In short
- Every business established in Germany must be able to receive EN 16931 e-invoices since 1 January 2025. An e-mail inbox is enough.
- Issuing becomes mandatory for supplies from 1 January 2027 if 2026 turnover exceeded €800,000, and from 1 January 2028 for everyone else.
- The rule only applies when both supplier and customer are established in Germany. Foreign suppliers without a German establishment are outside it.
- XRechnung, ZUGFeRD (not MINIMUM or BASIC-WL) and other EN 16931 formats such as Peppol UBL are accepted. A plain PDF is not an e-invoice.
- There is no platform, no clearance and no e-reporting. A wrong format is not fined, but the customer's input VAT is at risk.
Germany has had a B2B e-invoicing obligation since 1 January 2025, and it is being phased in until 2028. Every business established in Germany already has to accept e-invoices. Issuing them becomes mandatory in two steps, in 2027 and 2028, depending on turnover.
This guide is written for people who look at the German rules from the outside: foreign suppliers with German customers, international groups with a German subsidiary, and expats or freelancers running a business in Germany. All dates come from the German VAT Act (UStG) and the Federal Ministry of Finance (BMF), checked on 14 November 2026.
The German timeline at a glance
| Date | What applies | Status |
|---|---|---|
| 1 Jan 2025 | All businesses established in Germany must be able to receive e-invoices | Passed |
| 31 Dec 2026 | Last day to issue paper or PDF invoices for 2025 and 2026 supplies | Upcoming |
| 1 Jan 2027 | Issuing mandatory if 2026 turnover exceeded €800,000 | Upcoming |
| 31 Dec 2027 | End of the extension for smaller businesses and of non-compliant EDI | Upcoming |
| 1 Jan 2028 | Issuing mandatory for all businesses in scope | Upcoming |
For France, Belgium and the EU's ViDA package on one page, see the e-invoicing deadlines calendar.
Who is in scope: both parties must be established in Germany
The German obligation is narrower than many foreign suppliers fear. Under § 14 UStG, an invoice must be an e-invoice only when both the supplier and the customer are established in Germany. Established means having the seat, the management, a fixed establishment involved in the supply, or a residence there.
Foreign suppliers selling into Germany
If your company has no seat, management or involved fixed establishment in Germany, you are outside the e-invoicing obligation, even if you are registered for VAT there. The BMF says such suppliers may state this on their invoice to explain why they do not send an e-invoice, and the German customer may rely on that statement.
Two practical points still apply:
- Your German customers may ask for an e-invoice for their own processes. That is a matter of contract, not VAT law.
- If you do have German premises or staff, the fixed-establishment test can be subtle. Ask a tax adviser before relying on the exemption.
Expats and freelancers running a business in Germany
If you are self-employed or run a company in Germany, you are established there and the rules apply to you in full. If you use the small business scheme (Kleinunternehmerregelung), you never have to issue e-invoices but must still receive them; see our Kleinunternehmer guide.
Receiving e-invoices: mandatory since 1 January 2025
Since 1 January 2025, every business established in Germany must be able to receive an e-invoice. There was no transition period. This includes Kleinunternehmer, businesses with only VAT-exempt sales such as doctors and residential landlords, flat-rate farmers, and associations for their business activities.
Receiving is easy to set up. An ordinary e-mail inbox is enough, and you do not need a separate mailbox only for e-invoices. A customer who cannot or will not accept an e-invoice has no right to demand paper instead: the supplier has complied if it sent the e-invoice and can prove the attempt.
To read an XML invoice, use your accounting software, the free official viewer at e-rechnung.elster.de, or our e-invoice validator.
Issuing e-invoices: 2027 or 2028, depending on turnover
The €800,000 test
Issuing is phased in by § 27 (38) UStG:
- Supplies from 1 January 2027: e-invoices are mandatory if the issuer's total turnover (Gesamtumsatz) in 2026 exceeded €800,000.
- Supplies from 1 January 2028: e-invoices are mandatory for all businesses in scope.
Example: a German subsidiary with €1.2 million turnover in 2026 must issue e-invoices for everything it supplies to German business customers from 1 January 2027. A design studio with €300,000 turnover in 2026 may keep sending PDFs (with consent) for 2027 supplies, provided each invoice is issued by 31 December 2027.
In a VAT group (Organschaft), the whole group's turnover counts. For self-billing (Gutschrift), the turnover of the party issuing the credit note counts.
Transitional rules until the end of 2027
- For supplies made in 2025 and 2026, paper is always allowed and other formats such as PDF are allowed with the customer's consent, if the invoice is issued by 31 December 2026.
- For supplies made in 2027, businesses at or below €800,000 may keep using paper or, with consent, PDF, if the invoice is issued by 31 December 2027.
- EDI invoices that do not meet EN 16931 may continue with the customer's consent until 31 December 2027. EDI formats that allow correct and complete extraction into an EN 16931 format stay allowed after that.
Watch out
Under the literal wording of § 27 (38), a supply made in December 2026 but invoiced in January 2027 is covered by neither transitional rule. If you invoice in arrears, ask your tax adviser how to handle December 2026 supplies, or send those invoices before the year ends.
Exceptions that last beyond 2028
Even after 2028, these invoices may stay paper or PDF:
- Invoices up to €250 gross (§ 33 UStDV), except for certain distance sales, intra-EU supplies and reverse-charge cases.
- Passenger travel tickets (§ 34 UStDV).
