Germany E-Invoicing Requirements 2026: Complete B2B Guide

Last reviewed: 5 August 2026

Germany e-invoicing requirements changed on 1 January 2025 for transactions between domestic businesses. Since that date, a German electronic invoice—an E-Rechnung—must contain structured data that allows electronic processing. Every domestic business must already be capable of receiving this type of invoice, although transitional rules mean many suppliers can continue issuing paper invoices or ordinary PDF invoices during 2026.

This guide explains what applies in 2026, when the transition periods end, which transactions and businesses are covered, the accepted formats, important exemptions, storage rules and the practical steps businesses should take.

Germany e-invoicing timeline at a glance

The transition affects the obligation to issue an E-Rechnung. It does not postpone the receiving requirement. A business that chooses to continue sending PDFs in 2026 must still be capable of receiving XRechnung, ZUGFeRD or another qualifying format from suppliers.

The Federal Ministry of Finance updated its official e-invoicing FAQ in March 2026. Businesses should use that page and the Ministry’s formal guidance when checking individual questions.

Read the Federal Ministry of Finance e-invoicing FAQ.

What is an E-Rechnung in Germany?

Since 1 January 2025, an E-Rechnung is an invoice that is created, transmitted and received in a structured electronic format and allows electronic processing. Its tax-relevant invoice information must be contained in structured data fields.

This definition separates a compliant electronic invoice from an ordinary digital document:

• Structured XML invoice: can qualify as an E-Rechnung.
• Hybrid invoice with structured XML and a readable PDF: can qualify when the structured component meets the requirements.
• Ordinary PDF without structured data: is an “other invoice,” not an E-Rechnung.
• Scanned paper invoice, image or Word document: is not a qualifying structured E-Rechnung.

The timing of the underlying supply matters. According to the Ministry’s FAQ, a supply completed before 1 January 2025 can follow the former definition even if its invoice is created later.

Who is considered a domestic business?

The German B2B rules generally concern transactions between domestic entrepreneurs. An entrepreneur is treated as domestic when it has its registered office, place of management or a fixed establishment involved in the transaction in Germany. Where there is no registered office, the entrepreneur’s residence or usual place of stay may be relevant.

The term entrepreneur is broad and can include companies, sole traders, freelancers, landlords, doctors, small-business operators and organisations carrying out business activities. Inclusion as an entrepreneur does not mean every transaction must use an E-Rechnung; the transaction must also fall within the invoicing rules and not qualify for an exemption.

A foreign business that is VAT-registered in Germany but has no German establishment involved in the transaction is not automatically treated as a domestic business for this purpose. Cross-border and fixed-establishment questions can be complex, so businesses should document their position and obtain advice when necessary.

Which transactions are covered?

The mandate generally applies where one domestic entrepreneur supplies another domestic entrepreneur and German VAT rules require an invoice. It is therefore primarily a domestic B2B requirement.

Private consumers are outside these domestic B2B rules. The system also does not turn every document exchanged between two organisations into a mandatory electronic invoice. The VAT nature of the transaction, the parties involved and the available exemptions all matter.

Main exemptions from issuing an E-Rechnung

The Federal Ministry of Finance identifies several situations in which a structured E-Rechnung is not required. They include:

• invoices to private consumers, known as B2C transactions;
• many VAT-exempt supplies, including certain financial services and exempt property rentals;
• small-value invoices with a gross total of no more than €250;
• tickets that qualify as invoices under the applicable rules;
• supplies made by businesses using the German Kleinunternehmer small-business scheme;
• supplies to legal persons that are not acting as entrepreneurs; and
• certain property-related supplies to final consumers.

An exemption from issuing a structured invoice does not always remove the duty to receive one. In particular, a Kleinunternehmer does not have to issue an E-Rechnung for its exempted supplies under the current rule, but it must still be able to receive E-Rechnungen from suppliers. If the business moves from the small-business scheme to normal taxation, the general issuing requirements can then apply.

Receiving electronic invoices in 2026

Every domestic business has needed to ensure receipt of E-Rechnungen since 1 January 2025. The Ministry states that an email inbox is sufficient as a basic receiving method. A business does not have to buy a large invoicing platform merely to satisfy the technical ability to receive a file.

However, receiving a file is only the beginning of a reliable process. The business should be able to:

• recognise supported XML and hybrid invoice formats;
• open or visualize invoices for staff who need to read them;
• check supplier and invoice data;
• route the file to the correct approver or accounting system;
• protect the original structured component from alteration; and
• store the invoice for the applicable retention period.

