E-Invoicing Guide

Germany E-Invoicing Mandate: Timeline, Requirements, and What to Prepare

A phased rollout from 2025 to 2028 — where your business fits and what you need to do at each stage.

Phased timeline

Germany's e-invoicing mandate (Wachstumschancengesetz) does not switch on all at once. It rolls out in three phases, giving businesses time to adapt. The key dates are set by revenue thresholds and transaction direction.

1 January 2025 — Receiving

All German B2B businesses must be able to receive structured e-invoices. This applies regardless of company size. If a supplier sends you an EN 16931 invoice, you must be able to process it.

1 January 2027 — Issuing (large businesses)

Businesses with prior-year revenue exceeding €800,000 must issue structured e-invoices for domestic B2B transactions. PDF invoices and paper invoices are no longer sufficient for these businesses.

1 January 2028 — Issuing (all businesses)

All remaining businesses must issue structured e-invoices for domestic B2B transactions. No revenue threshold — the mandate applies to everyone.

Important

The receiving obligation is already in effect since January 2025. Even if your issuing deadline is 2027 or 2028, you must already be able to accept e-invoices from suppliers who have adopted early.

Who's affected at each phase

The mandate applies to domestic B2B transactions between businesses established in Germany. Cross-border transactions and B2C sales are not currently in scope.

Scope by phase

2025: All German B2B businesses

Must accept structured e-invoices. No exemptions by size. This includes freelancers, small businesses, and enterprises alike.

2027: Revenue above €800,000

Must issue e-invoices. The threshold is based on the previous calendar year's total revenue (Gesamtumsatz). If you exceeded €800,000 in 2026, you must issue e-invoices from January 2027.

2028: All businesses

No threshold. Every business issuing domestic B2B invoices in Germany must use structured e-invoicing.

What about Kleinunternehmer?

Small businesses using the Kleinunternehmerregelung (small business scheme under §19 UStG) are also included. While they do not charge VAT on their invoices, they must still comply with the e-invoicing format requirements for B2B transactions from their applicable deadline.

Technical requirements

Germany's mandate requires invoices to conform to the European standard EN 16931. This is the same standard used across EU e-invoicing mandates, which means tools built for EN 16931 compliance work across borders.

Accepted formats

✓

XRechnung

The German national standard, fully EN 16931 compliant. Pure XML format. Already mandatory for B2G (business-to-government) invoices in Germany.
✓

ZUGFeRD (version 2.0.1+)

A hybrid format that embeds structured XML data inside a PDF/A-3 document. The EN 16931 profile (also called the "Comfort" or "EN 16931" profile) is accepted.
✓

Other EN 16931 syntaxes

Any format conforming to EN 16931 (e.g., UBL-based formats) is also accepted under the mandate, as long as it meets the structural requirements.

Plain PDF is not enough

A standard PDF invoice (without embedded structured data) does not qualify as an e-invoice under the German mandate. Even if it looks like a proper invoice, it lacks the machine-readable data required by EN 16931.

XRechnung vs ZUGFeRD

Both formats are valid under the mandate, but they serve slightly different purposes.

XRechnung

Pure XML — no visual component
Strictly EN 16931 compliant
Already standard for German B2G
Requires software to read and display
Best for: automated processing, government submissions

ZUGFeRD

PDF/A-3 with embedded XML
Human-readable and machine-readable
Multiple profiles (use EN 16931 profile)
Can be opened like a normal PDF
Best for: businesses that still need visual invoices

For many service businesses, ZUGFeRD offers a practical middle ground: your clients can open the PDF and read it normally, while the embedded XML satisfies the e-invoicing mandate. XRechnung is the better choice when the recipient processes invoices entirely through software without human review.

How this differs from Belgium

Belgium is also rolling out a B2B e-invoicing mandate, but the approach differs in several ways.

Format Germany accepts multiple EN 16931 formats (XRechnung, ZUGFeRD, UBL). Belgium mandates Peppol BIS Billing 3.0 specifically.

Network Belgium requires invoices to be exchanged via the Peppol network. Germany does not mandate a specific exchange network — invoices can be sent by email or other electronic means.

Rollout Germany uses a phased approach (2025-2028) with revenue thresholds. Belgium targets a single go-live date for all VAT-registered businesses.

Flexibility Germany's approach is more flexible on format and delivery, while Belgium's is more prescriptive with Peppol as the single mandatory channel.

