Germany e-Invoicing Guide
Every domestic business in Germany has had to be able to receive a structured e-invoice since 1 January 2025. Issuing becomes mandatory on 1 January 2027 for businesses whose total turnover exceeded 800,000 euros in the preceding calendar year, and for all remaining domestic businesses on 1 January 2028. XRechnung and ZUGFeRD both qualify.
Last updated 29 Sep 2026
What is e-Invoicing in Germany?
Germany's B2B mandate rests on its own law. Article 23 of the Wachstumschancengesetz, promulgated on 27 March 2024 in Bundesgesetzblatt 2024 Teil I Nr. 108, rewrote section 14 UStG to define an e-invoice as a structured electronic format that allows electronic processing. The duty covers domestic businesses for their domestic B2B supplies.
Receiving has applied since 1 January 2025, and the BMF FAQ on mandatory e-invoicing states that an existing email mailbox is enough. The BMF letter of 15 October 2025 names XRechnung and ZUGFeRD as examples of qualifying formats, and Peppol carries federal B2G invoicing.
Germany e-Invoicing deadlines and milestones
Issuing follows as the transitional periods in section 27(38) UStG close. The first ends on 31 December 2026, so from 1 January 2027 a domestic business whose total turnover under section 19(2) UStG exceeded 800,000 euros in the preceding calendar year must issue e-invoices. The rest, for smaller issuers and for invoices sent by agreed EDI, end on 31 December 2027.
Measure 18 of the BMF Action Plan against tax and financial crime, published on 16 July 2026, commits Germany to an electronic VAT reporting system. It names no draft legislation, scope or start date, and the 2027 and 2028 deadlines are unchanged. Select a milestone below for its detail.
Federal B2G e-invoicing mandatory for suppliers
XRechnung became mandatory for suppliers to the direct federal administration under the E-Rechnungsverordnung. Invoices carry a Leitweg-ID in field BT-10 and arrive through the federal submission portal or the Peppol network.
Wachstumschancengesetz creates the B2B mandate
The Wachstumschancengesetz was promulgated in Bundesgesetzblatt 2024 Teil I Nr. 108. Its Article 23 rewrote section 14 UStG to define an e-invoice as a structured electronic format that allows electronic processing, and added the transitional rule in section 27(38) UStG.
Mandatory reception and archiving requirements
Domestic businesses must be able to receive an EN 16931 e-invoice. The retention period for a copy of every incoming and outgoing invoice fell from ten years to eight under section 14b(1) UStG.
ViDA Package published in Official Journal
Directive (EU) 2025/516 was published in the Official Journal. On entry into force on 14 April 2025 it allowed Member States to mandate domestic e-invoicing without seeking a Council derogation.
GoBD 2nd amendment for e-invoicing
BMF Schreiben of 14 July 2025 amends the GoBD principles to align with mandatory B2B e-invoicing. For hybrid invoices (e.g. ZUGFeRD), the human-readable part need only be retained alongside the structured part where it contains additional or differing tax-relevant information.
Invoice particulars in other EU official languages
The BMF letter of 17 September 2025 lets certain mandatory invoice particulars carry the wording used for Article 226 of the VAT Directive in another official EU language, and adds Anlage 8 to the VAT application decree listing standard equivalents.
ZRE deactivated; OZG-RE migration cutover completed
The final migration wave from ZRE to OZG-RE completed on 19 September 2025, after which the ZRE was no longer available from Q4 2025. OZG-RE is the sole federal submission portal, and Peppol submission remains supported.
BMF Clarifications on Format and Archiving
BMF Schreiben of 15 October 2025 distinguishes format errors from business rule errors, reaffirms EN 16931 validation, requires e-invoices to be archived in their original structured format, and clarifies that credit notes must be issued as e-invoices.
EN 16931-1:2026 approved
CEN approved a revised European e-invoicing standard, its definitive text available on 18 March 2026 per the European Commission. Its specifications page records publication in May 2026, the 2017 version staying compliant during migration.
BMF e-invoicing FAQ updated (Stand März 2026)
The BMF FAQ on mandatory e-invoicing (Stand März 2026) adds question 7b on collective, corrected, advance and final invoices, and question 12a on making a received e-invoice human-readable, including through the ELSTER e-invoice viewer. Deadlines are unchanged.
