Last reviewed: 16 September 2026
Germany e-invoicing requirements are already partly in force. Since 1 January 2025, businesses established in Germany have generally needed to be able to receive structured electronic invoices for covered domestic B2B transactions. However, Germany is still in a transition period for issuing invoices, which means many suppliers can continue using paper invoices or ordinary PDF invoices during 2026.
The next important change arrives on 1 January 2027. From that date, the general transition available to all invoice issuers ends. Businesses with previous-year turnover of no more than €800,000 receive an additional transition through the end of 2027. After the transition periods expire, structured electronic invoices become the standard requirement for covered domestic B2B transactions.
Quick answer: Germany’s E-Rechnung system is already active for receiving invoices. All domestic businesses generally need to be capable of receiving qualifying structured e-invoices. During 2026, suppliers can still use transitional invoicing methods. From 1 January 2028, structured electronic invoicing becomes mandatory for covered domestic B2B transactions unless a specific exemption applies.
Germany e-invoicing timeline at a glance
| Date | Requirement | Status |
|---|---|---|
| 1 January 2025 | Domestic businesses generally became required to be capable of receiving structured electronic invoices. | In force |
| 1 January 2025 – 31 December 2026 | All invoice issuers may use the general transition and continue issuing other invoices instead of an E-Rechnung. | Current transition |
| 1 January – 31 December 2027 | Businesses whose previous-year turnover does not exceed €800,000 may continue using other invoices. Certain EDI arrangements also receive transitional treatment. | Upcoming |
| From 1 January 2028 | Structured E-Rechnungen become mandatory for covered domestic B2B transactions after the general transition periods expire. | Full rollout |
The transition periods mainly affect the obligation to issue an electronic invoice. They do not postpone the receiving requirement. Businesses have generally needed to be capable of receiving E-Rechnungen since 1 January 2025.
Check the Federal Ministry of Finance E-Rechnung guidance.
What applies in Germany in 2026?
Germany is currently in an important transition year. Structured electronic invoicing has already become part of the German VAT framework, but suppliers are not yet required to use an E-Rechnung for every covered transaction.
Until 31 December 2026, an invoice issuer can generally choose to issue another type of invoice instead.
During this transition:
- a paper invoice can generally still be issued;
- an ordinary PDF or another non-structured electronic invoice can generally be used with the recipient’s consent;
- a compliant structured E-Rechnung can already be issued; and
- domestic businesses must generally remain capable of receiving E-Rechnungen.
This means businesses should not treat 2026 as a period in which no action is required. Suppliers can already send structured invoices, and businesses need a reliable way to receive, read, process and retain them.
What changes on 1 January 2027?
The broad transition available to all invoice issuers ends after 31 December 2026.
During 2027, an additional transition remains available for certain suppliers whose previous-year turnover does not exceed €800,000.
Qualifying businesses can continue issuing other invoices through 31 December 2027. Certain EDI arrangements that do not yet meet the full E-Rechnung definition can also continue under the applicable transition until the end of 2027.
Important: The €800,000 rule is a temporary 2027 transition threshold. It is not a permanent exemption from Germany’s E-Rechnung rules.
What changes on 1 January 2028?
From 1 January 2028, the main transitional periods end.
For covered transactions between domestic businesses, a qualifying structured electronic invoice must then generally be used unless the transaction falls within a specific legal exemption.
Businesses that wait until late 2027 to prepare may face avoidable software, customer-data and workflow problems. Testing structured invoicing during 2026 and 2027 can make the final transition easier.
What is an E-Rechnung in Germany?
Under the German rules applicable since 1 January 2025, an E-Rechnung is an invoice issued, transmitted and received in a structured electronic format that allows electronic processing.
The important difference is the presence of structured machine-readable invoice data.
- Structured XML invoice: can qualify as an E-Rechnung.
- Hybrid PDF plus structured XML: can qualify when the structured data meets the requirements.
- Ordinary PDF: does not qualify as an E-Rechnung by itself.
- Scanned paper invoice: does not qualify as a structured E-Rechnung.
- Image or Word file: does not qualify merely because it is transmitted electronically.
An ordinary PDF is classified as an other invoice under the current German definition.
Is a PDF invoice still allowed in Germany?
