The obligation to receive e-invoices has applied since 1 January 2025 and comes with no transitional period. For issuing them, the transitional rules are being phased out in stages, and the next date is 1 January 2027. Companies with more than 800,000 euros in turnover in 2026 must be able to send e-invoices from that day.
Many companies have set up an email inbox for incoming invoices and treated the matter as closed. That is rarely enough: incoming e-invoices must also be readable, verifiable, approvable, postable and storable in their original structured form.
The three stages
| Period | Who may still issue other invoices? |
|---|---|
| until 31.12.2026 | every issuer. Paper without the recipient’s consent, simple electronic formats such as PDF only with it |
| until 31.12.2027 | only businesses with prior-year turnover of up to 800,000 euros. The same applies to EDI procedures that do not meet the requirements for an e-invoice |
| from 01.01.2028 | no one. Between businesses established in Germany, the e-invoice becomes the default unless an exemption applies |
What counts is the turnover of the preceding year. Cross the threshold in 2026 and the obligation starts on 1 January 2027, not in 2028.
What qualifies as an e-invoice
Under § 14 (1) sentence 3 UStG (the German VAT Act), an e-invoice is issued, transmitted and received in a structured electronic format that allows electronic processing. In Germany, two formats meet that definition: „XRechnung”, pure XML, and „ZUGFeRD” from version 2.0.1, excluding the MINIMUM and BASIC-WL profiles. A PDF sent by email remains an other invoice within the meaning of sentence 4 of the same provision.
With hybrid formats such as „ZUGFeRD”, the structured XML part prevails over the readable image. Where the two diverge, the visual part may count as a separate other invoice and trigger an incorrect VAT statement under § 14c UStG. This is the most expensive of the silent errors in this area, because the invoice on screen looks entirely correct.
An „XRechnung” is a plain XML file and therefore unreadable to the human eye. The receiving side needs a viewer or a visualisation in the ERP system. Without it, an incoming invoice cannot realistically be checked.
When an e-invoice is mandatory
For case-by-case assessment, one fixed sequence works well:
- Is this a taxable supply of goods or services?
- Is the recipient a taxable person acting for their business?
- Are both parties established in Germany?
- Does no exemption apply?
- Is no transitional rule still available?
Only if all five answers are yes is the e-invoice mandatory.
Who owes the tax is irrelevant here. Reverse-charge cases under § 13b UStG, for instance construction services or sales of scrap and precious metals, fall within the obligation. So do the margin scheme for travel services under § 25 UStG and the differential taxation scheme under § 25a UStG, once the other conditions are met.
Exemptions from the obligation to issue
- invoices to private individuals
- small-value invoices up to 250 euros under § 33 UStDV
- transport tickets under § 34 UStDV
- businesses under the small-business scheme („Kleinunternehmer”), § 19 UStG
These exemptions cover issuing only. Every business established in Germany must be able to receive e-invoices, including those under the small-business scheme. Issuing one voluntarily remains possible in all of these cases.
The cases that hold things up in practice
Cash purchases above 250 euros. The small-value threshold is crossed more often than the invoice run suggests: hotel stays, fuel for construction machinery, larger purchases from builders’ merchants or wholesalers. A small dedicated process with three clear roles pays off here: who requests the e-invoice, who checks it, who archives it?
Continuing obligations such as rent, leasing or maintenance. A single e-invoice for the first part-performance period is often sufficient, provided the underlying contract is attached or the content makes clear that this is a recurring invoice. If mandatory details change, the amount for example, a new invoice may be required.
Advance payment and final invoices are technically harder to produce than standard invoices in many software packages. Test them early and separately.
Corrected invoices. Where the original invoice had to be an e-invoice, so does the correction. A mere change to the taxable amount under § 17 UStG, a cash discount for instance, requires no correction.
Archiving and interfaces
The structured part must be retained unchanged in its original format. For hybrid formats, it must be documented which components are stored, how, and how they will be made readable again. The „GoBD” requirements (the German principles for keeping and retaining records) continue to apply in full: traceability, immutability and machine evaluability.
In practice, problems arise less often when creating the invoice than at the handovers between inbox, document management, ERP, payment approval and archive. One question clarifies more than any inventory of systems: which system is ultimately the authoritative data source for the VAT return?
What to complete by the end of 2026
- Assign responsibility. One person or department coordinates the changeover technically and in substance.
- Identify the outgoing invoices affected, in particular continuing obligations, advance payments, credit notes and cash purchases above 250 euros.
- Check prior-year turnover. Above or below 800,000 euros?
- Define a receiving channel and assign responsibility for checking and approval.
- Test the software on „XRechnung” and „ZUGFeRD”, including validation, visualisation and archiving, not just sending.
- Update master data: taxable-person status, VAT ID, billing address and preferred format for each customer and supplier.
- Run tests with key business partners, including corrections and cancellations.
- Train staff and update the process documentation.
The later the changeover starts, the more a pragmatic approach makes sense: receipt, checking, posting and archiving have to work reliably first. Automation and interface optimisation can follow.
How e-invoicing fits with day-to-day bookkeeping is set out under German Accounting & Reporting, and the tax filing obligations under German Tax & Compliance. The most frequent individual questions are answered in our e-invoicing question catalogue.
Sources: §§ 14, 14a, 14c, 17, 19, 25, 25a and 27 (38) UStG as amended by the „Wachstumschancengesetz” of 27.03.2024; §§ 33 and 34 UStDV; BMF circular of 15.10.2024, III C 2 – S 7287-a/23/10001 :007.