ZUGFeRD 2.5 published
FeRD published ZUGFeRD 2.5 on 10 June 2026, bringing code lists and validation artefacts into line with the current EN 16931 publication and adding elements to the EXTENDED profile. Statutory deadlines and qualifying formats are unchanged.
BMF Action Plan announces electronic VAT reporting
Measure 18 of the BMF Action Plan against tax and financial crime commits Germany to an electronic VAT reporting system; measure 19 proposes 15-year retention of booking documents. No draft legislation, scope or start date has been published.
XRechnung 4.0 pre-release published
KoSIT published a pre-release of the XRechnung 4.0 specification, not yet meant for productive use, with the final bundle expected in spring 2027. XRechnung 3.0 stays in force until at least 31 July 2027.
B2B issuance mandatory above €800,000 turnover
The first transitional period in section 27(38) UStG closes on 31 December 2026, so a domestic business whose total turnover under section 19(2) UStG exceeded 800,000 euros in the preceding calendar year must issue e-invoices for its domestic B2B supplies.
B2B issuance mandatory for all domestic businesses
The remaining transitional periods in section 27(38) UStG, covering issuers at or below 800,000 euros turnover and invoices sent by agreed EDI, expire on 31 December 2027. Every domestic business must then issue e-invoices for its domestic B2B supplies.
ViDA: Cross-border B2B DRR
The Digital Reporting Requirements in Directive (EU) 2025/516 take effect, with the main impact on businesses making cross-border B2B supplies.
ViDA: Domestic Alignment
Member States running a domestic digital reporting system must align it with the EU model and standards set by Directive (EU) 2025/516.
Who needs to comply in Germany?
Receiving applies to all domestic businesses. Kleinunternehmer, whose invoices are governed by section 34a UStDV, are exempt from issuing but must still be able to receive, and invoices up to 250 euros gross, travel tickets and many VAT-exempt supplies fall outside the duty to issue.
Suppliers to the direct federal administration have had to send XRechnung since 27 November 2020 under the E-Rechnungsverordnung, with the carve-outs listed below.
| Transaction | Obligation | Scope | Effective |
|---|---|---|---|
| B2B | Receive | All domestic businesses | 1 January 2025 |
| B2B | Issue | Domestic businesses; Total turnover (section 19(2) UStG) above EUR 800,000 in the preceding calendar year | 1 January 2027 |
| B2B | Issue | All remaining domestic businesses | 1 January 2028 |
| B2G | Issue and receive | Suppliers to the direct federal administration | 27 November 2020 |
Exemptions and deferrals
| Who | What applies | Source |
|---|---|---|
| Small-Amount Invoices | Up to EUR 250 gross per invoice | section 33 UStDV |
| Travel Tickets | Outside the issuance duty | section 34 UStDV |
| Kleinunternehmer | Exempt from issuing; must still be able to receive | section 34a UStDV |
| Tax-Exempt Supplies | Many exempt supplies and consumer invoices outside the duty | BMF FAQ on mandatory e-invoicing |
| Federal B2G Carve-outs | Direct awards, classified data and some overseas procurement | section 3(1) ERechV |
How does e-Invoicing work in Germany?
Germany uses a post-audit model for B2B. There is no clearance or real-time reporting: invoices pass directly between the parties by email, EDI, a service provider or Peppol, and compliance is checked after issuance under the GoBD. Federal B2G invoices go through the OZG-RE portal or Peppol, addressed with a Leitweg-ID, and KoSIT acts as the national Peppol Authority for Germany.
Invoices are kept for eight years under section 14b(1) UStG. The BMF letter of 15 October 2025 requires at least the structured part to be kept unaltered in its original form, distinguishes format errors from business rule errors and states that credit notes must be issued as e-invoices.
Supplier
Issues the e-invoice
XRechnung or ZUGFeRD
Sends it directly
Email, EDI, a service provider or Peppol
Buyer
Receives the e-invoice
An existing email mailbox is enough
Tax authority
Checks after issuance
Under the GoBD
Planned
- Intra-EU B2B: ViDA digital reporting from 1 July 2030
- Electronic VAT reporting: announced in the BMF Action Plan, no start date
- Supplier
- OZG-RE portal or Peppol
- Direct federal administration
XRechnung or Peppol BIS, addressed with a Leitweg-ID
No e-invoicing requirement in Germany
Documents by transaction
| Document | Used for | B2B | B2G | B2C |
|---|---|---|---|---|
| XRechnung | Structured XML; required for federal B2G | · | ||
| ZUGFeRD | Hybrid PDF/A-3 with embedded XML | · | · | |
| Peppol BIS | Reaching federal authorities over Peppol | · | · |
What are the e-Invoicing penalties in Germany?
