E-Invoicing for the Self-Employed in Germany: What You Need to Know
Germany's e-invoicing mandate is rolling out to everyone in the B2B space, including freelancers and the self-employed. Understanding the timeline, the formats involved and what you need in place is the first step.
What the mandate covers
The German e-invoicing obligation applies to domestic business-to-business (B2B) transactions between companies established in Germany. It does not initially apply to B2C invoices or small amounts below 250 euros.
The timeline
- 1 January 2025: All businesses, including the self-employed, must be able to RECEIVE structured e-invoices (XRechnung or ZUGFeRD).
- 1 January 2027: Businesses with a prior-year turnover above 800,000 euros must SEND structured e-invoices to other German businesses.
- 1 January 2028: All remaining German businesses and self-employed, regardless of turnover, must send structured e-invoices for B2B transactions.
What counts as an e-invoice under the mandate
Under the EN 16931 standard, an e-invoice must be a structured XML file (XRechnung) or a hybrid PDF-plus-XML document (ZUGFeRD). A PDF alone is no longer sufficient after the mandate takes effect. Scanned paper invoices and unstructured PDFs do not qualify.
What Kleinunternehmer status means here
Even if you operate under Kleinunternehmerregelung (Section 19 UStG) and do not charge VAT, the e-invoicing mandate still applies to your B2B invoices once the relevant deadline arrives. VAT exemption and invoicing format requirements are separate matters.
What you should do now
- Set up a method to receive structured e-invoices: an email address and software that can read XRechnung XML or ZUGFeRD PDFs.
- Check whether your clients are already sending e-invoices.
- If you issue invoices to German business clients, plan for the 2027 or 2028 obligation.
This article is general information, not tax or legal advice. For your specific situation, consult a Steuerberater or legal professional. The E-Rechnung app creates both XRechnung XML and ZUGFeRD PDFs with all required fields. For an explanation of the two formats and when each applies, see the guide to XRechnung vs ZUGFeRD.
Common questions
- Do freelancers in Germany have to send e-invoices?
- Yes, from 1 January 2028 (or 2027 if your prior-year turnover exceeded 800,000 euros). The mandate applies to all domestic B2B invoices regardless of business size or structure, including freelancers.
- Does Kleinunternehmer status exempt you from the e-invoicing mandate?
- No. The VAT exemption under Section 19 UStG and the e-invoicing format obligation are separate. Even if you do not charge VAT, you must comply with the structured format for B2B invoices once the relevant deadline applies.
- What is the difference between XRechnung and ZUGFeRD?
- XRechnung is a pure XML file; ZUGFeRD is a hybrid PDF with embedded XML. Both comply with EN 16931. ZUGFeRD is often more practical because the PDF is human-readable while the embedded XML satisfies the machine-readable requirement.