E-Invoicing in Germany 2026: Rules, Deadlines and Formats
Short answer: e-invoicing in Germany is mandatory for sales between German businesses, phased in from 2025 to 2028. Every German business must already be able to receive e-invoices. Businesses with more than €800,000 turnover must issue them from 1 January 2027, and everyone else from 1 January 2028. A PDF is not an e-invoice: you need XRechnung or a qualifying ZUGFeRD file. If you’re based outside Germany with no office there, the rule doesn’t apply to your sales, even if you hold a German VAT number.
This guide is for small businesses selling to other businesses in Germany: German shops and studios, and foreign sellers wondering whether they’re caught. For how e-invoicing works across the EU, see the EU e-invoicing overview.
Germany e-invoicing at a glance
Section titled “Germany e-invoicing at a glance”| Mandate status | Live for receiving since 1 January 2025. Issuing phased in from 2027 |
| Who’s in scope | Domestic B2B sales where both seller and buyer are established in Germany |
| Key dates | Receive: 1 January 2025. Issue: 1 January 2027 (prior-year turnover over €800,000), 1 January 2028 (everyone) |
| Required formats | XRechnung, ZUGFeRD 2.0.1 or later (not MINIMUM or BASIC-WL), or other EN 16931-compatible formats agreed between the parties |
| Network / platform | None prescribed. Email, Peppol, EDI or a portal all work |
| Penalties | No specific e-invoice fine. A non-compliant invoice can put the buyer’s input VAT deduction at risk |
| Non-residents | Out of scope unless they have a German establishment involved in the sale |
| Legal basis | Section 14 and section 27(38) of the VAT Act (UStG), introduced by the Growth Opportunities Act (Wachstumschancengesetz) |
Does the German e-invoice rule apply to you?
Section titled “Does the German e-invoice rule apply to you?”| Your situation | Must you issue e-invoices? | Must you receive them? |
|---|---|---|
| German business selling to German businesses, 2026 turnover over €800,000 | From 1 January 2027 | Yes, since 2025 |
| German business selling to German businesses, 2026 turnover €800,000 or less | From 1 January 2028 | Yes, since 2025 |
| German small business using the Kleinunternehmer exemption | No, never required | Yes, since 2025 |
| German business selling only to consumers | No | Yes, for invoices from German suppliers |
| Foreign business with no German establishment (with or without a German VAT number) | No | No |
| Foreign business with a German branch or office involved in the sale | Yes, on the same dates | Yes |
| Selling to German public bodies | Yes, already (see B2G) | n/a |
The legal basis: the Growth Opportunities Act
Section titled “The legal basis: the Growth Opportunities Act”Germany’s e-invoicing rules come from the Growth Opportunities Act (Wachstumschancengesetz) of 27 March 2024, which rewrote section 14 of the VAT Act from 1 January 2025. Since then German law has two kinds of invoice:
- E-invoice (E-Rechnung): an invoice “issued, transmitted and received in a structured electronic format” that allows electronic processing. The format must follow the European standard EN 16931, or be agreed between the parties and convertible into it without losing data.
- Other invoice (sonstige Rechnung): everything else, meaning paper, PDF, Word, a scan or an image.
For a sale from one German business to another, the invoice must be an e-invoice. The phase-in dates are in section 27(38) of the VAT Act.
Timeline: 2025, 2027 and 2028
Section titled “Timeline: 2025, 2027 and 2028”| Period | Receiving | Issuing |
|---|---|---|
| 1 January 2025 to 31 December 2026 | Every German business must be able to receive e-invoices | Paper always allowed. PDF and other formats allowed if the customer agrees |
| 1 January to 31 December 2027 | Required | E-invoice required if your 2026 turnover was over €800,000. If it was €800,000 or less, paper or PDF (with consent) is still allowed. EDI allowed for everyone, with consent |
| From 1 January 2028 | Required | E-invoice required for everyone (exceptions below) |
2025 and 2026: receiving is mandatory
Section titled “2025 and 2026: receiving is mandatory”Since 1 January 2025 you can’t refuse an e-invoice from a German supplier. The Federal Ministry of Finance’s e-invoicing FAQ says an email inbox is enough to receive them. You don’t need special software to receive, though you’ll want something that can display the XML in readable form, because that file, not any PDF, is the invoice.
There are no exceptions to receiving. Small businesses under the Kleinunternehmer exemption and businesses that only make VAT-exempt sales must be able to receive too.
