E-Invoicing in Germany: Complete Guide

What Is E-Invoicing in Germany?

Germany has fundamentally changed the legal definition of an electronic invoice as part of the Growth Opportunities Act (Wachstumschancengesetz), approved by the Bundesrat on 22 March 2024.

From 1 January 2025, an electronic invoice (E-Rechnung) is defined exclusively as an invoice issued, transmitted, and received in a structured electronic data format that enables automatic electronic processing. The structured data must allow the recipient to import invoice information directly into their systems without manual re-entry.

This is a significant legislative shift: invoices sent as standard PDF files by email no longer qualify as e-invoices under German law. They are instead classified as "other invoices" (sonstige Rechnungen). Paper invoices also fall into this category.

Germany published detailed administrative guidance on the introduction of e-invoicing in a BMF letter dated 15 October 2024, supplemented by an updated letter in October 2025. The German Ministry of Finance also maintains an official FAQ (last updated March 2026), which is referenced throughout this guide.

Mandatory B2G (Business-to-Government) e-invoicing has been in place in Germany since November 2020, governed by the Federal E-Invoicing Ordinance (ERechV), though implementation is decentralised across the federal states. The B2B VAT rules and the ERechV operate independently and in parallel — businesses dealing with public authorities must observe both sets of requirements.

Have a look at our e-invoicing overview for Europe for the current implementation status across all EU member states.

When Does the Mandate Apply?

The B2B e-invoicing obligation is being introduced in three phases:

• 1 January 2025: All domestic businesses must be able to receive structured e-invoices. Issuing e-invoices is not yet mandatory for all (see Transition Rules below).
• 1 January 2027: Businesses with prior-year turnover exceeding €800,000 must issue structured e-invoices.
• 1 January 2028: German businesses must issue structured e-invoices. All transitional arrangements expire.

The mandate received the required EU authorisation by way of derogation from Articles 218 and 232 of the EU VAT Directive, allowing Germany to make e-invoicing the default system without requiring recipient consent — placing Germany ahead of the curve in alignment with the ViDA proposal.

German E-invoicing Scope

Who is Affected?

The German e-invoicing mandate applies to domestic B2B transactions — supplies made between businesses established in Germany. Both the supplier and the customer must be domestic businesses for the obligation to apply.

A business is considered "domestic" for these purposes if it has its registered seat, place of management, or a fixed establishment involved in the relevant transaction within Germany.

Foreign businesses that hold a German VAT registration but have no fixed establishment in Germany are not required to issue or receive structured e-invoices. These businesses may note their non-established status on the invoice, and recipients may rely on that indication when applying ordinary commercial care.

Transactions excluded from the mandate

Even where both parties are domestic businesses, the e-invoicing obligation does not apply to:

• Intra-Community supplies (cross-border transactions within the EU)
• Small amount invoices with a gross value of €250 or less
• Transport tickets that qualify as invoices under German VAT law
• Certain VAT-exempt supplies under §4 No. 8–29 UStG (e.g. financial services, certain property lettings)
• B2C transactions (supplies to private end consumers)
• Invoices to non-entrepreneur legal entities, such as associations acting in a non-business capacity or public bodies not acting as businesses.

Small businesses (Kleinunternehmer) operating under the small business scheme are exempt from issuing structured e-invoices. However, they are not exempt from receiving them — all domestic businesses, including small businesses, must be capable of receiving e-invoices from 1 January 2025. If a small business subsequently switches to the standard VAT regime, the obligation to issue e-invoices applies from that point onwards.

Associations (Vereine) may carry out both business and non-business activities. Where an association acts as a business (i.e. is a VAT taxable person), the general e-invoicing rules apply in full — it must both issue and receive structured e-invoices, subject to any applicable exemptions or transition rules. Where the supply relates to the association's non-business activities, the obligation does not apply.

Accepted E-Invoice Formats

German e-invoices must comply with the European standard EN 16931 (CEN 16931), which specifies a structured XML-based format that enables automatic electronic processing.