Yes, during the applicable transitional period, but it should not be confused with a compliant E-Rechnung.
During 2026, businesses can generally continue sending ordinary electronic invoices such as PDFs if the recipient agrees to that electronic format.
A paper invoice can also generally be used during the 2026 transition.
However, an ordinary PDF does not contain the structured invoice data required by Germany’s long-term E-Rechnung framework.
Who is considered a domestic business?
The core B2B E-Rechnung rules generally concern transactions between entrepreneurs established in Germany.
A business can generally be treated as domestic when it has a relevant:
- registered office in Germany;
- place of management in Germany;
- fixed establishment involved in the transaction; or
- other place of establishment covered by the German rules.
The definition of an entrepreneur is broad and can include companies, freelancers, sole traders, landlords and other persons carrying out business activities.
A foreign company does not automatically become a domestic entrepreneur for this purpose merely because it holds a German VAT registration. Cross-border businesses should review whether a relevant German establishment is involved in the particular transaction.
Which transactions are covered?
The mandatory E-Rechnung framework principally applies to transactions between domestic entrepreneurs where German VAT rules require an invoice.
This makes it primarily a domestic B2B requirement.
The exact treatment depends on:
- the status of the supplier;
- the status of the customer;
- where the businesses are established;
- the VAT treatment of the supply;
- the invoice amount; and
- whether a specific exemption applies.
Main exemptions from mandatory E-Rechnung issuance
Germany provides several situations where a structured E-Rechnung does not need to be issued.
Examples include:
- invoices to private consumers, or B2C transactions;
- many VAT-exempt transactions covered by specified provisions;
- small-value invoices with a gross amount of no more than €250;
- qualifying tickets that count as invoices;
- supplies made by businesses using the German Kleinunternehmer small-business scheme;
- certain supplies to legal persons that are not entrepreneurs; and
- certain property-related supplies to final consumers.
The presence of an exemption should be checked against the actual transaction rather than assumed from the business type alone.
Do Kleinunternehmer need to use E-Rechnungen?
Businesses using Germany’s Kleinunternehmer small-business scheme are generally exempt from the obligation to issue structured E-Rechnungen for qualifying supplies under the current rules.
However, this does not mean they can ignore electronic invoicing completely.
A Kleinunternehmer generally still needs to be capable of receiving E-Rechnungen from suppliers.
If the business later leaves the small-business scheme and becomes subject to normal VAT rules, the general E-Rechnung issuing requirements can apply.
Receiving E-Rechnungen in Germany
The receiving requirement has already been in force since 1 January 2025.
The Federal Ministry of Finance states that maintaining an email inbox can be sufficient as a basic technical method for receiving an E-Rechnung.
Businesses do not necessarily need an expensive specialised platform simply to satisfy the basic receiving requirement.
In practice, however, a useful internal process should allow the business to:
- receive structured XML or hybrid invoice files;
- display the invoice information in a readable form;
- check supplier and tax information;
- send invoices to the correct accounting workflow;
- identify incorrect or invalid invoices;
- protect the original structured file; and
- archive the invoice correctly.
Accepted E-Rechnung formats
Qualifying electronic invoices generally need to meet the requirements of the European standard EN 16931 or use another agreed structured format that allows the correct and complete extraction of the invoice information required under German VAT law.
XRechnung
XRechnung is one of Germany’s widely recognised structured electronic invoice formats.
It is based on machine-readable XML. Because an XRechnung does not necessarily include a normal visual invoice page, businesses may use a viewer to display the XML data in a human-readable format.
ZUGFeRD
ZUGFeRD combines a readable PDF document with embedded structured XML invoice data.
According to Federal Ministry guidance, qualifying ZUGFeRD versions and profiles can meet Germany’s E-Rechnung requirements. The structured XML element remains essential for compliance.
Other structured formats and EDI
Other structured formats can also qualify where they meet the legal requirements and allow correct and complete extraction of the required invoice information.
EDI systems can therefore remain relevant. However, simply calling a file or transmission method “electronic” does not automatically make it an E-Rechnung.
What information must be structured?
The tax-relevant mandatory invoice information must be contained in the structured part of the electronic invoice.