The law does not require the recipient to automate every accounting step. A business can use a simple process, but it still needs appropriate storage and controls.

Issuing invoices during 2026 and 2027

From 1 January 2025 through 31 December 2026, every invoice issuer can use the general transition. During this period, a supplier may issue a paper invoice or another electronic invoice instead of an E-Rechnung.

The distinction between paper and an ordinary electronic file is important:

• a paper invoice can be used during the transition without electronic-format consent;
• an ordinary electronic invoice such as a PDF sent by email requires the recipient’s consent; and
• a qualifying E-Rechnung does not depend on the recipient agreeing to receive the structured format where the statutory receiving requirement applies.

For 2027, the extended turnover transition is available when the issuer’s total turnover in the preceding calendar year does not exceed €800,000. In addition, an EDI process that does not yet satisfy the E-Rechnung definition may continue through the end of 2027 under the relevant transition.

Businesses should not treat these periods as a reason to delay all preparation. Customers may request structured invoices before the final deadline, and suppliers may already send them.

Accepted electronic invoice formats

A qualifying format should generally meet the European EN 16931 standard or otherwise allow the correct and complete extraction of the invoice information required under German VAT law.

XRechnung

XRechnung is a structured XML format commonly used in Germany. It contains machine-readable data but normally does not include a built-in PDF presentation. Staff may therefore need a viewer to display it in a familiar invoice layout.

ZUGFeRD

ZUGFeRD is a hybrid format. It combines a readable PDF with embedded structured XML data. The Ministry states that ZUGFeRD from version 2.0.1 can meet the E-Rechnung requirements, except for the MINIMUM and BASIC-WL profiles.

Other agreed formats and EDI

Businesses may agree on another format, including a suitable EDI process, when the format permits correct and complete extraction of the invoice information required by the German VAT Act. A commercial file called “electronic” is not automatically compliant; its structure and extractability must satisfy the legal definition.

Technical validation is not itself an automatic condition for VAT recognition, but the Ministry recommends validation because it can identify missing fields, incorrect formats and logical errors before an invoice is sent.

Which invoice information must be structured?

The mandatory VAT invoice information must appear in the structured part of the E-Rechnung. Simply placing required information in an unstructured PDF attachment and referring to it from the XML is generally insufficient.

The structured description of the supply must make the transaction clear and verifiable. Supporting detail can be provided in an attached document where appropriate. For example, detailed timesheets may be attached, but the structured invoice still needs enough information to identify the service.

When a hybrid invoice contains different information in its XML and readable PDF sections, the structured data is the leading component. Businesses should therefore validate and, where possible, independently visualize the XML rather than relying only on the PDF image.

How can an E-Rechnung be transmitted?

Germany’s domestic B2B law does not prescribe one compulsory transmission network or central government clearance portal. Depending on the agreement between the supplier and customer, an E-Rechnung can be transmitted through:

• email;
• a software interface or API;
• a customer or supplier portal;
• a shared storage location within a corporate group;
• an established EDI connection; or
• a network such as Peppol.

Peppol can be useful, but it is not generally mandatory for every domestic B2B invoice. The parties should agree on a secure and practical delivery method and confirm which formats, addresses and identifiers they accept.

Is a Leitweg-ID required for B2B invoices?

A Leitweg-ID is generally not required for an ordinary B2B E-Rechnung. It is an identifier used when addressing invoices to German public authorities. Some technical formats include a buyer-reference field; a private business may use an internal identifier or an appropriate placeholder where permitted.

Do not copy a B2G requirement into every commercial invoice. Ask the customer which reference it requires and distinguish an authority’s Leitweg-ID from an ordinary customer or supplier number.

B2B and B2G invoicing are different

The domestic B2B requirements under the German VAT Act operate alongside separate rules for invoicing public authorities. Federal B2G electronic invoicing has applied to relevant suppliers since November 2020 under the federal E-Invoicing Ordinance, and public bodies can require particular portals, formats and identifiers.

A supplier invoicing a federal authority may need XRechnung, the authority’s Leitweg-ID and a federal receiving platform. State and local public-sector requirements can differ. Always follow the procurement documents and the instructions of the receiving authority.

Visit the official federal B2G e-invoicing information portal.

