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E-invoicing mandate · From 2025 · Germany

German e-invoicing
mandate 2025

From 2025, all German businesses must be able to receive e-invoices. Find out what this means – and how to open XRechnung & ZUGFeRD immediately.

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Free · No upload · No login · XRechnung & ZUGFeRD

The e-invoicing mandate timeline

2025 from 1 Jan.
Receiving obligation for all businesses All VAT-registered businesses in Germany must be able to receive and process EN 16931 e-invoices.
2027 from 1 Jan.
Sending obligation for large businesses Businesses with annual revenue exceeding €800,000 must send e-invoices. Smaller businesses have a transition period and must comply from 2028.
2028 from 1 Jan.
Sending obligation for all businesses All VAT-registered businesses must send e-invoices for B2B transactions – regardless of company size.

Which formats count as an e-invoice?

Only formats based on the European standard EN 16931 qualify as statutory e-invoices under § 14 UStG. Plain PDFs do not meet this definition – but may still be sent with the recipient's consent during the transition period until end of 2026.

XRechnung UBL .xml · German public sector standard
XRechnung CII .xml · UN/CEFACT syntax
ZUGFeRD 2.x .pdf · hybrid, EN 16931 compliant
Factur-X .pdf · identical to ZUGFeRD 2.x
Does not qualify as an e-invoice: plain PDF, Word document, scanned invoice, or email attachment without an EN 16931 format.

What exactly is an e-invoice under § 14 UStG?

Since the amendment of § 14 UStG by the Growth Opportunities Act, the rule is: an e-invoice must conform to a structured electronic format based on the European standard EN 16931. Plain PDFs – even when sent by email – no longer count as e-invoices under the law.

Formats that meet the requirements: XRechnung (UBL or CII syntax), ZUGFeRD from version 2.x and Factur-X. A ZUGFeRD PDF always contains both a human-readable PDF view and an embedded XML – the XML is the legally relevant part.

§ 14 UStG – Statutory text · EN 16931 – European standard (CEN)

Who is affected and when?

According to the legislative commentary, the receiving obligation applies to all VAT-registered businesses operating in B2B in Germany. For small businesses under § 19 UStG and special constellations (e.g. VAT-exempt supplies), it is advisable to consult a tax adviser.

The phased plan under the Growth Opportunities Act: receiving obligation from 01.01.2025. Sending obligation from 01.01.2027 for businesses with prior-year revenue over €800,000. From 01.01.2028 for all others. B2C invoices (to private individuals) are not affected.

  • B2G (to authorities): XRechnung mandatory since 2020 (federal level)
  • B2B (between businesses): receiving obligation from 01.01.2025
  • B2C (to consumers): no e-invoicing obligation

Growth Opportunities Act (BMJ) · BMF letter 15.10.2024 – transitional arrangements

PDF invoices: what is still allowed, what is not?

According to the BMF letter, between 01.01.2025 and 31.12.2026 an ordinary invoice (PDF, paper) may still be issued with the recipient's consent. From 2027 this option is no longer available for larger businesses. A scanned paper invoice or a PDF without embedded XML never meets the statutory definition under § 14 UStG.

To check received e-invoices: digital-rechnung.de opens XRechnung and ZUGFeRD locally in the browser – no upload, no account.

BMF letter on e-invoicing obligation (PDF)

Received an e-invoice? Open it for free.

XRechnung (.xml), ZUGFeRD or Factur-X (.pdf) – upload and read instantly.

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Frequently asked questions

What changes from 2025?

From 1 January 2025 all VAT-registered businesses in Germany must be able to receive and process EN 16931 e-invoices. Sending obligations are phased in from 2027/2028.

Does this affect non-German EU businesses?

Foreign businesses supplying German companies may receive XRechnung or ZUGFeRD invoices and need to be able to process them. If you issue invoices to German clients, check whether they require EN 16931 format. Consult a tax adviser for your specific obligations.

What is the difference between XRechnung and ZUGFeRD?

XRechnung is a pure XML file. ZUGFeRD is a hybrid format: PDF with embedded XML. Both comply with EN 16931 and count as e-invoices. digital-rechnung.de supports both.