The short version:
- What: A structured, EN 16931-compliant invoice (XRechnung or ZUGFeRD) — not a plain PDF
- Who: Domestic B2B transactions between businesses established in Germany
- Receiving mandatory since: 1 January 2025, for every business
- Issuing mandatory from: 1 January 2027 (revenue > €800,000), 1 January 2028 (everyone)
- Exempt: B2C invoices, invoices up to roughly €250, transport tickets, cross-border invoices
- Legal basis: Wachstumschancengesetz (2024), §14 UStG
What counts as an e-invoice in Germany
An e-invoice is not just an invoice sent electronically. It's a structured, machine-readable document that complies with the European standard EN 16931. In Germany, two formats are in practical use:
- XRechnung — a pure XML file with no visual layout of its own; it needs software to render it as something a human can read.
- ZUGFeRD (from version 2.0.1) — a hybrid PDF that looks like a normal invoice, with the same structured XML data embedded inside it so it works for both people and machines.
A regular PDF invoice, even a well-formatted one, does not qualify — it contains no embedded structured data a system can read automatically.
The mandate timeline
| Date | What changes |
|---|---|
| 1 January 2025 | Every business in Germany must be able to receive a structured e-invoice for domestic B2B transactions. |
| 2025–2026 | Transition period: businesses may still issue paper or PDF invoices, generally with the recipient's consent. |
| 1 January 2027 | Businesses with prior-year revenue above €800,000 must issue e-invoices for domestic B2B sales. |
| 1 January 2028 | The issuing obligation applies to practically all businesses, regardless of revenue. |
Who's exempt
- B2C invoices — the mandate only covers business-to-business sales.
- Small-value invoices, generally up to €250, and transport tickets.
- Cross-border invoices to or from businesses outside Germany — that's regulated separately at EU level, on a longer timeline.
Why Germany introduced it
The law is driven mainly by closing the VAT gap: structured invoice data gives tax authorities machine-readable transaction data instead of documents that would need to be requested and read individually, making VAT fraud (particularly carousel fraud) harder. It's also Germany's national step toward the EU-wide VAT in the Digital Age (ViDA) initiative for near-real-time digital reporting.