Storage and retention requirements

For VAT purposes, German businesses must generally retain copies of incoming and outgoing invoices for eight years. For an E-Rechnung, at least the structured component must be stored intact in its original form.

A readable copy can be useful for daily work, but converting an XML invoice to PDF and keeping only the PDF would remove the original structured data. A safe process preserves the original file, associated attachments, relevant validation results and any audit information required by the business’s accounting controls.

The Ministry’s 2025 GoBD update explains that retaining the structured part is sufficient where it contains the relevant information. A human-readable component also needs to be retained if it contains additional or different tax-relevant information.

Read the official GoBD update for electronic invoices.

How to prepare your business

1. Confirm scope. Identify domestic German entities, business activities, transaction types and exemptions.
2. Create a receiving address. Use a monitored invoice inbox or another agreed channel and communicate it to suppliers.
3. Choose supported formats. Decide whether the business will use XRechnung, ZUGFeRD or another compliant format.
4. Check software readiness. Ask whether current accounting software can create, validate, visualize, import and archive structured invoices.
5. Review turnover. Determine whether the €800,000 transition can apply during 2027, using the correct previous-year turnover.
6. Clean customer data. Confirm legal names, addresses, tax numbers, VAT IDs, email addresses and buyer references.
7. Test realistic invoices. Test standard invoices, credit notes, attachments, recurring invoices and corrections.
8. Protect original files. Configure storage so that structured invoices remain intact and retrievable throughout the retention period.
9. Document exceptions. Explain how staff should handle small-value invoices, B2C sales, public-sector customers and exempt supplies.
10. Train staff and suppliers. Give finance, purchasing and sales teams a clear process for sending, receiving and rejecting invoice files.

Common mistakes to avoid

• Calling every PDF an E-Rechnung. An ordinary PDF does not contain the required structured data.
• Ignoring the receiving requirement. Domestic businesses have needed to receive E-Rechnungen since January 2025.
• Confusing €800,000 with a permanent exemption. It is a transition threshold for 2027, not a general permanent exemption.
• Assuming Kleinunternehmer do nothing. They may be exempt from issuing but still need to receive structured invoices.
• Keeping only a visual PDF. The original structured component must be retained.
• Applying B2G identifiers to every B2B invoice. A Leitweg-ID is generally associated with public authorities.
• Waiting until 2028 to test. Customers and suppliers can already use structured invoices.

Frequently asked questions

Is a PDF invoice compliant in Germany in 2026?

An ordinary PDF is not an E-Rechnung under the definition used since 2025. It can still be issued during the general 2026 transition if the recipient agrees to that electronic format. Paper invoices can also be used during the transition.

Does every business need to receive E-Rechnungen?

Domestic businesses have been required to ensure receipt since 1 January 2025. The official guidance says an email inbox can be sufficient as the basic receiving channel.

Must a Kleinunternehmer issue E-Rechnungen?

Supplies made under the current German small-business scheme are exempt from the structured issuing requirement. However, the business must still be capable of receiving E-Rechnungen.

Is Peppol mandatory in Germany?

Peppol is one possible transmission method, but Germany’s domestic B2B rules do not generally require every invoice to pass through Peppol or one central portal. Public-sector contracts may have different transmission requirements.

What happens if the XML and PDF show different data?

For a hybrid invoice, the structured component is the leading part. If it conflicts with the readable image, the structured data is decisive under the Ministry’s guidance.

How long must electronic invoices be stored?

For VAT purposes, incoming and outgoing invoices are generally retained for eight years. The structured component must remain intact in its original form.

Does Germany already require real-time reporting of B2B invoices?

The Ministry describes a future transaction-based reporting system, but additional legislation will be required. The current E-Rechnung rules should not be presented as an existing central clearance or real-time reporting mandate.

Are cross-border invoices covered?

The core mandate concerns transactions between domestic entrepreneurs. A foreign VAT registration alone does not necessarily make a business domestic where it has no relevant German establishment. Businesses should obtain advice for complex fixed-establishment or cross-border arrangements.

Official sources

• Federal Ministry of Finance: E-Rechnung questions and answers, updated March 2026
• Federal Ministry of Finance: formal guidance dated 15 October 2025
• Federal government portal: invoicing public authorities

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Visit the Invoice Mandates homepage for more international deadlines. You can also compare Germany with our guides to Belgium e-invoicing requirements and France e-invoicing requirements.