Failing to issue an invoice, or to issue it within six months, can be fined up to 5,000 euros per infringement under section 26a(2) UStG. A second consequence falls on the buyer: where a supply requires an e-invoice, any other invoice is not a proper invoice and does not in principle entitle the recipient to deduct input VAT until it is corrected.
| Offence | Penalty | Source |
|---|---|---|
| Input VAT Deduction | Input VAT not deductible in principle until corrected | BMF letter of 15 October 2025 |
| Retention Failures | Up to EUR 5,000 | section 26a(2) no. 2 UStG |
| B2G Submission Failures | Rejected at OZG-RE; payment waits for a compliant invoice | Leitweg-ID |
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Germany e-Invoicing FAQs
When does e-invoicing become mandatory in Germany?
Receiving has been mandatory for all domestic businesses since 1 January 2025. Issuing becomes mandatory on 1 January 2027 where total turnover under section 19(2) UStG exceeded 800,000 euros in the preceding calendar year, and on 1 January 2028 for all remaining domestic businesses.
Which e-invoice formats qualify in Germany?
The BMF letter of 15 October 2025 names XRechnung, the German EN 16931 standard, and ZUGFeRD from version 2.0.1, excluding the MINIMUM and BASIC-WL profiles, as examples. For federal B2G, Peppol BIS Billing 3.0, an EN 16931 CIUS, is used to reach federal authorities over the Peppol network.
Can EDI invoicing continue in Germany after 2026?
Yes, until 31 December 2027. EDI transmission agreed with the recipient may continue to that date under section 27(38) UStG, when the remaining transitional periods expire.
Is Germany planning electronic VAT reporting?
Measure 18 of the BMF Action Plan against tax and financial crime, published on 16 July 2026, commits Germany to an electronic VAT reporting system in which businesses report their turnover promptly and individually. The plan names no draft legislation, scope or start date, and it does not change the 2027 and 2028 deadlines.
Are small businesses exempt from e-invoicing in Germany?
Kleinunternehmer, whose invoices are governed by section 34a UStDV, are exempt from the duty to issue an e-invoice but must still be able to receive one. Separately, an invoice whose total does not exceed 250 euros gross is a Kleinbetragsrechnung under section 33 UStDV and need not be issued as an e-invoice.
Which suppliers must send e-invoices to Germany's federal administration?
Suppliers to the direct federal administration, since 27 November 2020 under the E-Rechnungsverordnung. They send XRechnung through the OZG-RE portal or Peppol, addressed with a Leitweg-ID. Direct awards invoiced at up to 1,000 euros, classified invoice data and some overseas procurement are carved out.
How long must e-invoices be archived in Germany?
Eight years for a copy of every incoming and outgoing invoice under section 14b(1) UStG, down from ten years from 1 January 2025. At least the structured part must be kept unaltered in its original form. A business established in Germany must archive in Germany, but may hold electronic invoices elsewhere in the EU where full online access is guaranteed and the tax office is notified of the location.
Does Germany require Peppol for B2B e-invoicing?
No route is prescribed for B2B: invoices may travel by email, EDI, a service provider or Peppol, and the BMF FAQ states that an existing email mailbox is enough to receive. For federal B2G, Peppol is one of two routes alongside the OZG-RE portal, with the receiver ID combining scheme 0204 and the buyer's Leitweg-ID.
What are the penalties for e-invoicing failures in Germany?
Up to 5,000 euros per infringement under section 26a(2) UStG for failing to issue an invoice or to issue it within six months, and up to 5,000 euros for not keeping invoice copies for eight years. A non-conforming document is not a proper invoice, so the recipient cannot in principle deduct input VAT until it is corrected, and federal B2G invoices with an invalid Leitweg-ID or format are rejected at OZG-RE.
Official Sources
BZStBundeszentralamt für SteuernTax authority
BMFBundesministerium der FinanzenMinistry
KoSITKoordinierungsstelle für IT-Standards (XRechnung)Standards body
FeRDForum elektronische Rechnung Deutschland (ZUGFeRD)Standards body
Last change recorded 15 September 2026. All updates