B2B vs B2G E-Invoicing in Germany: Who Must Comply and When
Germany's e-invoicing rules do not apply uniformly: the obligations for invoicing a government body differ from those for invoicing another private business, and the timelines for each phase of the B2B mandate are staggered. Sorting out which scenario applies to you is the first step.
What B2G means in Germany
B2G stands for business-to-government: invoices from a private company to a German federal, state or municipal authority. XRechnung is the required format for federal government suppliers, submitted via the designated portals. Most federal state governments introduced their own mandates between 2020 and 2023.
What B2B means for e-invoicing
B2B covers invoices between two private businesses. Germany's B2B e-invoicing mandate was introduced by the Wachstumschancengesetz (Growth Opportunities Act) and came into force in January 2025. From that date, all VAT-registered German businesses must be able to receive a structured e-invoice. Sending obligations are staggered by turnover.
The B2B timeline
- From 1 January 2025: all businesses must be able to accept a structured e-invoice in XRechnung or ZUGFeRD format.
- From 1 January 2027: businesses with prior-year turnover above 800,000 euros must send e-invoices.
- From 1 January 2028: all remaining VAT-registered businesses must send e-invoices.
- A PDF invoice is no longer a recognised structured e-invoice under the 2025 rules.
- Dates and thresholds are subject to change; always verify against the latest BMF (Bundesministerium der Finanzen) guidance.
Which format to use
For B2G invoices, XRechnung is the required format, submitted through the relevant portal. For B2B invoices, both XRechnung (pure XML) and ZUGFeRD/Factur-X (a hybrid PDF with embedded XML) are recognised structured formats under EN 16931. ZUGFeRD has the advantage of being human-readable as a PDF while carrying the machine-readable data inside.
What if you invoice both public and private clients?
Most small businesses with public-sector contracts alongside private clients need to handle both formats. The underlying data model is the same (EN 16931), so a tool that generates both XRechnung and ZUGFeRD covers both scenarios without duplicate data entry.
The E-Rechnung app creates both XRechnung XML (CII or UBL 2.1) and ZUGFeRD/Factur-X PDFs to EN 16931 on your iPhone, with all required fields validated as you type. For more on the format difference, see our guide to XRechnung vs ZUGFeRD. This article is general information and does not constitute tax or legal advice.
Common questions
- When did B2B e-invoicing become mandatory in Germany?
- From 1 January 2025, all VAT-registered German businesses must be able to receive structured e-invoices. Sending obligations are phased in from 2027 onward, depending on turnover. This is general information, not legal or tax advice.
- What is the difference between B2B and B2G e-invoicing?
- B2G (business-to-government) requires XRechnung format submitted through designated portals and has been mandatory for federal suppliers since 2020. B2B (between private businesses) requires structured e-invoices in EN 16931-compliant formats and is being phased in from 2025.
- Does a PDF count as an e-invoice in Germany?
- No. From 2025, a PDF without embedded structured XML data is not recognised as a structured e-invoice under German law. Only formats conforming to EN 16931, such as XRechnung and ZUGFeRD, qualify. This is general information, not legal advice.