The e-invoicing mandate in Germany
With the Growth Opportunities Act, electronic invoicing becomes mandatory step by step in the B2B sector. Here are all the deadlines, who is affected and what you should do now.
The deadlines at a glance
27 Nov 2020
B2G – invoices to the federal government
Suppliers to the German federal government must issue electronic invoices (XRechnung). So the obligation in the public sector has already been in place for years.
01 Jan 2025
Mandatory receiving for everyone
Every domestic business must be able to receive and process e-invoices that comply with EN 16931. A simple email inbox is technically enough, but suitable software for reading and archiving is strongly recommended.
until 31 Dec 2026
Transition period for sending
Paper invoices are still allowed. Other electronic formats (e.g. simple PDFs) may only be sent with the recipient's consent.
01 Jan 2027
Mandatory sending above €800,000
Businesses with more than €800,000 in prior-year turnover must send e-invoices in domestic B2B transactions.
01 Jan 2028
Mandatory sending for all businesses
The obligation to send e-invoices then applies to all businesses, regardless of turnover.
Who is affected?
The obligation applies to transactions between domestic businesses (B2B). Exempt are, among others, invoices to private individuals (B2C), certain tax-free transactions and small amounts up to €250.
- All domestic businesses in B2B — including small businesses (receiving).
- Freelancers, tradespeople, retailers and service providers.
- Not affected: pure B2C invoices to end consumers.
- Special cases: small-amount invoices up to €250 and travel tickets.
What counts as an e-invoice?
An e-invoice in the legal sense is an invoice in a structured electronic format that complies with the European standard EN 16931. A scanned invoice or one sent as a plain PDF is not an e-invoice.
Counts as an e-invoice
- XRechnung
- ZUGFeRD from version 2.0.1 (except MINIMUM & BASIC-WL profiles)
- Other EN 16931 compliant formats
Does not count as an e-invoice
- Paper invoice
- Plain PDF without structured data
- Scanned invoice as an image
- JPG / photo of the invoice
What you should do now
- 1Make sure you can receive and read e-invoices.
- 2Set up audit-proof archiving.
- 3Check from when you have to send e-invoices yourself.
- 4Test creating XRechnung/ZUGFeRD – for example with Kivo Invoice.
Sources
- Federal Ministry of Finance – e-invoicing FAQ
- IHK – e-invoicing obligation from 2025
- European Commission – eInvoicing in Germany
This page is for general information and does not constitute legal or tax advice. Information as of 2026.