Germany e-Invoicing Guide

Germany is implementing one of Europe's largest B2B e-invoicing mandates, affecting millions of businesses. Since January 2025, every business operating in Germany must be capable of receiving structured electronic invoices. The obligation to send e-invoices is being phased in by revenue, with full coverage by January 2028.

The German system supports multiple formats (XRechnung, ZUGFeRD, and Peppol BIS), all conforming to the European EN 16931 standard. This flexibility means businesses can choose the format that best fits their existing ERP infrastructure while remaining compliant.

Germany's phased approach gives businesses time to adapt. Reception has been mandatory since January 2025. Transmission becomes mandatory for larger businesses (revenue above EUR 800,000) from January 2027, with all remaining businesses required to follow by January 2028. Paper and PDF invoices remain acceptable for transmission during the transition period if the recipient agrees.

The B2B mandate applies to all businesses operating in Germany, regardless of size. Since January 2025, every business must accept structured e-invoices from trading partners. The transmission obligation follows a revenue-based schedule.

Small-value invoices up to EUR 250 under §33 UStDV may be issued as regular invoices instead of structured e-invoices; this carve-out does not apply to intra-Community supplies (§6a UStG), reverse-charge transactions (§13b UStG) or distance sales (§3c UStG). B2C transactions are outside scope. The grace period for paper and unstructured electronic invoices is staggered: with buyer consent, all businesses may continue issuing them through 31 December 2026; from 1 January 2027 the option remains only for businesses with prior-year turnover at or below EUR 800,000, until 31 December 2027. From 1 January 2028 all domestic businesses must issue structured e-invoices. Federal B2G invoicing has been mandatory since 27 November 2020, originally via the ZRE and OZG-RE portals; OZG-RE became the sole federal portal from end of 2025.

Germany uses a decentralised exchange model. There is no central government platform through which B2B invoices must pass. Instead, businesses exchange structured invoices directly through their ERP systems or via service providers, using EN 16931-compliant formats.

For federal B2G transactions, the OZG-RE platform serves as the receiving system, and invoices must include a Leitweg-ID for routing; state (Land) authorities operate their own portals, with Peppol providing interoperability. B2B invoices have no such routing requirement and flow directly between trading partners. All invoices must be archived in their original electronic format for at least 8 years under §147 AO and GoBD principles.

Germany ties e-invoicing compliance to existing VAT and GoBD bookkeeping regulations. Non-compliant invoices may not qualify for VAT deduction, and failure to archive electronic invoices properly can trigger GoBD violations. For B2G, non-compliance can lead to payment delays and contract penalties.