Germany's E-Invoicing Mandate: Deadlines and Who Is Exempt (2025 to 2028)
Germany is moving business invoices from PDF and paper to structured e-invoices. The change comes in three steps, and the dates that apply to you depend on your turnover and on who your customers are. This is the short version, with the paragraph behind each rule so you can check it yourself.
A summary, not tax advice. The sources are linked at the end.
What counts as an e-invoice
An e-invoice is not a PDF sent by email. § 14 Abs. 1 of the German VAT Act (UStG) defines it as an invoice that is “issued, transmitted and received in a structured electronic format” that allows electronic processing, and the format must follow the European standard EN 16931.
In practice that means two formats:
- XRechnung, pure XML, which many public authorities ask for;
- ZUGFeRD (also called Factur-X), a PDF with the XML inside. It counts from version 2.0.1, except the profiles MINIMUM and BASIC-WL, which carry too little data.
A plain PDF, even one made by invoicing software, is an “other invoice” under the law, not an e-invoice.
The timeline
| When | What applies | Source |
|---|---|---|
| Since 1 January 2025 | Every business must be able to receive e-invoices. There is no transition period for receiving. | BMF, see IHK Pfalz |
| 2025 and 2026 | You may still send paper, or a PDF if your customer agrees. | § 27 Abs. 38 Nr. 1 UStG |
| 2027 | The same, but only if your total turnover in 2026 was €800,000 or less. Above that, e-invoices are mandatory from 1 January 2027. | § 27 Abs. 38 Nr. 2 UStG |
| From 1 January 2028 | E-invoices for all invoices between businesses in Germany. Existing EDI setups may run until the end of 2027. | § 14 Abs. 2, § 27 Abs. 38 Nr. 3 UStG |
The €800,000 threshold is the Gesamtumsatz under § 19 Abs. 2 UStG of the previous calendar year. For invoices you write in 2027, that is your 2026 turnover.
Who does not have to send e-invoices
You may keep sending a normal invoice (paper or PDF) in these cases:
- Small invoices up to €250 in total. § 33 UStDV says such an invoice “can always be transmitted as another invoice”.
- Kleinunternehmer under § 19 UStG. § 34a UStDV gives invoices for their tax-free sales the same rule.
- Tickets for passenger transport (§ 34 UStDV).
- Invoices to consumers. The duty covers invoices between businesses.
- Invoices to customers outside Germany. § 14 Abs. 2 UStG requires the e-invoice when the supplier and the customer are based in Germany.
None of these exceptions covers receiving. A Kleinunternehmer must still be able to accept an e-invoice from a supplier.
Five quick examples
- A freelance designer with €48,000 turnover in 2026, charging VAT. Must accept e-invoices now. May send PDF invoices (with the client’s consent) until the end of 2027, and e-invoices from 1 January 2028.
- An agency with €1.3 million turnover in 2026. E-invoices to German business clients for every sale from 1 January 2027.
- A Kleinunternehmer with €18,000 turnover. Never has to send e-invoices, may send them voluntarily, and must be able to receive them.
- A €180 invoice (gross) to a German company. Can stay a normal invoice, at any time.
- A consultant billing a company in Austria. Not covered by the German duty, because the customer is not based in Germany.
What to do now
- Make sure you can receive. An e-mail address is enough as a channel; the law prescribes none. You also need a way to read and keep the XML, because a ZUGFeRD PDF shows a picture of the invoice but the XML is the e-invoice.
- Pick your format. For business customers, ZUGFeRD is the usual choice because the PDF stays readable for people. Public authorities often require XRechnung with their Leitweg-ID. We compared both with real files in XRechnung vs ZUGFeRD.
- Check what your software produces. The official KoSIT validator is free. A file that the validator rejects is not a valid e-invoice, even if your software calls it one.
Where Inkvoice fits
Inkvoice is free, open-source invoicing software. From version 0.3.4 it creates XRechnung and ZUGFeRD e-invoices from your normal invoices and attaches them to the email. Every change to that code is checked with the KoSIT validator, and the sample files and validator reports are public, including a voluntary Kleinunternehmer e-invoice. The steps are in How to send an e-invoice with Inkvoice.
Sources
- § 14 UStG (definition, duty for B2B in Germany)
- § 27 Abs. 38 UStG (transition rules, €800,000)
- § 33 UStDV, § 34 UStDV, § 34a UStDV (small invoices, tickets, Kleinunternehmer)
- BMF: questions and answers on the e-invoice (German)
- IHK Pfalz: Elektronische Rechnungen (receiving since 2025, ZUGFeRD profiles; German)
Laws were checked on 7 November 2026. Rules change; for a decision about your own business, ask your tax adviser.