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When do e-invoices become mandatory in Germany?

Since 1 January 2025, every business in Germany must be able to receive e-invoices; an email inbox is enough. You must issue e-invoices to other businesses in Germany from 1 January 2028 at the latest, or from 1 January 2027 if your turnover in the previous year was over 800,000 euros.

Last checked 25 October 20262 min readSources
Contents

E-invoicing is coming to Germany in stages. Every business must already be able to receive e-invoices. When you must issue them depends on your turnover: from 1 January 2027 or from 1 January 2028. This guide sums up what the Federal Ministry of Finance (BMF) says about it.

What is an e-invoice?

An e-invoice is an invoice in a structured electronic format that allows it to be processed electronically. This applies in particular to formats that meet the European standard EN 16931, such as XRechnung and ZUGFeRD. A plain PDF is not an e-invoice but an “other invoice” (sonstige Rechnung), just like a paper invoice.

XRechnung or ZUGFeRD: what is the difference?

Must I already be able to receive e-invoices?

Yes. Since 1 January 2025, all businesses in Germany must be able to receive e-invoices. There are no exceptions to this, not even for Kleinunternehmer (small businesses under § 19 UStG, the German VAT Act). An email inbox is enough for this.

An XRechnung has no human-readable view. To read one, you need a viewer, such as ours, which runs directly in your browser:

When must I start issuing e-invoices?

DateWhat changes
27 November 2020Invoices to the federal government. Suppliers to federal authorities must send e-invoices from €1000, under the federal E-Invoicing Regulation (ERechV).
1 January 2025Every business must be able to receive. All businesses in Germany, including small businesses (Kleinunternehmer), must be able to receive e-invoices. An e-mail inbox is enough. Until the end of 2026, every business may still choose to send paper invoices, or PDF if the customer agrees.
1 January 2027Larger businesses must issue. Businesses whose total turnover in the previous year was over €800000 must issue e-invoices to other German businesses. Smaller businesses may still send paper, or PDF if the customer agrees, until the end of the year.
1 January 2028Every business must issue. The transition ends: e-invoices are required between German businesses, apart from exceptions such as small amounts, travel tickets and small businesses (Kleinunternehmer).

In short, under § 27(38) UStG:

  • Until 31 December 2026, all businesses may issue an other invoice instead of an e-invoice: on paper at any time, or as a PDF or in another electronic format only if the recipient agrees.
  • Until 31 December 2027, this still applies to businesses whose total turnover in the previous year was no more than 800,000 euros, and to certain EDI procedures.
  • After that, e-invoices are mandatory for transactions between businesses in Germany.

What counts is the date of the transaction, not the invoice date.

What are the exceptions?

Even where you must issue an invoice, you do not need to issue an e-invoice for:

  • small-amount invoices up to 250 euros including VAT;
  • tickets that count as invoices;
  • supplies by Kleinunternehmer;
  • supplies to legal entities that are not businesses, for example many associations.

The rules do not apply to invoices to private customers or to many VAT-exempt transactions.

Do Kleinunternehmer have to issue e-invoices?

What should you do now?

  1. Make sure you can receive and read e-invoices, for example with an email inbox and a viewer. The tax authorities offer a free e-invoice viewer on ELSTER (the German tax authorities’ online portal).
  2. Check with your bookkeeper or software provider when you must start issuing e-invoices yourself.
  3. Check your customers’ details, for example their USt-IdNr. (VAT ID):

Frequently asked questions

Is a PDF sent by email still enough?
Only during the transition periods, and only if your customer agrees. A plain PDF is not an e-invoice but an "other invoice" (sonstige Rechnung). A paper invoice can always be used during the transition period.
Is there a required way to send e-invoices?
No. The law does not prescribe one: email, an interface, a portal or another channel are all possible. You agree the channel with your business partner.
Does the obligation also apply to invoices for private customers?
No. Invoices to consumers are not covered by the rules on mandatory e-invoicing.
How long must I keep e-invoices?
For VAT purposes, 8 years. You must keep at least the structured part, unaltered and in its original form.
Do I need something different for invoices to public authorities?
Yes. Invoices to public-sector clients have their own rules. For the federal government, the E-Invoicing Regulation (ERechV) has applied since 27 November 2020, from 1,000 euros. For these invoices you need the authority's Leitweg-ID (routing ID).

Related guides

XRechnung or ZUGFeRD: what is the difference?

Both formats count as e-invoices. The difference: ZUGFeRD is a PDF with embedded data, XRechnung is data only. Here is how to read both.

Do Kleinunternehmer have to issue e-invoices?

Kleinunternehmer (small businesses under § 19 UStG) do not have to issue e-invoices, but since 1 January 2025 they must be able to receive them. What this means in practice.

Sources

This guide is general information, checked against the official sources above. It is not legal or tax advice; for your own situation, ask your accountant or software provider.