The following formats are accepted:

• XRechnung — Germany's native structured XML format, developed and maintained by KoSIT (Koordinierungsstelle für IT-Standards). It contains no embedded human-readable layer; a separate viewer is needed to read the file.
• ZUGFeRD (version 2.0.1 and above) — a hybrid format combining a structured XML component with a human-readable PDF layer. Note that the MINIMUM and BASIC-WL profiles of ZUGFeRD do not meet the e-invoicing requirements.
• EDI formats (e.g. EDIFACT) — existing EDI arrangements may continue to be used if agreed between the parties and provided the format enables correct and complete extraction of all mandatory VAT data. This option remains available until the end of 2027 under the transitional rules; after that, EDI formats must comply with EN 16931 to qualify as e-invoices.
• Other EN 16931-compliant formats — parties may also agree on alternative formats, provided they satisfy all data extraction requirements.

Important: In ZUGFeRD hybrid invoices, the structured XML part now takes precedence over the human-readable PDF layer. If there is any discrepancy between the two, the XML data governs. This reverses the previous rule.

Mandatory content in the structured part

All mandatory VAT data under the UStG must be contained within the structured part of the e-invoice — not merely referenced or linked to an external document. Supplementary information (e.g. a detailed breakdown of hours worked, or a bill of quantities for construction services) may be attached as an unstructured annex, provided the structured part includes a clear and explicit reference to it.

For construction service invoices (Bauleistungen), it is currently sufficient to include only the individual trades and their totals in the structured part, with a detailed breakdown attached in a human-readable annex that is clearly referenced.

Viewing and validation

Since XRechnung files contain no built-in PDF layer, businesses require separate viewer software. The German tax authority provides a free viewer at www.e-rechnung.elster.de, supporting both XRechnung and ZUGFeRD formats. Various third-party viewers are also available.

Validation of an e-invoice against the EN 16931 technical requirements is not a legal prerequisite for VAT purposes (including for input VAT deduction). However, it is strongly recommended as a means of identifying missing or inconsistent mandatory fields before dispatch.

Leitweg-ID

A Leitweg-ID routing identifier is not required for B2B e-invoices. It is only needed when invoicing public authorities (B2G). In B2B invoicing, if a format field for this identifier is present, a placeholder value (e.g. "–") is sufficient from a VAT compliance perspective.

Transmission and Receipt of German E-invoices

German law does not prescribe a specific transmission channel for e-invoices, providing flexibility to accommodate different business practices. Acceptable methods include email delivery, electronic interfaces (APIs), shared central storage within a corporate group, portal download, or even physical media (e.g. USB drive).

The choice of transmission method is a commercial matter to be agreed between the contracting parties.

Since 1 January 2025, all domestic businesses have been required to be capable of receiving structured e-invoices. The BMF has confirmed that having a functioning email inbox is sufficient to meet this obligation. There are no exceptions to the receipt requirement — small businesses and associations with business activities must also be able to receive e-invoices.

Transition Rules

The transition rules determine when the obligation to issue (not receive) structured e-invoices becomes binding. Note that the obligation to receive has applied to all domestic businesses since 1 January 2025 without any transition period.

• 1 January 2025 - 31 December 2026: All businesses may still issue paper invoices (always permissible) or other electronic formats (e.g. PDF by email), provided the recipient consents to the non-structured format.
• Until 31 December 2027: Businesses with prior-year turnover of €800,000 or less may continue using other invoice formats. EDI arrangements not already complying with EN 16931 may also continue until end of 2027.
• From January 2028: All domestic B2B transactions require structured e-invoices. No further extensions apply.

The decision to rely on transitional rules rests with the invoice issuer, not the recipient. That said, the rules also allow a recipient to seek out suppliers who continue to issue paper invoices during the transition, where that better suits their own systems.

Specific scenarios during the transition:

• Advance, deposit, and progress invoices issued before the applicable mandatory deadline do not need to be in structured format, even if the service or payment occurs after that date.
• Invoice corrections (Berichtigungen) must be issued as structured e-invoices once the mandate applies in full. During the transition, corrections may still be made using non-structured formats. A correction may also be incorporated into a subsequent e-invoice, provided it specifically and unambiguously references the original.
• Collective invoices (Sammelrechnungen) covering multiple supplies within a calendar month are permitted, with the calendar month stated as the supply date.

VAT Deduction Implications

This is one of the most commercially significant aspects of the mandate for businesses. During the transition period, a non-structured invoice (paper or PDF) is still treated as a valid invoice for input VAT deduction purposes, provided it meets all other mandatory VAT data requirements.

Once the transitional period ends and structured e-invoicing becomes fully mandatory:

• Only compliant structured e-invoices will support input VAT deduction. Non-compliant invoices — paper or unstructured electronic formats — will not be valid for VAT recovery once the relevant deadline has passed.
• Businesses that fail to adapt their invoicing systems in time risk losing the right to deduct input VAT on purchases received under non-compliant invoices.