2027: the €800,000 test
Section titled “2027: the €800,000 test”For sales made in 2027, you can keep sending paper or PDF invoices (PDF with the customer’s consent) only if your total turnover in 2026 was €800,000 or less. Turnover here means the Gesamtumsatz as defined in section 19(2) of the VAT Act, essentially your taxable sales for the year, minus certain exempt sales and sales of fixed assets.
Above €800,000, e-invoices are mandatory for your German B2B sales from 1 January 2027.
EDI until the end of 2027
Section titled “EDI until the end of 2027”Businesses that already exchange invoices by EDI (common with large retailers and in manufacturing) can keep using an EDI format that doesn’t meet EN 16931 until 31 December 2027, with the customer’s consent, whatever their turnover. After that, an EDI format still counts if the required data can be extracted into an EN 16931 format without loss.
2028: everyone
Section titled “2028: everyone”From 1 January 2028 every German business must issue e-invoices for domestic B2B sales, except for the cases in the next section.
What counts as an e-invoice in Germany
Section titled “What counts as an e-invoice in Germany”| Format | Counts? | Notes |
|---|---|---|
| XRechnung | Yes | Germany’s national EN 16931 format, in UBL or CII syntax. Also required for most public sector invoices |
| ZUGFeRD 2.0.1 or later: profiles EN 16931 (COMFORT), EXTENDED, XRECHNUNG and BASIC | Yes | A PDF with embedded XML. The XML is the invoice |
| ZUGFeRD: profiles MINIMUM and BASIC-WL | No | They don’t carry all the data a VAT invoice needs |
| Factur-X | Yes, in the qualifying profiles | Technically the same as ZUGFeRD 2.x |
| Peppol BIS Billing 3.0 | Yes | EN 16931 in UBL |
| EDI (EDIFACT and similar) | With consent | Allowed if the data can be converted into EN 16931 without loss. Non-compliant EDI allowed until 31 December 2027 |
| PDF, Word, scan, paper | No | These are “other invoices” |
The format list comes from question 7 of the Finance Ministry FAQ. Every mandatory invoice detail (names, addresses, VAT numbers, invoice number, date, description, amounts, rates) must be in the structured part itself. Pointing to an attachment or the PDF view isn’t enough.
You don’t need Peppol in Germany. You can send an e-invoice by email, over Peppol, through EDI or through a customer portal. What matters is the file, not the channel.
Exceptions: small invoices, tickets and small businesses
Section titled “Exceptions: small invoices, tickets and small businesses”These invoices can always be sent as paper or PDF, even after 2028:
| Exception | Rule | Legal basis |
|---|---|---|
| Small-amount invoices | Total of €250 or less, including VAT | Section 33 UStDV |
| Travel tickets | Tickets for passenger transport | Section 34 UStDV |
| Small business exemption | Invoices from businesses using the Kleinunternehmer exemption | Section 34a UStDV |
| VAT-exempt sales | Sales exempt under section 4 nos. 8 to 29 UStG (for example most financial, insurance and medical services) | Section 14(2) UStG |
| Sales to consumers | B2C sales are outside the e-invoice rule | Section 14(2) UStG |
The €250 limit applies to the total of each invoice, including VAT.
Worked examples
Section titled “Worked examples”A small German maker selling wholesale
Section titled “A small German maker selling wholesale”A candle maker in Leipzig had €310,000 turnover in 2026, mostly through its own Shopify store, with some wholesale. A Hamburg gift shop orders 120 candles at €9.00:
- Net: 120 × €9.00 = €1,080.00
- VAT at 19%: €205.20
- Total: €1,285.20
| Invoice date | What the maker can send |
|---|---|
| 2026 | PDF by email, as the shop agreed to PDFs |
| 2027 | Still PDF with consent, because 2026 turnover was €800,000 or less |
| From 1 January 2028 | An e-invoice (XRechnung or ZUGFeRD), sent by email or any other channel |
A follow-up order of 15 candles (€135.00 net, €160.65 including VAT) is under €250, so it can stay a PDF even in 2028. The maker’s consumer orders don’t need e-invoices at all.
A mid-sized brand over €800,000
Section titled “A mid-sized brand over €800,000”A Munich furniture brand had €1.4 million turnover in 2026. It sells a table and chairs to a Cologne hotel for €12,000.00 net plus €2,280.00 VAT, total €14,280.00, invoiced in February 2027.
Because 2026 turnover was over €800,000, this must be an e-invoice. A PDF would not be a valid invoice under section 14, and the hotel could have trouble deducting the €2,280.00 of input VAT until the brand sends a correct e-invoice.
