Summary · 2026-10-12
Germany’s e-invoice mandate: 2025, 2027, 2028
Germany’s Growth Opportunities Act (Wachstumschancengesetz, 27 March 2024) rewrote § 14 of the VAT Act (UStG). An “electronic invoice” is now only an invoice in a structured format that follows the European standard EN 16931 – in practice XRechnung (pure XML) or ZUGFeRD / Factur-X (PDF/A-3 with embedded XML). A plain PDF is no longer an e-invoice but an “other invoice”.
Timeline
| Date | What applies |
|---|---|
| 1 Jan 2025 | Every business established in Germany must be able to receive e-invoices for domestic B2B supplies. An e-mail inbox is enough (BMF FAQ). |
| 2025–2026 | Transition: paper and (with the recipient’s consent) PDF invoices are still allowed for everyone (§ 27 para. 38 no. 1 UStG). |
| 1 Jan 2027 | Businesses whose total turnover in the previous calendar year exceeded €800,000 must issue e-invoices for domestic B2B supplies. Smaller businesses may keep using paper/PDF until 31 Dec 2027 (§ 27 para. 38 no. 2). |
| 1 Jan 2028 | Everyone must issue e-invoices. EDI formats outside EN 16931 are also only tolerated until the end of 2027 (§ 27 para. 38 no. 3). |
Exceptions
Not covered: invoices to consumers (B2C), small-amount invoices up to €250 (§ 33 UStDV), tickets (§ 34 UStDV), supplies exempt under § 4 no. 8–29 UStG, and invoices issued by small businesses under § 19 UStG (§ 34a UStDV) – who nevertheless must be able to receive e-invoices.
What to do
Make sure incoming XML and ZUGFeRD files can be opened, checked and archived unchanged for 8 years (§ 14b UStG). For outgoing invoices, pick a tool that produces EN 16931-compliant files – for example E-Rechnung für Excel or E-Rechnung für Sheets, which create XRechnung and ZUGFeRD directly from your spreadsheet rows.
General information, not tax or legal advice. Sources: German VAT Act (UStG), UStDV and the BMF FAQ on e-invoicing, as of 2026-10-12.