E-Rechnung Deadlines in Germany: A Timeline Overview
Germany's e-invoicing mandate under the Wachstumschancengesetz does not take effect all at once. Different deadlines apply depending on whether you are receiving or issuing invoices and how large your business is.
The core obligation: receiving vs issuing
The mandate distinguishes between receiving structured e-invoices and issuing them. The receiving obligation applies first and to everyone. The issuing obligation is phased by business size.
1 January 2025: receiving obligation for all
From the start of 2025, all businesses registered for VAT in Germany (B2B transactions) must be technically capable of receiving structured e-invoices in a compliant format such as XRechnung or ZUGFeRD. A business that cannot receive these formats risks being unable to process supplier invoices that arrive in the new format.
1 January 2027: issuing obligation for larger businesses
Businesses with a prior-year turnover above 800,000 euros must issue structured e-invoices for all B2B transactions from 1 January 2027. PDF invoices sent by email will no longer be sufficient for these businesses from that date.
1 January 2028: issuing obligation for all remaining businesses
From 1 January 2028, all remaining VAT-registered businesses (including small businesses, freelancers and sole traders) must issue structured e-invoices for B2B transactions within Germany. At this point the mandate is fully in force across all business sizes.
What counts as a compliant e-invoice
A compliant e-invoice must follow the European standard EN 16931 and be in a machine-readable structured format. In Germany, XRechnung and ZUGFeRD (profile EN 16931 or higher) both meet this standard. A PDF invoice, even one sent digitally, does not qualify as a structured e-invoice.
Transactions not covered by the mandate
The mandate applies to B2B transactions between VAT-registered businesses with a place of supply in Germany. Consumer invoices (B2C), small-amount invoices under 250 euros, and certain other transactions may be exempt. Cross-border transactions follow separate rules under EU directives.
This article is general information only and does not constitute tax or legal advice. For your specific situation, consult a tax advisor (Steuerberater). E-Rechnung helps you read and validate XRechnung and ZUGFeRD files on your iPhone. For a comparison of the two main German e-invoice formats, see the guide to XRechnung vs ZUGFeRD.
Common questions
- When does Germany's e-invoicing mandate start?
- The receiving obligation starts on 1 January 2025, meaning all VAT-registered businesses must be able to receive structured e-invoices. The issuing obligation is phased: larger businesses (over 800,000 euros turnover) must comply from 2027, and all remaining businesses from 2028. This is general information, not legal advice.
- Do freelancers in Germany need to issue e-invoices?
- Freelancers and sole traders registered for VAT must issue structured e-invoices for B2B transactions from 1 January 2028. The receiving obligation, however, applies from 2025. This is general information; consult a tax advisor for your specific situation.
- What happens if I cannot receive e-invoices by January 2025?
- From 2025, your suppliers may send structured e-invoices in XRechnung or ZUGFeRD format. If your systems cannot process these, you may face administrative difficulties. Working with a compliant invoicing tool or accounting software before the deadline is advisable. This is general information, not legal advice.