Germany introduced new electronic invoicing rules on January 1, 2025. However, the change did not make the issuance of an E-Invoice immediately mandatory for every business. The obligation is being introduced in stages, with different rules for receiving and issuing invoices.
Since January 1, 2025, businesses established in Germany must generally be able to receive an E-Invoice. The mandatory issuance of E-Invoices for domestic B2B transactions is subject to transitional periods that run until the end of 2026 or, for certain businesses and systems, until the end of 2027.
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Transparency notice: This article was prepared with the assistance of an AI system. Its legal and tax statements were checked against current guidance from the German Federal Ministry of Finance and the applicable provisions of the German VAT Act.
Important: This article provides general information and does not constitute individual tax or legal advice. Businesses should confirm how the rules apply to their situation with a qualified tax adviser.
E-Invoice requirements in Germany at a glance
Issue
Rule applicable in 2026
Receiving E-Invoices
Businesses established in Germany have generally been required to be able to receive E-Invoices since January 1, 2025. A dedicated email address is sufficient from a technical perspective.
Issuing invoices in 2026
For affected domestic B2B transactions, businesses may continue issuing paper invoices until December 31, 2026. Other electronic invoices, such as a simple PDF, may also be used during this period if the recipient agrees.
Issuing invoices in 2027
Businesses whose previous-year turnover does not exceed €800,000 may continue using other invoices until December 31, 2027. Certain existing EDI procedures also have a transitional period until the end of 2027.
From January 1, 2028
Businesses covered by the rules must generally issue structured E-Invoices for domestic B2B transactions unless a statutory exception applies.
Simple PDF invoices
A normal PDF without structured invoice data is classified as an “other invoice” rather than an E-Invoice.
Retention period
Invoices generally have to be retained for eight years for German VAT purposes. The structured part of an E-Invoice must remain intact in its original form.
What is an E-Invoice?
An E-Invoice, or E-Rechnung, is an invoice issued, transmitted and received in a structured electronic format that allows the information to be processed automatically.
The defining feature is the structured data. A standard PDF sent by email may be digital, but it does not qualify as an E-Invoice under the German rules applicable to transactions carried out after December 31, 2024.
An invoice generally qualifies as an E-Invoice when its format complies with the European EN 16931 standard or another agreed format from which all information required by German VAT law can be extracted correctly and completely.
Is E-Invoicing mandatory in Germany in 2026?
Germany distinguishes between the ability to receive an E-Invoice and the obligation to issue one.
Receiving E-Invoices
Since January 1, 2025, businesses established in Germany must generally be able to receive E-Invoices. This also applies to businesses using the German Kleinunternehmer VAT scheme, even though they may be exempt from issuing E-Invoices for their own supplies.
The law does not require a particular receiving platform. According to the German Federal Ministry of Finance, an email inbox is sufficient. Businesses may also use accounting software, an electronic interface, a customer portal or another agreed transmission channel.
Issuing E-Invoices during 2026
During 2026, a general transitional rule remains available. For affected domestic B2B transactions, invoice issuers may continue to use:
paper invoices; or
other electronic invoices, including simple PDF invoices, if the recipient agrees to that electronic format.
These invoices can remain valid for VAT purposes while the applicable transitional rule is available. Therefore, it is inaccurate to state that every German business has already been required to issue an E-Invoice since January 1, 2025.
What changes in 2027?
From January 1, 2027, the general transitional period ends. However, businesses whose total turnover in the previous calendar year did not exceed €800,000 may continue issuing other invoices until December 31, 2027.
A separate transitional rule allows certain EDI procedures that do not yet meet the new E-Invoice requirements to continue until the end of 2027.
What changes in 2028?
After the transitional periods expire, structured E-Invoices will generally be mandatory for affected transactions between businesses established in Germany. Statutory exceptions will continue to apply.
Which transactions are covered?
The German VAT rules primarily concern transactions between domestic businesses. A business is generally treated as domestic when it has its registered office, place of management or a fixed establishment involved in the transaction in Germany.
A foreign company does not automatically become a domestic business solely because it has a German VAT registration. Cross-border transactions must therefore be assessed separately.
The E-Invoice requirement normally applies only where German VAT law requires an invoice to be issued in the first place.
Which transactions are excluded?
The obligation to issue an E-Invoice does not apply to every invoice. Important exclusions include:
invoices issued to private consumers in B2C transactions;
many VAT-exempt transactions covered by Section 4, numbers 8 to 29, of the German VAT Act;
small-value invoices with a gross amount of up to €250;
transport tickets that qualify as invoices;
supplies made by businesses applying the German Kleinunternehmer scheme;
certain supplies to legal entities that are not acting as businesses; and
certain property-related supplies to private consumers.
A Kleinunternehmer may be exempt from issuing an E-Invoice but must still be able to receive one. If the business later changes to standard VAT taxation, its obligation to issue E-Invoices should be reassessed.
What is the difference between B2B and B2G E-Invoicing?
The VAT rules for invoices between businesses should not be confused with the separate requirements for invoices submitted to public authorities.
Invoices sent to federal, state or local authorities may be subject to B2G regulations, specific submission portals and additional identifiers such as a Leitweg-ID. The applicable requirements depend on the public authority receiving the invoice.
A Leitweg-ID is generally not required for an ordinary B2B E-Invoice between private businesses.
Which E-Invoice formats are accepted in Germany?
