At a glance
- Since 1 January 2025, every business in Germany must be able to receive e-invoices.
- From 1 January 2027, businesses with more than €800,000 in prior-year revenue must issue them; from 1 January 2028, all businesses must.
- A PDF file is not an e-invoice. What counts is a structured format under EN 16931 – such as XRechnung or ZUGFeRD.
- Invoices up to €250, travel tickets and invoices to consumers are exempt.
What an e-invoice is – and what it isn’t
Since § 14 of the German VAT Act (UStG) was rewritten by the Growth Opportunities Act (Wachstumschancengesetz), an e-invoice is an invoice that is issued, transmitted and received in a structured electronic format that allows electronic processing. The benchmark is the European standard EN 16931. So what matters is not that the invoice is digital, but that a machine can read it without anyone retyping it.
A PDF file, a scan or an invoice in the body of an email is therefore no longer an e-invoice but an “other invoice” (sonstige Rechnung). The mandatory details under § 14(4) UStG remain unchanged – they will simply sit in data fields.
The deadlines at a glance
| From | What applies |
|---|---|
| 1 January 2025 | All businesses must be able to receive e-invoices. They may still issue paper and PDF invoices (PDF only with the recipient’s consent). |
| 1 January 2027 | Businesses with more than €800,000 in total revenue in the previous year must issue e-invoices. Smaller businesses may continue to use paper and – with consent – PDF until the end of 2027. |
| 1 January 2028 | All businesses must issue e-invoices for domestic transactions. The transitional rule for existing EDI procedures also ends: EDI remains permissible only if the EN 16931 data can be extracted from it. |
The mandate applies to transactions between businesses that are both established in Germany. Suppliers based abroad with no establishment in Germany are not subject to the obligation to issue e-invoices – but their German customers must still be able to receive e-invoices.
XRechnung or ZUGFeRD?
Both formats comply with the standard; they differ in structure:
| XRechnung | ZUGFeRD | |
|---|---|---|
| Structure | pure XML file | PDF/A-3 with an embedded XML file |
| Human-readable | only with a viewer | yes, like a familiar PDF |
| Typical use | invoices to public authorities, large companies | mid-sized businesses, mixed recipients |
| Points to note | Authorities often also require a Leitweg-ID (routing ID) | The MINIMUM and BASIC-WL profiles are not sufficient; all mandatory details belong in the XML part, and in case of discrepancies it prevails |
By the way, businesses that supply German federal contracting authorities have been issuing e-invoices, mostly as XRechnung, since November 2020 – little changes for them.
Who and what is exempt
- Small-value invoices up to €250 gross and travel tickets may still be sent on paper or as PDF.
- Invoices to consumers are not affected.
- Small businesses under § 19 UStG (the small-business scheme) do not have to issue e-invoices – but they must still be able to receive them.
- Special rules apply to certain VAT-exempt supplies; it is worth reviewing these with your tax advisor.
“Able to receive” – what it means in practice
An email inbox is enough to receive e-invoices. But that alone doesn’t do the job: an XRechnung cannot be checked meaningfully without a viewer, and to deduct input VAT the invoice must be correct in substance. Transferring the data straight into your accounting saves retyping – that is the real benefit of the mandate.
Retention: in the original format, for eight years
E-invoices must be kept in their original format – the XML file for XRechnung and, for ZUGFeRD, at least the XML part; the safest option is to keep the PDF together with the embedded XML. A printout is not sufficient. Since 2025, the retention period for invoices and accounting records has been eight years; the GoBD (German bookkeeping principles) remain the yardstick: unalterable, complete and readable at any time.
Checklist: what you should do now
- Check that your inbox and your accounting system can accept, display and archive e-invoices – this has been mandatory since 2025.
- Establish when you must start issuing them: prior-year revenue above €800,000 means 2027, otherwise 2028.
- Agree on the format with your key customers – ZUGFeRD is the easiest transition because people can still read it.
- Check your invoicing software: does it generate XRechnung or ZUGFeRD at profile EN 16931 or higher, and does it validate the file before sending?
- Define your archiving – audit-proof, in the original format, for eight years.
- Update your process documentation and bring in your tax advisor.
How irot helps
irot ERP will create and receive XRechnung and ZUGFeRD to EN 16931 out of the box – it is in development, and pilot customers can join from the first module. Also on the roadmap: irot Faktura for businesses that only need to write invoices, and irot Archiv for audit-proof storage.
Legal basis and sources
- § 14 UStG as amended by the Growth Opportunities Act of 27 March 2024; transitional rules in § 27(38) UStG
- Federal Ministry of Finance (BMF) circular of 15 October 2024 on the introduction of mandatory e-invoicing, and second BMF circular of 15 October 2025 (additions, including mandatory details in the XML part)
- European standard EN 16931 (semantic data model for electronic invoices)
- § 14b UStG and § 147 of the German Fiscal Code (AO): eight-year retention period since the Fourth Bureaucracy Relief Act (Bürokratieentlastungsgesetz IV)
This guide reflects the legal position as of 12 September 2026 and does not replace tax advice. For your specific situation, your tax advisor is the right person to ask.