Businesses should not place essential VAT invoice information only inside an unstructured PDF attachment while leaving it out of the structured invoice fields.
Supporting documentation can still be attached where appropriate. For example, detailed timesheets or additional contract information may accompany an invoice, but the structured invoice must still contain enough information to identify and understand the transaction.
What if XML and PDF data are different?
This is particularly important for hybrid invoice formats such as ZUGFeRD.
If the structured XML information conflicts with the visual PDF representation, the structured electronic data is the leading component for the E-Rechnung.
Businesses should therefore validate and process the structured data rather than relying only on what appears visually in the PDF.
How can E-Rechnungen be sent?
Germany does not currently require all domestic B2B invoices to pass through one central government clearance platform.
Depending on the agreement between the parties, a structured electronic invoice may be transmitted through methods such as:
- email;
- accounting or ERP software;
- an API or system integration;
- a supplier or customer portal;
- an EDI connection;
- a shared corporate system; or
- a network such as Peppol.
The parties should agree on suitable addresses, formats and transmission channels.
Is Peppol mandatory in Germany?
No. Peppol can be used to exchange structured electronic invoices, but Germany does not generally require every domestic B2B invoice to pass through the Peppol network.
A business can use another compliant transmission method where the relevant requirements are met.
Public-sector invoicing can involve different rules and technical channels.
Is a Leitweg-ID required for B2B invoices?
A Leitweg-ID is generally associated with invoicing German public authorities rather than ordinary private-sector B2B transactions.
Businesses normally do not need a government Leitweg-ID simply because they exchange an E-Rechnung with another commercial business.
Some invoice formats contain a buyer-reference field. A private customer may provide its own customer number, purchase reference or other identifier for that field.
Germany B2B vs B2G e-invoicing
The domestic B2B E-Rechnung rules should not be confused with Germany’s existing electronic-invoicing rules for public-sector customers.
Federal government suppliers have already faced B2G electronic-invoicing requirements for several years.
A supplier invoicing a public authority may need:
- XRechnung or another accepted public-sector format;
- a Leitweg-ID;
- specific buyer-reference information;
- a government invoice portal; and
- other procurement information required by the authority.
Federal, state and local public-sector requirements can differ, so suppliers should follow the instructions issued by the relevant public customer.
Visit Germany’s official federal B2G e-invoicing portal.
How long must E-Rechnungen be stored?
For German VAT purposes, incoming and outgoing invoices are generally subject to an eight-year retention period.
For a structured electronic invoice, businesses should preserve the original structured component intact.
Converting an XML E-Rechnung into a PDF for viewing and then deleting the XML file is not an appropriate archival approach because the structured original has been lost.
A practical archive can preserve:
- the original XML or hybrid electronic invoice;
- relevant attachments;
- validation results where used;
- processing information;
- accounting links; and
- other records required under the business’s audit procedures.
Does Germany have real-time invoice reporting?
Germany’s current domestic B2B E-Rechnung system should not be described as a central real-time invoice-clearance system.
The Federal Ministry of Finance has explained that structured e-invoicing is also intended to prepare businesses for a future transaction-based electronic reporting system.
However, additional legislation will be required for that reporting system. Businesses should therefore distinguish today’s E-Rechnung obligations from any future digital reporting requirements.
How to prepare for Germany e-invoicing
- Confirm whether the business is in scope. Review German entities, establishments, VAT status and transaction types.
- Set up an E-Rechnung receiving channel. Make sure suppliers know where structured invoices should be sent.
- Review your current invoicing software. Confirm whether it can create, receive, display and archive structured invoice data.
- Select supported formats. Decide whether XRechnung, ZUGFeRD or another compliant format best fits your workflow.
- Review the 2027 transition. Determine whether your previous-year turnover may qualify for the €800,000 transition.
- Clean customer and supplier data. Check company names, addresses, VAT IDs, tax information and invoice-delivery addresses.
- Test structured invoices. Test standard invoices, corrections, credit notes, attachments and recurring transactions.
- Preserve original files. Configure storage so the structured invoice remains intact.
- Document exemptions. Make sure staff understand the treatment of B2C transactions, small-value invoices and Kleinunternehmer.
- Prepare before 2028. Do not wait until the full mandatory phase to test the process.
