The German e-invoicing mandate: 2025, 2027 and 2028

What the e-invoicing mandate actually means

Since 1 January 2025 German VAT law applies a new classification: an e-invoice is not simply a PDF sent by email. It means a structured invoice that can be processed electronically and follows the European standard EN 16931. A PDF invoice, a scan or a Word document remains what the law calls an "other invoice".

The mandate consists of two parts that are far apart in time and are therefore often confused. Receiving has been mandatory since 2025 — for every domestic business, with no transitional period and no revenue threshold. Issuing your own e-invoices only becomes mandatory after the transitional periods, staggered by previous-year revenue.

In practice: even a business that may keep writing paper invoices for years must already be able to accept an XRechnung today, render it readable and retain it properly.

• Receiving since 2025 — no exception

  All domestic businesses must be able to receive e-invoices. There is no general exception on the receiving side, not even for small businesses.

• Issuing from 2027 or 2028

  The obligation to issue is phased in. Previous-year revenue and the 800,000 euro threshold decide the order.

• A plain PDF will no longer be enough

  A PDF without structured data does not meet the legal definition once no transitional rule and no exception applies any more.

• Transitional periods are no reason to wait

  Anyone switching only in 2027 or 2028 changes processes, software, responsibilities and archiving under time pressure — and has depended on incoming e-invoices long before that.

The deadlines from 2025 to 2028

The timing is the part that matters most in practice: receiving mandatory since 2025, a general transitional period for issuing until the end of 2026, and an extended deadline for smaller issuers until the end of 2027.

1. 2025

   Receiving becomes mandatory

   Every domestic business must be able to accept e-invoices. Formally an email inbox suffices per the ministry FAQ; in practice you also need a way to read, check and traceably file the XML file.

2. 2026

   General transitional period runs

   Other invoices remain possible: paper without consent, a simple electronic format only with the recipient’s consent.

3. 2027

   Issuing required above 800,000 euros

   Issuers with more than 800,000 euros previous-year revenue must issue e-invoices for the covered domestic B2B transactions. Smaller issuers get one more year.

4. 2028

   Business as usual

   The extended deadline ends too. E-invoicing becomes the standard for the covered domestic B2B transactions; only the statutory exceptions remain.

Who is covered by the mandate?

The mandate covers entrepreneurs for VAT purposes where the supplier and the recipient are both established in Germany and an invoice is required. Whether you run a large company, a sole proprietorship, a professional practice or a small office makes no difference.

Classic B2C sales to private customers are not covered. Many VAT-exempt transactions also fall outside the same scope, because there is usually no obligation to issue an invoice for them at all. Invoices to public buyers are additionally governed by their own B2G rules, which have existed for longer.

• Covered: domestic B2B transactions

  Both parties are established in Germany and there is a VAT obligation to issue an invoice. That is the core of the scope.

• Freelancers and the self-employed too

  What matters is being an entrepreneur, not the legal form or the size. A single practice is covered just as a limited company is.

• Small businesses: receiving yes, issuing no

  Small businesses under § 19 UStG must be able to receive e-invoices, but are exempt from issuing them for their exempt supplies.

• Not covered: invoices to consumers

  The VAT B2B mandate does not apply to B2C sales. Issuing an e-invoice voluntarily remains permitted.

• Public buyers: their own rules

  In B2G, federal or state requirements apply on top — often mandating XRechnung and a routing identifier.

• Foreign business partners

  Invoices to or from abroad are not covered by the German mandate, but must comply with the relevant national and European rules.

The most important exceptions

Even after 2028 there remain cases in which no e-invoice has to be issued. Important: these exceptions almost always concern issuing, not receiving.

• Small-value invoices up to 250 euros gross

  No e-invoice has to be issued for invoices up to and including 250 euros gross.

• Transport tickets

  Tickets and certain comparable documents remain exempt from the obligation to issue.