A UK brand with a German VAT number
Section titled “A UK brand with a German VAT number”A UK skincare brand stores stock in a German 3PL warehouse and is registered for German VAT. It has no office or staff in Germany. It sells 200 units at €15.00 to a Berlin pharmacy chain: €3,000.00 net plus €570.00 VAT (19%), total €3,570.00.
The brand is not established in Germany: a VAT number and stock in a warehouse run by someone else usually don’t amount to a fixed establishment, which needs its own staff and equipment. So it can issue a PDF in 2027 and 2028. The Finance Ministry’s FAQ says a foreign business in this position can state on the invoice that it has no German establishment, and the buyer can rely on that if it takes normal commercial care.
Foreign businesses: are you in scope?
Section titled “Foreign businesses: are you in scope?”The e-invoice obligation applies only when both the seller and the business customer are established in Germany. Under section 14(2) of the VAT Act, a business is established in Germany if it has its registered office, its management, or a fixed establishment that takes part in the sale there.
- A German VAT number alone doesn’t count. Many foreign sellers register for VAT in Germany because of stock held there, imports or events. That doesn’t put them in scope.
- A German branch or office does count, for the sales it’s involved in.
- Selling to German businesses from abroad: your German customer is established in Germany, but you aren’t, so the obligation doesn’t apply. The usual cross-border rules apply instead, normally the reverse charge. See Selling to EU businesses.
- Buying from German suppliers: if you’re a foreign business without a German establishment, German suppliers don’t have to send you an e-invoice.
US SaaS companies selling to German businesses are covered in more detail in Does your US SaaS need to charge VAT in Germany?
The Finance Ministry letters
Section titled “The Finance Ministry letters”The Federal Ministry of Finance (BMF) has published three administrative letters (BMF-Schreiben) on the rules. They bind the tax offices and explain how the law is applied.
| Letter | What it covers |
|---|---|
| 15 October 2024 | The first full guidance: definitions, scope, formats, the transition rules, archiving. Amended the VAT Application Decree (UStAE) |
| 15 October 2025 | Updated the 2024 letter. Introduced three types of error: a format error (the file breaks the EN 16931 syntax) means the document is not an e-invoice at all. Confirmed every mandatory detail must be in the structured part, and that credit notes (self-billing) are covered. A customer that can’t or won’t accept an e-invoice has no right to demand a PDF instead |
| 15 October 2026 | Supplementary rules ahead of 2027. Reported changes include: the description of the goods or services must be in the structured part from 1 January 2027 (“services as per attachment” won’t do); simplifications for advance and final invoices, construction work and gross-price invoices; a business-rule error only matters if it affects a required VAT detail; and issuing a PDF instead of an e-invoice is not an administrative offence. E-invoices issued up to 31 December 2026 that follow the earlier letters won’t be challenged |
The October 2026 letter is very recent. The details above come from the Ministry’s published letter as summarised by German tax advisers. Check the full text before changing your processes.
Archiving: the 8-year rule and GoBD
Section titled “Archiving: the 8-year rule and GoBD”- Keep invoices for 8 years, counted from the end of the year the invoice was issued (section 14b UStG).
- Keep the structured file itself, unchanged, in the form you received or sent it. Converting the XML into a PDF or image and keeping only that isn’t enough.
- The GoBD are the Finance Ministry’s rules on keeping digital records. The July 2025 amendment, in force from 14 July 2025, says keeping the structured part of an e-invoice is enough. You only need to keep the human-readable part too (for example the PDF of a ZUGFeRD file) if it contains extra tax-relevant information, such as booking notes.
Penalties
Section titled “Penalties”Germany has no specific fine for sending a PDF where an e-invoice is required. According to the October 2026 Finance Ministry letter, doing so is not an administrative offence under section 26a UStG.
The consequences are indirect but real:
- The invoice doesn’t meet section 14. Where an e-invoice is mandatory, a PDF is not a proper invoice. In a tax audit, your customer’s input VAT deduction can be questioned until a corrected e-invoice is issued. Expect larger customers to reject PDFs from 2027 for that reason.
- Not issuing an invoice at all, or not on time, and not keeping invoices for 8 years, are offences under section 26a, with fines of up to €5,000.
Invoicing the German public sector (B2G)
Section titled “Invoicing the German public sector (B2G)”Selling to the German federal government has required e-invoices since 27 November 2020, under the E-Invoicing Ordinance (E-Rechnungsverordnung), for direct contracts worth €1,000 net or more. The federal states (Länder) have their own rules, which vary.
