1. Home
2. Guides
3. Germany e-invoicing mandate

Germany's B2B e-invoicing mandate: receive since 2025, issue from 2027

Germany's Growth Opportunities Act (Wachstumschancengesetz) rewrote the invoicing rules in the VAT Act for supplies made after 31 December 2024. Invoices between businesses established in Germany move to structured e-invoices in three steps. Everything below is from the Federal Ministry of Finance's FAQ (as of March 2026) unless another source is linked.

Updated 19 October 2026

Timeline

1. Since 1 January 2025: everyone must be able to receiveEvery domestic business, including small businesses under the Kleinunternehmer scheme. An email inbox is enough to receive.
2. 2025 and 2026: transition for issuingAny issuer may still send other invoices: paper always, PDF or other electronic formats only if the recipient agrees.
3. 1 January 2027: issuers with prior-year turnover above €800,000Must issue e-invoices. Businesses with prior-year turnover up to €800,000 may keep using other invoices until the end of 2027. EDI procedures that are not EN 16931 also remain allowed until the end of 2027.
4. 1 January 2028: everyoneE-invoices are mandatory for all invoices between domestic businesses, except the cases below.

Legal basis: § 14 UStG and the transitional rule in § 27 (38) UStG; administrative guidance in the BMF letters of 15 October 2024 and 15 October 2025.

Who is affected

The rules apply to supplies between domestic businesses: those with their seat, management or a fixed establishment involved in the supply in Germany. Freelancers, landlords, doctors and small businesses count as businesses too. A foreign business that is only VAT-registered in Germany, with no fixed establishment, may state this on its invoice to explain why it issues no e-invoice (FAQ, question 3).

Exceptions: no e-invoice needed

• Invoices to consumers (B2C), and many VAT-exempt supplies (§ 4 Nr. 8–29 UStG, for example financial services and residential lettings).
• Small-amount invoices up to €250 gross (§ 33 UStDV).
• Tickets that count as invoices (§ 34 UStDV).
• Supplies by small businesses under the Kleinunternehmer scheme (§ 34a UStDV). They still have to be able to receive.
• Supplies to legal persons that are not businesses, such as many associations or public bodies acting as authorities.

Cash purchases are not an exception: a business lunch or a hardware-store purchase over €250 needs an e-invoice once the transition ends (FAQ, question 10).

Which formats count

An e-invoice is a structured electronic invoice that follows the European standard EN 16931. The ministry names the usual German formats: XRechnung and ZUGFeRD from version 2.0.1, except the profiles MINIMUM and BASIC-WL. Other formats, such as EDIFACT, are allowed if both parties agree and all the invoice data required by VAT law can be extracted correctly. A PDF on its own is not an e-invoice.

For hybrid formats like ZUGFeRD, the XML is now the leading part: where it differs from the PDF, the XML counts (FAQ, question 12a).

How e-invoices are sent

The law does not prescribe a channel. Email, an API, a shared storage location or a download portal all work; the parties agree among themselves. Peppol is an option, not a requirement, for invoices between businesses.

Public-sector invoices are a separate set of rules

Invoices to public authorities are governed by public-procurement law, not the VAT Act. At federal level the E-Rechnungsverordnung has required e-invoices since 27 November 2020, with its own threshold (from €1,000) and the Leitweg-ID as the address. Both sets of rules apply side by side.

Is validation required?

Not legally: a validation is not a precondition for the input-VAT deduction. The ministry still calls it sensible and recommends validating when the invoice is created and sent, because it catches missing or inconsistent mandatory data (FAQ, question 7). For a developer that means: validate every invoice your system issues against the official rules, and validate what you receive before booking it. The free validator does that in the browser; the API does it in your pipeline.

What to do now, as a developer

1. Make sure your product can receive and read XRechnung and ZUGFeRD (mandatory since 2025).
2. Find out your customers' prior-year turnover. Those above €800,000 must issue e-invoices from 1 January 2027; plan to be ready by the end of 2026.
3. Pick a format: ZUGFeRD EN 16931 for businesses, XRechnung for authorities (comparison).
4. Add validation to your tests and your issuing pipeline; fix the errors described in Validate an XRechnung and Validate a ZUGFeRD file.

Sources

• Bundesministerium der Finanzen: Fragen und Antworten zur Einführung der obligatorischen E-Rechnung, as of March 2026 (questions 3, 4, 4a, 7, 8, 10, 11, 12, 12a).
• § 14 UStG and § 27 UStG (transitional rules, paragraph 38).
• E-Rechnungsverordnung (ERechV).