E-invoice obligation in Germany: deadlines and checklist

What it is about

With the Growth Opportunities Act (Wachstumschancengesetz) Germany introduced the e-invoice for transactions between domestic businesses (B2B). The rules are in section 14 of the VAT Act. The obligation does not apply to invoices to private persons.

The deadlines at a glance

The obligation takes effect in stages. There are transitional rules for issuing invoices.

• Since 1 January 2025: all businesses must be able to receive and process e-invoices. A mailbox that accepts such invoices is the first step.
• Until 31 December 2026: invoices may still be issued on paper or as another electronic invoice (for example a simple PDF), for electronic invoices with the recipient’s consent.
• Until 31 December 2027: this transitional rule continues for businesses whose total turnover in the previous year was at most 800,000 euros.
• From 1 January 2028: all businesses must issue e-invoices for domestic B2B transactions.

Exceptions

No e-invoice is needed for invoices to private persons, for small-amount invoices up to 250 euros, for tickets and for certain tax-exempt transactions. Small businesses under the small-business scheme must be able to receive e-invoices but are generally not obliged to issue them. Whether your case falls under an exception, please clarify with your tax adviser.

Checklist to get started

Prepare step by step:

• Set up a mailbox for invoices that accepts XML files and ZUGFeRD PDFs
• Check whether your accounting software can read and create e-invoices
• Test-check a received e-invoice and show it as a readable PDF
• Clarify retention: the machine-readable original is archived, generally for eight years
• Practise issuing before your deadline: create a test invoice as XRechnung or ZUGFeRD and validate it
• Keep master data complete: tax number or VAT ID, address and, for authorities, the Leitweg-ID

• Validate e-invoice
• E-invoice to PDF
• Create e-invoice (XRechnung)

What happens with errors?

A faulty or formally incomplete invoice can be rejected by the recipient and, in unfavourable cases, put the input tax deduction at risk. That is why it pays to check e-invoices before sending or before booking them.

This guide does not replace tax or legal advice. Deadlines and exceptions may change. Please check the current position with your tax adviser or the Federal Ministry of Finance.

Frequently asked questions

From when must I be able to receive e-invoices?

Since 1 January 2025. This applies to all domestic businesses, including small ones.

From when must I issue e-invoices?

By 1 January 2028 at the latest. For businesses with higher turnover (over 800,000 euros in the previous year) the transition ends already on 31 December 2026.

Is a PDF by e-mail enough?

Only during the transition period and with the recipient’s consent. Afterwards a structured e-invoice such as XRechnung or ZUGFeRD is required.

Does the obligation apply to small businesses under the small-business scheme?

They must be able to receive e-invoices but are generally not obliged to issue them.

More guides

• What is an e-invoice?
• Validate an e-invoice

These guides do not replace tax or legal advice. For questions about your own case please ask your tax adviser.