- Format: XRechnung is the standard. Check with the authority if you want to use another EN 16931 format.
- Channel: invoices to the federal administration go through the OZG-RE portal, which now also covers the former central portal ZRE, as the two were merged. You can type invoices into the web form, upload files, or send by Peppol or email after a free registration. See the federal e-invoicing site.
- Leitweg-ID: a routing ID that tells the system which office the invoice is for. Your public customer gives it to you, and it goes in the buyer reference field (BT-10). You don’t need one for B2B invoices.
How GoodVat helps
Section titled “How GoodVat helps”E-invoicing sits on top of the VAT basics: whether you’re established in Germany, whether you need a German VAT number, which rate applies and who accounts for the VAT. GoodVat Global Tax Compliance handles that side:
- Maps your obligations in Germany and the rest of the EU, including whether the e-invoice rule applies to you
- Registers you for German VAT, OSS or IOSS where you need it
- Calculates the right VAT at checkout, including the reverse charge for business customers
- Files your returns in Germany, the rest of the EU, the UK and US states
GoodVat is not an e-invoicing platform or Peppol access point. If you need to send XRechnung or ZUGFeRD files, you’ll do that through your invoicing software.
Is e-invoicing mandatory in Germany?
Section titled “Is e-invoicing mandatory in Germany?”Yes, in stages. Since 1 January 2025 every business established in Germany must be able to receive e-invoices from other German businesses. Issuing e-invoices becomes mandatory on 1 January 2027 for businesses with prior-year turnover above €800,000, and on 1 January 2028 for everyone else.
Can I still send PDF invoices in Germany?
Section titled “Can I still send PDF invoices in Germany?”Until 31 December 2026, yes, to German business customers who agree to receive them. During 2027 only businesses whose 2026 turnover was €800,000 or less can keep sending PDFs with consent. From 1 January 2028 a PDF no longer meets the rules for domestic B2B sales, except for invoices of €250 or less and a few other exceptions.
Which formats count as an e-invoice in Germany?
Section titled “Which formats count as an e-invoice in Germany?”XRechnung and ZUGFeRD from version 2.0.1 count, except the ZUGFeRD profiles MINIMUM and BASIC-WL. Factur-X, the French twin of ZUGFeRD, works the same way. Other formats, including EDI, are allowed if both sides agree and the required data can be extracted into a format that follows the European standard EN 16931.
Do foreign companies have to issue e-invoices in Germany?
Section titled “Do foreign companies have to issue e-invoices in Germany?”Not if they have no establishment in Germany. The obligation only applies when both the seller and the business customer are established in Germany, through a head office, management or a fixed establishment involved in the sale. A German VAT registration on its own doesn’t count as being established.
Do small businesses (Kleinunternehmer) need e-invoicing in Germany?
Section titled “Do small businesses (Kleinunternehmer) need e-invoicing in Germany?”They don’t have to issue e-invoices. Businesses using the small business exemption (Kleinunternehmerregelung) can always send paper or PDF invoices. But like every German business, they must be able to receive e-invoices, and an email inbox is enough for that.
What is the penalty for not sending an e-invoice in Germany?
Section titled “What is the penalty for not sending an e-invoice in Germany?”There is no specific fine for sending a PDF where an e-invoice is required, and the Finance Ministry’s October 2026 letter says it is not an administrative offence under section 26a of the VAT Act. The real risk is that the invoice doesn’t meet the invoicing rules, which can put your customer’s input VAT deduction at risk until a correct e-invoice is issued.
Is a small invoice under €250 exempt from e-invoicing in Germany?
Section titled “Is a small invoice under €250 exempt from e-invoicing in Germany?”Yes. An invoice whose total, including VAT, is €250 or less can always be sent as paper or PDF, even after 2028. The same applies to travel tickets. Both are set out in the VAT Implementing Ordinance (UStDV).
Related guides
Section titled “Related guides”- E-invoicing in Europe: every EU mandate, formats and the ViDA timeline
- XRechnung explained: the format, the Leitweg-ID and how to send one
- ZUGFeRD explained: versions, profiles and which ones count in Germany
- Selling to Germany: rates, rules and compliance: German VAT rates, invoicing and customs
- Does your US SaaS need to charge VAT in Germany?: German VAT for software sellers
- Do US sellers need to charge VAT in Germany?: physical goods, IOSS and Amazon FBA
- E-invoicing in Belgium: the Peppol mandate in force since 2026
- E-invoicing in France: the 2026 and 2027 deadlines
- Selling to EU businesses: reverse charge and VAT number checks