Germany's E-Invoicing Mandate 2025-2028: Deadlines, Who's Affected & Exemptions

Germany's e-invoicing mandate requires domestic companies to use structured electronic invoices in business-to-business (B2B) transactions. Since 1 January 2025, every company must be able to receive e-invoices. The obligation to issue is phased in: from 1 January 2027 for companies with more than EUR 800,000 prior-year turnover, and from 1 January 2028 for all others. The legal basis is the Growth Opportunities Act (Wachstumschancengesetz), which anchors the rules in the German VAT Act.

This guide explains the deadlines, exactly who is affected, which exemptions apply, what happens on non-compliance and how to prepare step by step.

Key takeaways

• Since 1 Jan 2025: all domestic B2B companies must be able to receive e-invoices.

• From 1 Jan 2027: obligation to issue for companies with prior-year turnover above EUR 800,000.

• From 1 Jan 2028: obligation to issue for all domestic B2B companies.

• An e-invoice is a structured data set (XRechnung, ZUGFeRD) based on EN 16931. A PDF is not an e-invoice.

• Exemptions: small-value invoices up to EUR 250, travel tickets, B2C transactions. Small businesses are exempt from issuing but must still be able to receive.

What is the e-invoicing mandate?

The e-invoicing mandate is the legal requirement that invoices between domestic companies (B2B) be issued, transmitted and received in a structured electronic format. It was introduced by the Growth Opportunities Act; the concrete rules sit in the German VAT Act and are specified by a circular from the Federal Ministry of Finance (BMF).

The key distinction: an e-invoice is a machine-readable data set based on the European standard EN 16931 (such as XRechnung or ZUGFeRD). A plain PDF does not qualify as an e-invoice; it counts as an "other invoice".

When does what apply? The 2025, 2027 and 2028 deadlines

• **1 Jan 2025: all domestic B2B companies; Must be able to receive** e-invoices. A transition period applies to issuing.
• **until 31 Dec 2026**: issuers; May still send paper or (with the recipient's consent) PDF.
• **1 Jan 2027: companies with prior-year turnover above EUR 800,000; Must issue** e-invoices. Smaller companies get one more year.
• **1 Jan 2028: all domestic B2B companies; Full obligation to issue**. EDI procedures must also be EN 16931-conformant.

Core point: the receiving obligation already applies to everyone. For issuing, prior-year turnover decides whether 2027 or 2028 is your deadline.

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Who is affected by the e-invoicing mandate?

It applies to transactions between domestic companies (B2B) where both parties are established in Germany. Concretely:

• Receiving: every company, regardless of size, has had to accept e-invoices since 2025. An email inbox is enough to receive them.
• Issuing: the phased deadline applies (2027 above EUR 800,000 prior-year turnover, 2028 for all).

Not affected are pure B2C transactions (services to private consumers) and cross-border transactions abroad (these fall under the separate EU initiative ViDA, "VAT in the Digital Age").

Which exemptions apply?

• Small-value invoices up to EUR 250 may still be issued as other invoices (e.g. paper or PDF).
• Travel tickets are exempt.
• Services to private consumers (B2C) are not covered.
• Small businesses under the German small-business rule are exempt from the obligation to issue, but must still be able to receive e-invoices.

What exactly is an e-invoice?

An e-invoice is a structured data set based on EN 16931. Two formats are common in Germany:

• XRechnung: pure XML, used mainly in public procurement.
• ZUGFeRD: a hybrid format, a PDF with embedded XML.

How to check an e-invoice for format and mandatory fields in detail is covered in How to Validate an E-Invoice: ZUGFeRD & XRechnung Checking. What invoice verification covers in general is explained in the foundational invoice verification guide.

How processing works:

Watch processing in the video →

What happens on non-compliance?

• If you cannot receive: from 2025 the issuer has fulfilled their obligation by sending the e-invoice. A company that cannot receive technically has no claim to a paper or PDF alternative and risks delays and problems with input-tax deduction.
• If you do not issue an e-invoice after your deadline: a non-conformant invoice is not considered proper for VAT purposes. This can endanger the recipient's input-tax deduction and be challenged in a tax audit.

In short: the mandate is not a mere formality; it has direct tax and financial consequences.

How to prepare (checklist)

1. Ensure receiving: set up an inbox or interface that accepts ZUGFeRD and XRechnung.
2. Establish checking: validate e-invoices for format (EN 16931) and mandatory fields.
3. Connect processing: hand approved documents to the ERP (SAP, DATEV) without a media break.
4. Prepare issuing: set up creation in an e-invoice format well before your applicable deadline (2027 or 2028).
5. Archiving: retain e-invoices in an audit-proof way (typically ten years).

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Checking and processing e-invoices automatically

The mandate is one side; efficient implementation is the other. As e-invoice volume grows, an automated, AI-based check that validates format and content in one step pays off. How that works is covered in Automate Invoice Verification with AI.

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Frequently asked questions (FAQ)

Who is obligated to use e-invoices?

Since 1 January 2025, all domestic B2B companies must be able to receive them. For issuing, the obligation applies from 1 January 2027 for companies with more than EUR 800,000 prior-year turnover and from 1 January 2028 for all other domestic B2B companies.

When does the e-invoicing mandate apply?

The receiving obligation has applied since 1 January 2025. The issuing obligation is phased in from 2027 (turnover above EUR 800,000) and 2028 for all.

Which companies must send e-invoices from 1 January 2027?

Companies whose total turnover in the previous calendar year (2026) exceeded EUR 800,000. Smaller companies only have to issue from 2028.

Is a PDF an e-invoice?

No. A plain PDF is an "other invoice", not an e-invoice. Only a structured data set based on EN 16931 (XRechnung, ZUGFeRD) meets the requirement.

What happens if I do not issue an e-invoice?

After your applicable deadline, a non-conformant invoice is not considered proper for VAT purposes. This can endanger the recipient's input-tax deduction and be challenged in an audit.

Are there exemptions from the e-invoicing mandate?

Yes: small-value invoices up to EUR 250, travel tickets and B2C services. Small businesses are exempt from issuing but must still be able to receive.

Note: this article is for general information and does not replace tax or legal advice. The applicable statutory rules and the BMF circular on e-invoicing are authoritative.

About ADVISORI FTC GmbH: ADVISORI builds AI-based, compliant solutions for the automated checking and processing of e-invoices, operated in Germany. Certified to ISO 27001, ISO/IEC 42001 and SOC 2 Type II.