E-invoicing in Germany: what changes from 2025 to 2028

Germany is phasing in mandatory B2B e-invoicing. Every business must already be able to receive e-invoices, and sending them becomes compulsory by 2028. Here is what that means for freelancers and small businesses.

Also available in: Deutsch

Quick answer

Since 1 January 2025, every business in Germany must be able to receive e-invoices from other German businesses. Sending them is phased in: paper and PDF invoices are still allowed until the end of 2026, or until the end of 2027 if your previous year’s turnover was €800,000 or less. From 1 January 2028, all domestic B2B invoices must be e-invoices.

Key dates

WhenWhat changes
1 January 2025All businesses must be able to receive e-invoices.
Until 31 December 2026Paper and PDF invoices still allowed (PDF only with the buyer’s agreement).
1 January 2027E-invoices required if your previous year’s turnover was over €800,000.
1 January 2028E-invoices required for all domestic B2B invoices.

What counts as an e-invoice in Germany

An e-invoice is a structured file that follows the European standard EN 16931, so accounting software can read it automatically. Two formats are common:

  • XRechnung: a pure XML file, also required for invoices to public authorities.
  • ZUGFeRD: a PDF with the XML data embedded, so people and software can both read it. Only profiles that meet EN 16931 count (not MINIMUM or BASIC WL).

A PDF made in Word or an invoice generator is not an e-invoice. It counts as an “other invoice” (sonstige Rechnung). You can send e-invoices by email; no special platform is required.

Who is affected, and who isn’t

The rules cover invoices between businesses established in Germany (domestic B2B). They do not apply to:

  • invoices to consumers (B2C)
  • small invoices up to €250 (Kleinbetragsrechnungen) and travel tickets
  • most VAT-exempt supplies

Small businesses using the Kleinunternehmer scheme (§19 UStG) do not have to send e-invoices, but like everyone else they must be able to receive them.

How to prepare

  1. Make sure you can receive, open and archive XML e-invoices now. An email inbox is enough to receive them.
  2. Check your turnover to see whether your deadline is 2027 or 2028.
  3. Agree with clients if you keep sending PDFs during the transition.
  4. Choose a tool that exports XRechnung or ZUGFeRD before your deadline.
  5. Keep e-invoices in their original format for the required retention period.

Where Invoiceferry fits

Invoiceferry can now download your invoice as an XRechnung, free while in beta. Open the invoice editor, fill in the “E-invoice (XRechnung)” section and click Download XRechnung (XML). Before downloading, it checks the file against the main EN 16931 and XRechnung rules and tells you what’s missing. It’s all done in your browser, so your invoices never leave your device. ZUGFeRD (a PDF with the data inside) is next; join the waitlist to hear when it’s ready.

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Frequently asked questions

Is a PDF invoice an e-invoice in Germany?

No. A PDF is an “other invoice”. Only structured formats that meet EN 16931, such as XRechnung or ZUGFeRD, count as e-invoices.

Do freelancers have to receive e-invoices?

Yes. Since 1 January 2025 every business, including freelancers, must be able to receive e-invoices from German businesses. An email address where they can be sent is enough.

Can I create an XRechnung for free?

Yes. Invoiceferry’s invoice editor can download your invoice as an XRechnung (XML), free while in beta, and checks it before you send it.

Do Kleinunternehmer have to send e-invoices?

No. Businesses under the small business scheme (§19 UStG) are exempt from sending e-invoices, but they must still be able to receive them.

What is the difference between XRechnung and ZUGFeRD?

XRechnung is pure XML, readable by software only. ZUGFeRD is a PDF with the same kind of XML data inside, so a person can read it too. Both are valid e-invoices if they meet EN 16931.

What happens if I don’t comply?

An invoice in the wrong format may not meet the legal requirements, so your client can lose their VAT deduction, and penalties are possible. Check with your tax adviser or the Federal Ministry of Finance for your situation.

Related guides

This guide is a summary, not legal or tax advice. Rules and dates change, so check with the tax authority or your adviser. Updated: 2026-11-04.

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