Common Germany e-invoicing mistakes
- Treating an ordinary PDF as an E-Rechnung. A normal PDF does not contain the required structured data.
- Thinking the mandate starts only in 2028. The receiving requirement has already applied since 1 January 2025.
- Ignoring the end of the 2026 general transition. The broad issuing transition ends on 31 December 2026.
- Treating €800,000 as a permanent exemption. It provides an additional 2027 transition for qualifying issuers.
- Assuming Kleinunternehmer do not need to prepare. They generally still need to be able to receive E-Rechnungen.
- Deleting the original XML after creating a PDF. The structured original should be preserved.
- Assuming Peppol is mandatory. Germany currently permits different compliant transmission methods.
- Using a Leitweg-ID for every B2B invoice. It is mainly associated with invoicing public authorities.
- Confusing E-Rechnung with future real-time reporting. Germany does not currently operate the domestic B2B mandate as a universal central clearance system.
Frequently asked questions
Is e-invoicing mandatory in Germany in 2026?
Germany’s E-Rechnung framework is already partly mandatory. Domestic businesses have generally needed to be capable of receiving structured electronic invoices since 1 January 2025. However, the general transition still allows suppliers to issue other invoices during 2026.
Can a business still send PDF invoices in 2026?
Yes. During the general transition through 31 December 2026, an ordinary electronic invoice such as a PDF can generally still be used where the recipient agrees to receive that format. However, the PDF is classified as an other invoice rather than an E-Rechnung.
What happens on 1 January 2027?
The general transition available to all invoice issuers ends. Qualifying businesses whose previous-year turnover does not exceed €800,000 can continue using other invoices during 2027.
What happens on 1 January 2028?
After the transition periods end, structured E-Rechnungen generally become mandatory for covered domestic B2B transactions unless a specific exemption applies.
Does every business have to receive E-Rechnungen?
Domestic entrepreneurs generally need to be capable of receiving qualifying E-Rechnungen. This receiving requirement has applied since 1 January 2025.
Is an email inbox enough to receive E-Rechnungen?
The Federal Ministry of Finance states that providing an email inbox can be sufficient as a basic receiving method. Businesses may still choose specialised accounting or invoice-management systems for processing and storage.
Is a normal PDF an E-Rechnung?
No. Since 1 January 2025, an ordinary unstructured PDF is classified as an other invoice. A qualifying E-Rechnung must contain structured machine-readable data.
Can Germany use ZUGFeRD invoices?
Yes. Appropriate ZUGFeRD versions and profiles can qualify where the structured invoice component meets Germany’s requirements.
Is XRechnung accepted?
Yes. XRechnung is a structured XML-based invoice format commonly used in Germany and can meet the E-Rechnung requirements.
Is Peppol compulsory?
No. Peppol is one possible transmission network, but it is not generally mandatory for every domestic German B2B E-Rechnung.
Do Kleinunternehmer have to issue E-Rechnungen?
Supplies made under the applicable Kleinunternehmer small-business scheme are generally exempt from mandatory structured issuance. However, the business still needs to be capable of receiving E-Rechnungen.
How long must E-Rechnungen be retained?
German businesses generally need to retain incoming and outgoing invoices for eight years for VAT purposes. The structured component of an E-Rechnung should remain intact.
Does Germany currently have a central invoice-clearance platform?
No. Germany’s domestic B2B rules currently allow several transmission methods and do not require every invoice to pass through one national real-time clearance portal.
Official German e-invoicing resources
- Federal Ministry of Finance: E-Rechnung Questions and Answers
- Federal Ministry of Finance: Official E-Rechnung Guidance
- German Federal Government: B2G Electronic Invoicing
Related country guides
- Belgium E-Invoicing Requirements
- France E-Invoicing Requirements
- Poland KSeF E-Invoicing Requirements
- Italy E-Invoicing Requirements
- Spain E-Invoicing Requirements
- Singapore InvoiceNow Requirements
- UAE E-Invoicing Requirements
Disclaimer: This article provides general educational information and does not constitute tax, accounting or legal advice. German e-invoicing rules, technical guidance and transitional requirements can change. Confirm important compliance decisions with the Federal Ministry of Finance, the responsible tax authority or a qualified German professional.