• Supplies by small businesses

  Under § 34a UStDV, small businesses may continue to issue other invoices for their supplies exempt under § 19 (1) UStG. Receiving is unaffected.

• Sales to consumers

  Invoices to private individuals do not fall under the domestic B2B mandate.

• Certain VAT-exempt transactions

  Many transactions under § 4 nos. 8 to 29 UStG are not covered, because no invoice is generally required for them.

• EDI procedures

  Established EDI procedures may continue where they meet the legal requirements. Procedures that do not yet meet them are permitted only for a limited time under the transitional rules.

Whether an exception applies in a specific case depends on the VAT treatment of that transaction. Clarify borderline cases with your tax adviser before you build a process on them.

What non-compliance actually costs

The mandate is not only a technical topic. It reaches into payment processes, supplier relationships, tax audits and documentation — and the consequences you feel are usually commercial rather than criminal.

• The recipient’s input VAT deduction

  Your customer needs a proper invoice. If it is not, questions and corrections follow — in the worst case after the payment term has long expired.

• Tax audits

  Unclear filing, missing XML originals or corrections that cannot be traced significantly increase audit effort and the number of queries.

• Late payment

  Business partners can reject invoices that do not arrive in the expected format. Every rejection costs a complete payment cycle.

• Supplier portals

  Large buyers increasingly insist on structured invoices and will not technically accept a deviating format at all.

• Duty to correct

  Where an e-invoice is required and one was issued in the wrong format, you should correct it. What follows in the individual case depends on the evidence available.

• Retention

  The structured part of an e-invoice must be preserved intact and in its original form. A printout or a newly generated PDF does not satisfy that.

Checklist: what to do now

The migration is above all a process question. These five steps take you forward in the order that actually matters.

1. 1

   Secure receiving — immediately

   Decide which address e-invoices go to, who opens them and where the XML file ends up. Without that, the receiving process is not properly settled even if an inbox technically exists.

2. 2

   Choose software — immediately

   You need a way to display, validate, create and export e-invoices. Check whether your existing solution handles XRechnung and ZUGFeRD in the profiles you need.

3. 3

   Settle retention — short term

   The structured XML part must be preserved unaltered. Decide where the original lives, how it is backed up and how you describe that in your process documentation.

4. 4

   Evaluate the revenue threshold — before 2027

   Determine your previous-year revenue against the 800,000 euro threshold. It decides whether the issuing obligation reaches you in 2027 or only in 2028.

5. 5

   Prepare the team — ongoing

   Accounting, sales and administration need to know what changes: which formats go out, how incoming invoices are checked, and who handles questions.

• Make an invoice you received readable right nowOpen an XRechnung or ZUGFeRD PDF free in your browser — no account, no upload.
• Check an invoice for errorsA report covering XML schema, EN 16931, XRechnung and Peppol with concrete findings.
• Read up on deadlines and formatsDefinition, formats and BT numbers in the e-invoicing basics.

Frequently asked questions about the mandate

The questions businesses actually ask — answered briefly and without a chain of statutory references.

Sources and legal basis

The deadlines and exceptions on this page rest on the following rules and publications. What governs is always the original text as currently in force.

• E-invoicing: questions and answers on the B2B rollout — German Federal Ministry of Finance
• German VAT Act § 14 — issuing invoices — Federal Office of Justice, Gesetze im Internet
• German VAT Act § 19 — small business scheme — Federal Office of Justice, Gesetze im Internet
• German VAT Implementing Ordinance § 34a — invoices from small businesses — Federal Office of Justice, Gesetze im Internet
• German E-Invoicing Ordinance (ERechV) for federal contracts — Federal Office of Justice, Gesetze im Internet
• VAT in the Digital Age (ViDA) — European Commission

This article reflects publicly available information as of the date shown and is not tax or legal advice. What governs are the statutory rules, the letters issued by the German Federal Ministry of Finance and the requirements of your invoice recipient.

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