The invoice must contain structured data that can be processed electronically. Common formats in Germany include:
XRechnung: an XML-based format frequently used for invoices submitted to public authorities and also suitable for B2B invoicing;
ZUGFeRD: a hybrid format combining a human-readable PDF with embedded structured XML data; and
Other EN 16931-compliant formats: additional structured formats may qualify if they meet the legal and technical requirements.
According to the German Federal Ministry of Finance, ZUGFeRD versions from 2.0.1 generally meet the requirements, except for the MINIMUM and BASIC-WL profiles.
Businesses may also agree to use another structured format, including an EDI-based format, provided that the information required under German VAT law can be extracted correctly and completely.
Is a PDF an E-Invoice?
A simple PDF invoice is not an E-Invoice under the definition applicable since January 1, 2025. It does not contain structured data that accounting software can process automatically.
During the transitional periods, a PDF may still be used as an “other invoice” when the applicable conditions are met. This does not convert the PDF into an E-Invoice.
A ZUGFeRD invoice is different because the PDF contains an embedded structured XML file. Whether it qualifies depends on the version and profile used.
How to receive E-Invoices
Businesses do not necessarily need expensive software simply to receive an E-Invoice. A basic setup may include:
creating a dedicated email address for incoming invoices;
informing suppliers which address or portal they should use;
checking that XML and hybrid invoice files are accepted by the email and security systems;
using a viewer to display XRechnung files in a readable form;
validating structured invoice data before posting it in the accounting system; and
archiving the original structured file in an appropriate document management or accounting system.
The German tax administration provides an official viewer through ELSTER for displaying XRechnung and ZUGFeRD files. Commercial and free third-party viewers are also available.
How to create and send an E-Invoice
The exact workflow depends on the accounting system, the invoice volume and the requirements of the recipient. A typical process involves the following steps:
collect all information required for a valid VAT invoice;
enter or import the invoice data into the accounting system;
generate a suitable structured format, such as XRechnung or ZUGFeRD;
check that all required information is included in the structured part of the invoice;
validate the file to identify missing or inconsistent data;
send the invoice through the agreed channel; and
retain the structured invoice file in its original form.
Validation is recommended because it can identify technical or logical errors. However, successful technical validation alone does not guarantee that an invoice is correct for tax purposes.
Is a digital signature required?
A qualified digital signature is generally not mandatory for an E-Invoice in Germany. The authenticity of the invoice’s origin, the integrity of its content and its readability must nevertheless be ensured.
Businesses may achieve this through appropriate internal controls that create a reliable audit trail between the invoice and the underlying supply or service. A qualified electronic signature or an appropriate EDI procedure may be used, but these are not the only available methods.
How long must an E-Invoice be retained?
For German VAT purposes, incoming and outgoing invoices generally have to be retained for eight years. This rule applies to paper invoices and E-Invoices.
For an E-Invoice, at least the structured part must be stored in a way that preserves it intact in its original form. Converting an XML invoice only into a PDF and deleting the original structured file would therefore be inappropriate.
Businesses should also consider whether other commercial, accounting or sector-specific retention obligations apply to the same records.
E-Invoice implementation checklist for 2026
Confirm whether the business can receive XRechnung and ZUGFeRD files.
Create a dedicated invoice email address or receiving channel.
Check whether email security systems block XML attachments.
Identify which customers already require structured E-Invoices.
Determine when the transitional period ends for the business.
Review the previous-year turnover before relying on the €800,000 rule for 2027.
Confirm which invoice formats the current accounting software supports.
Make sure all mandatory invoice information appears in the structured data.
Test validation, transmission, receipt and correction workflows.
Store original structured files for the required retention period.
Document internal responsibilities and staff procedures.
Ask a tax adviser to review any uncertain or unusual transaction types.
Support with E-Invoice implementation
Optis Digital can support businesses with the technical and organisational side of E-Invoice implementation. This may include analysing existing workflows, comparing suitable software, preparing digital processes and coordinating integration with current systems.
Questions involving the interpretation of German tax law or the treatment of individual transactions should be reviewed by a qualified tax adviser or lawyer.
Are E-Invoices mandatory for all companies in Germany in 2026?
No. Businesses established in Germany must generally be able to receive E-Invoices. However, the general transitional rule still permits paper invoices and, with the recipient’s agreement, other electronic invoices for affected B2B transactions until December 31, 2026.
Do small businesses have to receive E-Invoices?
Yes. Businesses using the German Kleinunternehmer scheme must generally be able to receive E-Invoices. They are, however, exempt from the obligation to issue E-Invoices for supplies covered by that scheme.
Is an emailed PDF a valid E-Invoice?
No. A simple PDF is an “other invoice” because it lacks structured, automatically processable invoice data. It may still be used during an applicable transitional period.
Can an E-Invoice be sent by email?
Yes. German VAT law does not prescribe one exclusive transmission method. Email, electronic interfaces, portals and other agreed channels may be used.
Which E-Invoice format should a business use?
XRechnung and qualifying ZUGFeRD profiles are widely used in Germany. The best option depends on the accounting software, customer requirements and whether a human-readable PDF representation is needed.
Does an E-Invoice require a digital signature?
No. A qualified digital signature is generally optional. The business must still ensure authenticity, content integrity and readability through appropriate controls.
How long must E-Invoices be stored?
The general retention period for VAT invoices is eight years. The original structured component of an E-Invoice must be retained intact.
When will structured B2B E-Invoices become fully mandatory?
After the transitional periods expire, affected domestic B2B invoices must generally be issued as structured E-Invoices from January 1, 2028. Businesses with previous-year turnover above €800,000 may already be required to issue them from January 1, 2027.
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