Germany's B2B E-Invoicing Mandate Explained: Who, When and What Counts
Since January 2025, every business in Germany has been required to be able to receive electronic invoices for domestic B2B transactions. The obligation to issue them follows in stages, and a plain PDF no longer counts as an e-invoice. Here is what the mandate actually says, who it affects and when each deadline hits.
What changed with the Wachstumschancengesetz
The German Wachstumschancengesetz (Growth Opportunities Act) introduced mandatory electronic invoicing for domestic business-to-business transactions. The key redefinition: since 2025, an E-Rechnung in the legal sense is only an invoice in a structured electronic format that complies with the European standard EN 16931, or a format agreed between the parties that allows correct extraction of the required data. A PDF you typed in Word and exported is no longer an electronic invoice under this definition. It counts as a sonstige Rechnung, an 'other invoice', and other invoices are being phased out for domestic B2B.
The most common compliant formats in Germany are XRechnung, a pure structured XML format, and ZUGFeRD (from version 2.0.1, excluding the MINIMUM and BASIC-WL profiles), a hybrid PDF with embedded XML. Both follow EN 16931.
The timeline: receive first, issue later
- 1 January 2025: every German business must be able to receive e-invoices for domestic B2B transactions. There is no size exemption for receiving. In practice an email inbox that can accept an XML or PDF attachment is enough to start.
- 2025 to 2026: transition period for issuing. Paper invoices and, with the recipient's consent, plain PDFs remain permitted for domestic B2B.
- 1 January 2027: businesses with more than 800,000 euros turnover in the previous calendar year must issue e-invoices for domestic B2B supplies. Smaller businesses may still use paper or, with consent, other electronic formats until the end of 2027, and EDI procedures also remain permitted through 2027 under transitional rules.
- 1 January 2028: the issuing obligation applies to essentially all domestic B2B invoices, regardless of turnover, as currently legislated.
These dates reflect the law as it stands. Transitional details have already been clarified several times by the Federal Ministry of Finance (BMF), so check the current BMF guidance or ask your Steuerberater before relying on a specific deadline.
Who is affected, and who is not
The mandate covers invoices between businesses (B2B) where both the supplier and the customer are established in Germany. It applies to Kleinunternehmer as recipients too: even if you use the small business scheme under section 19 UStG, you must be able to receive e-invoices. Under current rules, Kleinunternehmer are exempt from the obligation to issue e-invoices, though they may do so voluntarily.
- B2C invoices to private consumers are not covered by the mandate.
- Kleinbetragsrechnungen, small-amount invoices up to 250 euros gross, remain exempt from the e-invoice obligation.
- Fahrausweise (tickets) are also exempt.
- Certain tax-exempt supplies are excluded as well.
- Cross-border invoices to customers outside Germany are not part of this domestic mandate, though EU-wide digital reporting (ViDA) is on the horizon.
What you should do now
Receiving is the immediate duty: make sure you can accept, open and archive structured invoices, and remember that GoBD rules require you to archive the structured data itself, not just a printout. For issuing, the practical advice is to switch before your deadline rather than on it. Many larger customers already request XRechnung or ZUGFeRD today, and public-sector clients have required XRechnung for years.
You do not need an accounting suite to comply. The E-Rechnung app creates XRechnung XML and ZUGFeRD/Factur-X PDFs to EN 16931 directly on your iPhone, with every required field validated as you type. If you are unsure which format to send, see our guide to XRechnung vs ZUGFeRD.
Not tax advice
This article is general information about the German e-invoicing mandate as understood in 2026. It is not tax or legal advice. Deadlines and transitional rules can change, so confirm your specific obligations with your Steuerberater or legal advisor.
Common questions
- Is a PDF invoice still allowed in Germany?
- For domestic B2B, a plain PDF is no longer an e-invoice in the legal sense. During the transition it may still be used with the recipient's consent, but from 2027/2028 most businesses must issue structured e-invoices such as XRechnung or ZUGFeRD. B2C invoices are unaffected.
- Do small businesses and freelancers have to send e-invoices?
- All businesses, including Kleinunternehmer, must be able to receive e-invoices since 2025. The obligation to issue starts 2027 for businesses above 800,000 euros prior-year turnover and 2028 for the rest, while Kleinunternehmer under section 19 UStG are currently exempt from issuing. Check current BMF guidance.
- When exactly does e-invoicing become mandatory in Germany?
- Receiving: since 1 January 2025 for all businesses. Issuing: 1 January 2027 for businesses with over 800,000 euros previous-year turnover, and 1 January 2028 for essentially all domestic B2B invoices, as currently legislated.
- Are there exceptions to the German e-invoice mandate?
- Yes. Small-amount invoices up to 250 euros gross, tickets, certain tax-exempt supplies and invoices to private consumers (B2C) are exempt. Cross-border invoices are outside this domestic mandate.