If you operate in both countries, the good news is that EN 16931 compliance covers both. The difference is mainly in how invoices are delivered and which specific profile is required.

What to do now

The receiving obligation is already active. Even if your issuing deadline is 2027 or 2028, you should prepare now.

Ensure you can receive e-invoices

Your accounting or invoicing software should be able to read and process XRechnung and ZUGFeRD files. This is not optional — it has been required since January 2025.

Check your revenue threshold

If your 2026 revenue will exceed €800,000, you must issue e-invoices from January 2027. Plan for this before the deadline, not after.

Choose your format

Decide between XRechnung and ZUGFeRD based on your business needs. ZUGFeRD is often the practical choice for service businesses that still share invoices with clients who expect a visual document.

Use compliant invoicing software

Your invoicing tool should generate EN 16931 compliant output. Retrofitting invoice data into compliant formats later is significantly more work than starting with the right tool.

EN 16931 compliant invoicing

Invoxo generates structured invoices that meet EN 16931 requirements, ready for Germany's e-invoicing mandate.

Try free for 14 days

Connection to Peppol and ViDA

Germany's domestic mandate is part of a broader European shift toward structured e-invoicing. Two initiatives are shaping the wider landscape.

Peppol

Unlike Belgium, Germany does not mandate the Peppol network for B2B invoice exchange. However, Peppol is widely used in German public procurement (B2G), and its adoption for B2B is growing. If you already use Peppol for government invoices, extending it to B2B transactions is a natural step.

ViDA (VAT in the Digital Age)

The EU's ViDA proposal aims to introduce mandatory e-invoicing and digital reporting for cross-border B2B transactions across all member states by 2030. Germany's domestic mandate aligns with this direction — businesses that adopt EN 16931 now will be well positioned when ViDA takes effect.

The combination of Germany's domestic mandate (2025-2028) and ViDA's cross-border requirements (expected 2030) means that e-invoicing will eventually cover both domestic and intra-EU B2B transactions. Getting compliant now avoids a second migration later.

Summary: Germany e-invoicing timeline

✓

January 2025 — All businesses must be able to receive structured e-invoices (already in effect)

✓

January 2027 — Businesses with revenue above €800,000 must issue e-invoices for domestic B2B

✓

January 2028 — All businesses must issue e-invoices for domestic B2B

✓

Formats — XRechnung, ZUGFeRD (EN 16931 profile), or any EN 16931 compliant syntax

✓

Delivery — No mandatory network (unlike Belgium's Peppol requirement)

✓

ViDA 2030 — Cross-border e-invoicing expected EU-wide, building on the same EN 16931 standard

Related guides

Belgium E-Invoicing Mandate

Belgium's Peppol-based mandate and how it compares.

Country Guide: Germany

VAT rates, registration, and invoicing rules for Germany.

EN 16931 Guide

The European e-invoicing standard explained for service businesses.

Common questions

Is the receiving obligation already in effect? ⌄

Yes. Since 1 January 2025, all German B2B businesses must be able to receive structured e-invoices in EN 16931 format (XRechnung or ZUGFeRD). This applies regardless of your company size.

Can I still send PDF invoices? ⌄

During the transition period, PDF invoices are still accepted for businesses below the issuing threshold. However, from your applicable deadline (2027 if revenue exceeds €800,000, 2028 for all others), plain PDF invoices will no longer satisfy the mandate for domestic B2B transactions. ZUGFeRD — which is a PDF with embedded structured data — does qualify.

Does this apply to cross-border invoices? ⌄

The German domestic mandate covers B2B transactions between businesses established in Germany. Cross-border e-invoicing will be addressed separately under the EU ViDA initiative, expected around 2030.

Do I need to use Peppol in Germany? ⌄

No. Unlike Belgium, Germany does not mandate a specific delivery network. You can send e-invoices by email or other electronic means. Peppol is commonly used for B2G transactions and is growing in B2B, but it is not required.

What happens if I don't comply by my deadline? ⌄

Non-compliant invoices may not be recognized as proper invoices under German tax law, which can affect your client's right to deduct input VAT and may lead to penalties during tax audits. The specifics will depend on enforcement guidance from the Bundesfinanzministerium.

Disclaimer: Invoxo provides tooling to support common VAT workflows. For complex scenarios, confirm requirements with your accountant.

Prepare for Germany's e-invoicing mandate

Invoxo generates EN 16931 compliant invoices with correct VAT treatment. Start now and be ready before the deadlines.

Start free trial

14-day free trial. No charges until trial ends.