Germany's E-Invoicing Mandate 2025-2028: What Every Business Needs to Know

Germany has joined the growing list of European countries requiring structured electronic invoices for business-to-business transactions. The mandate, introduced by the Growth Opportunities Act (Wachstumschancengesetz) passed in March 2024, rolled out in phases starting January 1, 2025.

If your business operates in Germany, this affects you now.

The Timeline

January 1, 2025 (Phase 1, active now). All businesses established in Germany must be capable of receiving structured electronic invoices. This applies regardless of company size or annual turnover. Importantly, you don’t need to create new software or processes; having an email inbox is sufficient to satisfy the receiving requirement.

January 1, 2027 (Phase 2). Businesses with annual turnover exceeding 800,000 EUR must issue structured e-invoices for all domestic B2B transactions. Paper and PDF invoices are no longer permitted for this group.

January 1, 2028 (Phase 3). All remaining businesses must issue structured e-invoices for domestic B2B transactions. This is the universal deadline.

There is one notable exemption: businesses operating under the small business exemption (Kleinunternehmerregelung, §19 UStG) with annual turnover under 22,000 EUR are exempt from issuing e-invoices, though they still need to be capable of receiving them.

What Counts as an E-Invoice

This is where many businesses get confused. A PDF sent by email is not an e-invoice under the new definition. Neither is a scanned paper invoice.

An e-invoice, under Germany’s mandate, is a structured electronic document that meets the European standard EN 16931. It must be machine-readable and processable automatically. A PDF is human-readable but not machine-readable in the relevant sense.

The accepted formats are:

XRechnung. Germany’s national implementation of EN 16931. A pure XML file. No human-readable PDF component; the structured data is everything.

ZUGFeRD 2.0 or higher. A hybrid format that contains both a human-readable PDF and an embedded XML file. The PDF is for viewing; the XML is the actual e-invoice. This is the more business-friendly format because you can read and view it like a normal PDF while the software extracts data from the XML.

Peppol BIS 3.0. The European network standard for e-invoice exchange, also accepted in Germany.

What It Means in Practice

For receiving e-invoices (required now): very little changes. An email inbox that can receive files is sufficient. If your accounting software can parse XRechnung or ZUGFeRD files, that’s better, but it’s not required under Phase 1.

For issuing e-invoices (required from 2027/2028): you need software capable of generating XRechnung or ZUGFeRD output. Most modern invoicing software either already does this or will add it before the deadline.

The mandate applies only to domestic B2B transactions between businesses established in Germany. It does not apply to: B2C transactions, invoices to customers outside Germany, transactions under 250 EUR, and certain VAT-exempt services.

The GoBD Connection

E-invoices are subject to the same GoBD retention requirements as other financial documents. The 10-year retention period applies. The document must be stored in its original structured format; you cannot receive a ZUGFeRD file and store only the PDF portion.

This means your document management or accounting system needs to handle structured XML storage, not just PDF.

How to Prepare

Verify your receiving capability. Confirm that invoices sent to your business email address actually reach the right inbox and don’t get caught in spam filters. This is the minimum requirement until 2027.

Audit your invoicing software. If you issue invoices, check whether your software can generate XRechnung or ZUGFeRD output. If not, assess whether an upgrade or replacement makes sense before the 2027 deadline.

Talk to your tax advisor (Steuerberater). The e-invoicing mandate connects to your existing GoBD compliance and DATEV workflow. Your tax advisor (Steuerberater) can advise on the smoothest integration path given your specific setup.

Don’t wait until 2027. Businesses that adopt structured invoicing now have two years to refine their processes. Businesses that wait until the last month will face the same learning curve under deadline pressure.

How KontoMatch Helps

KontoMatch stores every uploaded invoice in its original format, maintains a timestamped audit trail for each document, and keeps records for up to 10 years. As the e-invoicing mandate phases in, keeping your document management organized and your records complete becomes increasingly important.