- Invoices by Kleinunternehmer (§ 34a UStDV).
- Supplies exempt under § 4 Nr. 8 to 29 UStG, which have no invoicing obligation at all. Mixed invoices with taxable lines still need an e-invoice.
- B2C invoices and invoices to non-business legal entities.
Accepted formats
German law does not prescribe one national format. Any structured format that follows the European standard EN 16931 qualifies, and the choice of valid format is a matter between the parties.
| Format | Accepted as e-invoice? |
|---|---|
| XRechnung (UBL or CII) | Yes |
| ZUGFeRD from 2.0.1, profiles EN 16931, EXTENDED, XRECHNUNG | Yes |
| ZUGFeRD profiles MINIMUM and BASIC-WL | No |
| Other EN 16931 formats, e.g. Peppol BIS UBL | Yes |
| EDI that can be converted to EN 16931 | Yes |
| Plain PDF, Word, scanned paper | No |
With a hybrid ZUGFeRD invoice, the XML part is what counts: if the XML and the PDF differ, the XML prevails. You can check any of these formats in our validator before you send them.
No platform, no clearance, no e-reporting
Unlike France or Belgium, Germany has no mandatory platform or network. E-mail, API, EDI, a portal download or shared storage are all fine, as agreed between the parties. There is no clearance by the tax office and, as of November 2026, no transaction reporting. The BMF says a reporting system is planned "at a later date", with no date set in law.
No Leitweg-ID is needed for B2B invoices. That routing ID is only used for invoices to public authorities, covered in our Leitweg-ID guide.
Penalties: no fine, but the customer's VAT is at risk
The BMF letter of 15 October 2026 and the BMF FAQ say that issuing a paper or PDF invoice where an e-invoice is required is not an administrative offence. That does not make it safe. For the customer, such an invoice is not a proper invoice, so input VAT is in principle not deductible. The customer can ask for a corrected e-invoice, and has a civil-law claim to receive one.
For a foreign supplier, this is the real commercial pressure: German customers will push for compliant invoices because their own VAT deduction depends on it.
The three BMF letters
The administrative view is set out in three BMF letters, dated 15 October 2024, 15 October 2025 and 15 October 2026. The 2026 letter adds tolerances, for example: e-invoices issued by 31 December 2026 that meet the 2024 and 2025 letters are accepted even if they miss the new 2026 requirements, including for input VAT.
Will the deadlines move?
As of 14 November 2026, no postponement has been enacted. The German crafts federation (ZDH) and the banking sector are lobbying for the €800,000 stage to move to 2028, but § 27 (38) UStG was unchanged on 14 November 2026. Plan for 1 January 2027 and re-check before the end of the year.
Getting ready
For most businesses, the work is choosing invoicing software that creates XRechnung or ZUGFeRD and reads incoming files. German options include Lexware Office, which creates and sends XRechnung and ZUGFeRD from its M plan, and sevDesk, which includes e-invoicing in all paid plans. For low volumes, SumUp Invoices has a €0 plan with up to 4 invoices a month and unlimited e-invoice receiving (as of Nov 2026). Check current plans with the vendor; our German e-invoicing software comparison covers more.
This page explains the law; it is not tax advice. For VAT groups, fixed-establishment questions or the December 2026 gap, speak to a German tax adviser (Steuerberater).
Questions people ask
Do foreign companies have to send e-invoices to German customers?
Not under German VAT law if they have no seat, management or fixed establishment in Germany involved in the supply, even if they are VAT-registered there. The obligation applies only when both parties are established in Germany, and a foreign supplier may say on its invoice that it has no German establishment.
When do German businesses have to issue e-invoices?
For supplies from 1 January 2027 if the issuer's total turnover in 2026 exceeded €800,000, and for supplies from 1 January 2028 for all other businesses. Until then paper and, with consent, PDF remain allowed under transitional rules.
Is a PDF invoice an e-invoice in Germany?
No. A PDF, Word file or scanned paper invoice is an 'other invoice'. Only a structured format that follows EN 16931, such as XRechnung or ZUGFeRD, counts as an e-invoice.
Is there a fine for not sending an e-invoice in Germany?
The BMF says issuing a paper or PDF invoice where an e-invoice is required is not an administrative offence. The risk sits with the customer, whose input VAT deduction is in principle not allowed on such an invoice.
Do I need Peppol to send e-invoices in Germany?
No. German law prescribes no network or platform. E-mail, an API, EDI or a portal are all fine, and the channel is agreed between the parties. Peppol is one option among several.
Official sources
- § 14 UStG: Ausstellung von Rechnungen gesetze-im-internet.de
- § 27 UStG: Allgemeine Übergangsvorschriften (Abs. 38) gesetze-im-internet.de
- BMF: Fragen und Antworten zur Einführung der obligatorischen E-Rechnung bundesfinanzministerium.de
- BMF letter of 15 October 2024 on the mandatory e-invoice bundesfinanzministerium.de
- BMF letter of 15 October 2025 on the mandatory e-invoice bundesfinanzministerium.de
- BMF letter of 15 October 2026 (supplementary rules) bundesfinanzministerium.de
- § 33 UStDV: Rechnungen über Kleinbeträge gesetze-im-internet.de
- § 34a UStDV: Rechnungen von Kleinunternehmern gesetze-im-internet.de
General information, not tax or legal advice. Check edge cases with a tax adviser.