Sending invoices as PDF files was standard practice for years. That has changed: e-invoicing in Germany is now mandatory in phases. Since January 1, 2025, businesses have been required to receive e-invoices. Beginning January 1, 2027, businesses with annual revenue of more than roughly $900,000 must also issue e-invoices. Starting in 2028, the requirement applies to all businesses.
This article explains the German e-invoicing timeline, the permitted formats, and what you should prepare now.
Key Points at a Glance
- Since January 1, 2025: All businesses in Germany must be able to receive and process e-invoices.
- Beginning January 1, 2027: Businesses with annual revenue of more than roughly $900,000 in the previous year must issue e-invoices.
- Beginning January 1, 2028: All businesses must issue and receive e-invoices, with limited exceptions (see the timeline below)
- An e-invoice is structured and machine-readable and follows the EN 16931 standard. A PDF does not qualify as an e-invoice.
- Existing EDI invoicing processes remain permitted during the transition period. Beginning in 2028, they must comply with EN 16931.
- Since January 1, 2025, the invoice retention period has been eight years instead of ten.
- The German e-invoicing requirements apply to domestic B2B invoices.
Timeline: All Deadlines at a Glance
Effective Date
Receiving
Issuing
PDF and Paper
EDI (e.g., EDIFACT)
January 1, 2025
Mandatory for all businesses
No requirement
Permitted with the recipient’s consent
Permitted during the transition period
January 1, 2026
Mandatory for all businesses
No requirement
Permitted with the recipient’s consent
Permitted during the transition period
January 1, 2027
Mandatory for all businesses
Mandatory for businesses with annual revenue of more than roughly $900,000 in the previous year
No longer permitted for businesses with revenue above roughly $900,000
Permitted during the transition period
January 1, 2028
Mandatory for all businesses
Mandatory for all businesses.
Exceptions to the issuance requirement: invoices up to $280 and sole proprietors, generally with revenue up to $28,000. The receiving requirement still applies.
No longer permitted
Only permitted if the format complies with EN 16931: the invoice information required under EN 16931 must be extractable.
2026 introduced no new requirements. For businesses above the revenue threshold, it is the final year to prepare for issuing e-invoices in Germany.
What Qualifies as an E-Invoice?
In Germany, an e-invoice is an electronic invoice issued, transmitted, and received in a structured format. Your system can process it automatically. It complies with the European standard EN 16931.
The following do not qualify as e-invoices:
- PDF files without structured data
- Scanned paper invoices
- Image files
These documents are still classified as “other invoices,” even when sent digitally.
You do not need the recipient’s consent for e-invoices that comply with EN 16931. Consent is required only for paper, PDF, and noncompliant electronic formats during the transition periods.
Who Is Affected?
The German e-invoicing mandate applies to all businesses established in Germany or operating a branch there. It covers domestic B2B invoices. Cross-border invoices are currently excluded.
Which Formats Are Permitted?
- XRechnung: An XML-only format
- ZUGFeRD version 2.0 and later: A PDF with embedded XML data
- Peppol BIS: An international standard with German extensions
- EDIFACT and other EDI processes: Permitted during the transition period; beginning in 2028, they must comply with EN 16931
- The official EN 16931 syntaxes are UBL and CII XML. Other formats may be used if agreed upon by the trading partners.
The main difference between XRechnung and ZUGFeRD is that XRechnung is XML only, while ZUGFeRD pairs a readable PDF with the XML data. Other formats may be used if the trading partners agree and the format complies with EN 16931.
What Does This Mean for Existing EDI Processes?
If you already handle e-invoicing through EDI, you do not need to start over. EDI processes remain permitted through the end of 2027 if both trading partners agree. Beginning in 2028, the messages must comply with EN 16931. You can therefore adapt your existing connections step by step instead of replacing them.
What You Should Do Now
- Check your ability to receive e-invoices: Can your systems receive and process e-invoices? This has been mandatory since 2025.
- Choose a format: XRechnung, ZUGFeRD, or a combination based on your trading partners’ requirements.
- Adapt your ERP and accounting systems for e-invoicing: Invoices should be generated and processed without manual steps.
- Agree on transmission methods: Email, EDI, or a platform. You are free to choose the method.
- Train your team and document your processes: Include process documentation that complies with Germany’s GoBD requirements.
- Prepare to issue e-invoices: If your annual revenue in the previous year exceeded €800,000, there is little time left before January 1, 2027.
You can find step-by-step instructions in our practical guide to e-invoicing.
Looking Ahead: ViDA and Cross-Border Invoices
The EU’s VAT in the Digital Age (ViDA) initiative aims to standardize e-invoicing and real-time reporting requirements across Europe. Cross-border B2B invoices could then also be covered. 2028 is being discussed as a possible start date.
Understand What Applies to Your Business
Want to know which format works with your systems and how to go live before the deadline? We can work through it with you, from selecting a format and connecting your ERP system to going live.
Request a consultation, or download our whitepaper on invoicing in Germany.
Frequently Asked Questions
When does e-invoicing become mandatory?
Since January 1, 2025, all businesses have been required to receive e-invoices. Businesses with annual revenue of more than €800,000 must issue them beginning January 1, 2027, and all other businesses follow beginning January 1, 2028.
Are PDF invoices still permitted?
Yes, with the recipient’s consent and only during the transition period. A PDF is not an e-invoice as defined by law. Beginning in 2028, it will no longer be permitted for domestic B2B invoicing.
Which formats are permitted?
All formats that comply with EN 16931, such as XRechnung, ZUGFeRD version 2.0 and later, and Peppol BIS.
Are EDI processes such as EDIFACT still permitted?
Yes, during the transition period through the end of 2027. Beginning in 2028, they must comply with EN 16931.
Who is affected by E-invoicing in Germany?
All businesses established in Germany and German branches of foreign businesses when issuing domestic B2B invoices.
Does the mandate also apply to cross-border invoices?
Not currently. ViDA is paving the way for an EU-wide framework.