German e-invoicing compliance
This page is the frame for everything else in this guide: what German law asks of your company, by when, and what that means for the way you invoice. The platform screens come after — they only matter once you know which duty applies to you.
What the law asks, and when
| Duty | Who it applies to | From when |
|---|---|---|
| Be able to receive a structured e-invoice | Every domestic business, for domestic B2B | 1 January 2025, with no transitional relief |
| Issue structured e-invoices | Businesses whose previous-year total turnover exceeded EUR 800,000 | 1 January 2027 |
| Issue structured e-invoices | All remaining domestic businesses | 1 January 2028 |
The receive duty is already in force and it has no grace period. The issuing duty arrives in two waves, and which wave you fall into is decided by your own turnover in the preceding calendar year (§ 27 Abs. 38 UStG).
The obligation applies only when both parties are established in Germany — seat, place of management, or an establishment that takes part in the transaction (§ 14 Abs. 2 UStG). A company that is merely VAT-registered in Germany, without any of those, is outside it.
Until your issuing duty starts, you may still send paper or a non-conforming electronic format with your customer's consent. That consent is the reason a customer accepts a PDF from you today and may refuse it in 2027 — nothing about your invoice changed, their duty did.
The statutory basis is the Wachstumschancengesetz of 27 March 2024, which rewrote § 14 UStG. The tax administration's reading is the BMF circular of 15 October 2024, extended by the circular of 15 October 2025, and the BMF also keeps a FAQ that is updated far more often than the circulars.
What counts as an e-invoice
German law recognises two kinds of invoice. An elektronische Rechnung is issued, transmitted and received in a structured electronic format that allows electronic processing. Everything else — a PDF, a scanned image, paper — is a sonstige Rechnung (§ 14 Abs. 1 UStG).
A structured format qualifies if it complies with EN 16931 and the syntax list of Directive 2014/55/EU, or if you and your customer agree on a format from which the VAT-mandatory particulars can be extracted correctly and completely into an EN 16931-compliant form.
The formats the BMF names are XRechnung and the hybrid ZUGFeRD from version 2.0.1 onwards, excluding the MINIMUM and BASIC-WL profiles, which are not EN 16931-compliant. Using a German format is not compulsory — any EN 16931-compliant European format qualifies.
A PDF is not an e-invoice. Sending one is a way of delivering a document, not a way of complying. Where the transaction falls under the mandate, the structured file is the invoice.
In a hybrid invoice — a PDF carrying the XML — the structured part governs. Every VAT-mandatory particular has to be in the XML; a note in the XML pointing at the PDF layer does not satisfy the requirement.
What is outside the obligation
Supplies exempt under § 4 Nr. 8–29 UStG, small-amount invoices up to EUR 250 under § 33 UStDV, and travel tickets under § 34 UStDV are outside the issuing obligation. Small businesses (Kleinunternehmer) may always issue a sonstige Rechnung instead, under § 34a UStDV.
Being outside the obligation is not the same as being unable to. If your customer processes structured invoices, sending one is still the easier path for both sides.
Germany has no central platform
This matters most if you also invoice in France or Italy. Germany operates a decentralised, post-audit model: there is no state clearance platform, no real-time reporting of B2B invoices, and no government portal an ordinary B2B invoice has to pass through. Transmission routes named by the tax administration include e-mail, an electronic interface, and shared access to a storage location — Peppol is one such route, not a legal requirement in itself.
Two consequences for your day-to-day work: there is no authority status to wait for after you send a domestic B2B invoice, and there is no lifecycle you have to report back. The invoice status you see on the platform is delivery and payment information, not a government response.
A German reporting system has been announced as a political intention, and the EU-level obligation under Directive (EU) 2025/516 applies to intra-EU B2B supplies from 1 July 2030. Neither changes what you have to do in 2026.
Public-sector invoicing is a separate regime
Invoicing a public authority came first and follows its own rules. At federal level the E-Rechnungsverordnung requires the XRechnung standard, transmission through a federal portal, and the Leitweg-ID as mandatory invoice content. The federal platforms were consolidated: the ZRE became unavailable during Q4 2025 and the federal administration now receives through the OZG-RE.
Germany is a federal state, so Land and municipal authorities have their own implementing law and their own portals. Do not assume the federal rules apply to a city or a Land authority — ask the buyer.
See Leitweg-ID and public buyers for what this means when you create the invoice.
Retention
A copy of every invoice you issue and every invoice you receive must be kept for eight years, counted from the end of the calendar year in which the invoice was issued (§ 14b Abs. 1 UStG). Eight years replaced the former ten, and applies to invoices whose retention period had not expired on 31 December 2024.
For an e-invoice, at least the structured part must be kept unaltered and remain machine-evaluable for the tax authority. The GoBD amendment of 14 July 2025 confirms that retaining the structured part alone is sufficient for a hybrid invoice — you are not obliged to keep the PDF layer as well.
Decide explicitly where your archive of record lives. If it is not the platform, make sure whatever you export is the structured file and not only a human-readable rendering.