Businesses should therefore prioritise readiness not only on the issuance side but also in their purchase invoice processing, to ensure they can correctly handle and archive incoming structured e-invoices.

Storage and Archiving of E-Invoices

E-invoices must be retained for eight years, in line with the general VAT retention requirement under §14b UStG. At minimum, the structured part of the e-invoice must be preserved in its original, unaltered form.

Storage outside a GoBD-compliant accounting system does not in itself constitute a violation of the VAT retention obligation, provided the content of the invoice remains intact and accessible.

If required by the tax authority (e.g. for a tax assessment procedure), e-invoices may be submitted via ELSTER, using the "Belegnachreichung zur Steuererklärung" function at www.elster.de.

Digital Reporting Requirements: What Comes Next?

Germany does not currently operate a Continuous Transaction Control (CTC) system or real-time digital reporting requirement alongside the e-invoicing mandate. There is no current obligation to transmit invoice data to the tax authority at the time of issuance.

However, the German authorities have been explicit: the e-invoicing mandate is designed as a preparatory step for a future transaction-based reporting system (Meldesystem). When that system is introduced, it will require certain invoice data to be reported electronically to the tax administration on a near-real-time basis. Introducing e-invoicing first allows businesses time to adapt their technical and organisational processes gradually before reporting obligations follow.

The BMF has confirmed that the current rules — including formats, transition periods, and scope definitions — may be reviewed and adjusted once the reporting system is developed. The federal government will bring forward the necessary legislative proposals in due course.

Germany is developing this future reporting system in parallel with ViDA (VAT in the Digital Age), and in particular its Pillar 1 on e-invoicing and digital reporting requirements at EU level. The alignment of Germany's accepted formats (EN 16931-compliant) with the ViDA framework means businesses investing in e-invoicing compliance now will be well placed for upcoming EU-wide changes.

Key FAQs — Based on the BMF's Official Guidance

The German Ministry of Finance publishes and regularly updates an official FAQ on e-invoicing (last updated: March 2026). Below is a summary of the most practically relevant questions based on that guidance.

Does a foreign business with a German VAT number need to issue e-invoices? No. Foreign businesses with a German VAT registration but no fixed establishment in Germany are not required to issue structured e-invoices. They may indicate their non-established status on the invoice, and recipients may rely on this when applying ordinary commercial care.

Is a PDF sent by email still a valid invoice? From 1 January 2025, a PDF without a structured XML component is no longer classified as an e-invoice — it is an "other invoice". During the transition period it remains valid for VAT purposes. Once the full mandate applies, it will not support an input VAT deduction claim.

Can I continue using EDI? Yes, until the end of 2027. After that, EDI formats must satisfy the EN 16931 requirements to qualify as e-invoices, unless the parties have separately agreed on a format that enables full extraction of mandatory VAT data.

What transmission method must I use? There is no prescribed method. Email, electronic interfaces, shared storage within a group, portal download, and physical media are all acceptable. The method is a matter for the parties to agree commercially.

How do I read an XRechnung file? XRechnung has no built-in PDF. Use any compatible XML viewer.

Can I issue a single invoice covering multiple transactions in a month? Yes. A collective invoice (Sammelrechnung) covering multiple supplies within a calendar month is permitted, with the calendar month stated as the supply date.

Do the e-invoicing rules apply to cash transactions (e.g. restaurant meals or purchases at a hardware store)? Yes, if the invoice amount exceeds €250 and the recipient is a business. The BMF suggests that, in practice, an "other invoice" (e.g. a till receipt) may be issued at the point of sale and subsequently corrected by means of a structured e-invoice, for instance sent by email.

Must the mandatory VAT data appear in the structured XML itself? Yes. All mandatory VAT data must be present in the structured part of the invoice. A reference in the structured data pointing to an unstructured annex for mandatory fields is not sufficient, as it would prevent full automatic processing. Supplementary details (e.g. hour breakdowns, annexes) may be attached separately but cannot substitute for mandatory structured content.

How Can Marosa Help?

Marosa offers end-to-end e-invoicing compliance support for businesses operating in Germany and across Europe. Whether you need to implement XRechnung or ZUGFeRD issuance, set up e-invoice receipt capabilities, or prepare for future digital reporting requirements, our team and technology are ready to help.

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