comply because invoices are "electronic".
ZUGFeRD profile confusionOnly profile EN 16931 and above qualifies; BASIC-WL or MINIMUM profiles do not.
Reading the PDF, booking the PDFIn hybrids, the XML governs. AP teams that key from the visual while the XML says something else create silent VAT errors.
Intra-group invoicing forgottenDomestic group companies invoice each other in scope like third parties — often the least automated flow in the house.
Waiting for a platformThere is none to wait for. The obligation is format + capability; the ViDA reporting layer comes later on top.

10What leading businesses are doing

They stood up a structured-inbox in 2025A single receipt channel (email address/Peppol endpoint) feeding a parser into AP workflow — with the XML archived as the original.
They chose a format strategy per counterparty classXRechnung for public and large corporates, ZUGFeRD EN 16931 for the long tail — one data model underneath.
They pulled 2027 forwardIssuing structured invoices voluntarily in 2026 to key customers, converting the mandate into an AR automation gain (faster approval, fewer disputes).
They design for ViDAChoosing tooling that can add per-invoice digital reporting later without re-platforming.

11Your action plan

  1. Verify you can receive & process EN 16931 invoices today (obligation live since 2025)
  2. Fix a format strategy: XRechnung / ZUGFeRD EN 16931 — and validate profiles
  3. Determine your issuance wave (turnover > €800k → 1 Jan 2027)
  4. Close ERP data gaps: buyer references, bank details, tax codes per line
  5. Align archiving: XML as original, GoBD-compliant, 8 years
  6. Make EDI flows EN 16931-interoperable before 2028

12Sources

Last verified: 8 July 2026 · report a change: hello@e-invoicing.org
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