Germany B2B E-Invoicing Mandate (XRechnung)
Since 1 January 2025 every German business must be able to receive structured e-invoices (EN 16931 — XRechnung or ZUGFeRD) for domestic B2B transactions. Issuing them becomes mandatory in stages: from 2027 for businesses with prior-year turnover above €800,000, and from 2028 for everyone. Paper and other electronic formats (PDF, EDI) remain usable only during the transition and only with the recipient's consent.
Facts last verified: 2026-07-12
Deadlines & phases
| Phase | Who is affected | Deadline | What is required |
|---|---|---|---|
| Receipt obligation | All German businesses (B2B) | 2025-01-01 | Must be able to receive and process EN 16931 e-invoices; a normal business email address is enough — no dedicated mailbox required |
| General transition ends | All businesses | 2026-12-31 | Last date paper or non-compliant electronic invoices (e.g. plain PDF) may be sent with recipient consent |
| Issuance — large businesses | Prior-year (2026) turnover above €800,000 | 2027-01-01 | Must issue structured e-invoices for domestic B2B; a narrower EDI carve-out can still apply through 2027 |
| Issuance — everyone | All businesses (adds those with 2026 turnover ≤ €800,000) | 2028-01-01 | Structured e-invoices mandatory for all domestic B2B invoices; extended transition and EDI carve-out end |
What counts as an e-invoice in Germany
Only structured formats conforming to EN 16931 qualify: XRechnung (pure XML, originally the public-sector standard, now equally valid for B2B) and ZUGFeRD from version 2.0.1 (a hybrid PDF/A-3 with embedded XML) — except ZUGFeRD's MINIMUM and BASIC-WL profiles, which don't carry enough structured line-item data to count on their own. A plain PDF sent by email is NOT an e-invoice under the new rules — that is the single most common misunderstanding.
During the general transition (2025-2026), paper, plain PDF and other electronic formats remain usable with the recipient's consent. A narrower rule then lets invoices transmitted via EDI procedures continue for transactions carried out in 2026 or 2027 — even without full EN 16931 data extraction — again only with the recipient's agreement; that carve-out, and the extended transition for smaller businesses, both close on 31 December 2027.
The timeline that actually matters
The receipt obligation is already live: since January 2025 you cannot refuse a compliant e-invoice from a German supplier, which means your accounts-payable process needs to parse XML invoices today. The general transition for issuing runs through 31 December 2026 for all businesses; issuance then becomes mandatory in two steps — from 2027 for businesses with prior-year turnover above €800,000, from 2028 for everyone, with a one-year extended transition (to end-2027) for smaller businesses in between.
Practical exemptions exist — small-value invoices up to €250 (§33 UStDV), transport tickets (§34 UStDV), and supplies by Kleinunternehmer under the small-business VAT regime (exempted from issuing, though not from receiving, e-invoices since the 2024 Jahressteuergesetz) — but they are narrow. Verify against the current BMF FAQ rather than assuming your case qualifies.
Preparing ERP and accounting systems
Receiving is the near-term project: inbound XRechnung/ZUGFeRD invoices should land in an automated pipeline — parsed, validated, matched and archived in a GoBD-compliant way — not printed out and re-typed. Issuing is a data-model project: your invoicing system must produce complete EN 16931 XML with correct tax categorization, buyer references and payment terms.
Dictode builds XRechnung/ZUGFeRD generation and inbound-invoice automation into custom ERPs and its accounting platform — including GoBD-compliant archiving and the Peppol connectivity many German enterprises now request from suppliers.
Compliance readiness checklist
- Confirm your issuance deadline: prior-year (2026) turnover above or below €800,000
- Set up an inbound channel that can receive, validate and archive XML e-invoices (live since 2025 — a normal email address is sufficient)
- Choose your outbound format: XRechnung (pure XML) or ZUGFeRD ≥ 2.0.1 (hybrid, excluding the MINIMUM/BASIC-WL profiles)
- Upgrade invoice data quality: EN 16931 mandatory fields, tax categories, Leitweg-ID for B2G
- Ensure GoBD-compliant archiving of the structured XML (not just a PDF rendering)
- Check whether the small-value (€250), ticket, Kleinunternehmer or tax-exempt-supply exemptions apply before assuming full scope
- Inform customers/suppliers about your transition plan and consent requirements
Frequently Asked Questions
Is a PDF invoice still allowed in Germany?
Only temporarily and only with the recipient's consent. A plain PDF is not a structured e-invoice under EN 16931; once the issuance mandate applies to you (2027 or 2028), domestic B2B invoices must be XRechnung or ZUGFeRD.
What is the difference between XRechnung and ZUGFeRD?
XRechnung is pure XML, originally required in public-sector (B2G) invoicing. ZUGFeRD (from 2.0.1, excluding its MINIMUM and BASIC-WL profiles) is a hybrid: a human-readable PDF/A-3 with the same structured XML embedded. Both satisfy the B2B mandate.
When must my company issue e-invoices?
From 1 January 2027 if your prior-year turnover exceeds €800,000; from 1 January 2028 for all businesses. The obligation to receive e-invoices has applied to every German business since 1 January 2025.
Does the mandate apply to invoices to consumers (B2C)?
No — the mandate covers domestic B2B transactions. B2C and cross-border invoices are outside the current German mandate, though the EU's ViDA reforms will shape cross-border rules.
Are there exemptions?
Yes, narrow ones: invoices up to €250 (§33 UStDV), transport tickets (§34 UStDV), and supplies by Kleinunternehmer under the small-business VAT regime, plus certain tax-exempt supplies. Verify your case against current BMF guidance before relying on an exemption.
What is GoBD and why does it matter here?
GoBD are Germany's rules for digital bookkeeping and archiving. The structured XML of an e-invoice is the tax-relevant original — it must be archived immutably and machine-readably, not just as a printed or PDF copy.
Did anything change for the mandate in 2026?
No deadline moved. The BMF's FAQ update (November 2025, summarized by KPMG in January 2026) and the revised EN 16931-1:2026 invoice standard published mid-2026 both clarified transmission-channel and data-quality details — the core 2025 / 2027 / 2028 dates are unchanged. Always check the current official BMF FAQ before relying on any date.
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Official sources
- BMF — E-Rechnung FAQ (official)
- XRechnung standard (KoSIT)
- KPMG — Germany: Updated FAQ on mandatory e-invoicing (Jan 2026)
- EY — Germany finalizes e-invoicing administrative guidance
- IHK Dresden — E-Rechnung: Pflicht, Fristen, Ausnahmen (EDI-Übergangsregelung)
- ZUGFeRD Community — Neue EN 16931-1:2026 veröffentlicht
This guide is general information, not tax or legal advice. Verify requirements with the official sources below or your advisor.