E-Invoicing Regulation in Germany: Deadlines, Software, and Exceptions

As of January 1, 2025, the new regulation requiring the issuance of electronic invoices (e-invoices) for all domestic B2B transactions under Section 14 of the German VAT Act (UStG) has come into effect. In other words, Germany has introduced a mandatory e-invoicing requirement.

This reform is part of the Growth Opportunities Act (Wachstumschancengesetz), which aims to boost economic growth and strengthen Germany’s competitiveness. The change brings extensive adjustments to invoicing practices. In this article, you’ll find all the key information and deadlines you need to know.

Gradual Introduction of the E-Invoicing Obligation

Although e-invoicing becomes the new legal standard for domestic B2B transactions as of January 1, 2025, companies are granted a phased transition period. The deadlines for receiving, issuing, and switching to e-invoices depend on company size and technical readiness. Here’s an overview:

Deadlines for the E-Invoicing Obligation in Germany

January 1, 2025
All domestic businesses must be able to receive structured electronic invoices (e-invoices). At the same time, companies are generally required to issue e-invoices for domestic B2B sales. However, transitional provisions allow deviations from this requirement until 2027.

December 31, 2026
End of the first transition phase: Until this date, companies may still issue paper invoices or other formats such as PDF invoices — but only with the recipient’s consent.

January 1, 2027
Companies with annual turnover exceeding €800,000 (in the previous year) lose the option to use other invoice formats. From this point onward, they must issue e-invoices in the prescribed structured format.

December 31, 2027
End of the extended transition period for smaller businesses: Companies with annual turnover of up to €800,000 may continue to use alternative formats until the end of 2027.

January 1, 2028
From this date, the e-invoicing obligation applies without exception to all domestic B2B transactions. Other invoice formats (e.g., PDF) will no longer be permitted in most cases.

What Counts as an Electronic Invoice?

Since January 1, 2025, an invoice is considered an electronic invoice (e-invoice) only if it:

• is issued in a structured electronic format,
• complies with the European standard EN 16931, and
• enables automated electronic processing.

Invoices in simple PDF format do not qualify as e-invoices. These are referred to as “other invoices” and will no longer be permitted from 2028 onward, unless a specific exception applies.

Approved E-Invoice Formats

The following formats are recognized as compliant e-invoice formats in Germany:

• XRechnung – an XML-based format, primarily used in the public sector
• ZUGFeRD (from version 2.0.1 onward) – a hybrid format that combines a PDF view with embedded XML data

In addition, certain EDI formats (Electronic Data Interchange) may also be used, provided they meet the legal requirements.

Exceptions to the E-Invoicing Requirement

Not all invoices must be issued as e-invoices. The following cases are exempt from the e-invoicing obligation:

• B2C invoices – invoices issued to private individuals
• VAT-exempt transactions under Section 4 Nos. 8–29 of the German VAT Act (UStG), e.g. rentals, medical, or financial services
• Low-value invoices up to €250 (Section 33 of the German VAT Implementation Regulation, UStDV)
• Tickets and travel documents (Section 34 UStDV)
• Services provided by small businesses under Section 19 UStG and Section 34a UStDV
• Services to legal entities that are not businesses, such as many associations or non-profits
• Certain real estate-related services provided to end consumers

In these cases, companies may still issue other types of invoices, such as PDF or paper invoices.

Do E-Invoices Also Apply to Cash Purchases?

Yes. Even for cash purchases between businesses — for example, at a hardware store or a business meal — an e-invoice is generally required for amounts exceeding €250, unless a transitional rule applies.

In practice, a receipt can be issued on-site, and an e-invoice can be provided later.

Obligation to Receive E-Invoices

Since January 1, 2025, all domestic businesses — regardless of turnover or legal form — are required to be able to receive and process e-invoices. This includes:

• Small businesses
• Companies not obligated to issue e-invoices themselves
• Legal entities that are not businesses

An email inbox is sufficient to receive e-invoices, as long as the received file is in a permitted structured format.

Mandatory Information and Retention Requirements

The mandatory details of an e-invoice are the same as those of a traditional invoice. However, they must be included within the structured XML data, such as:

• Invoice number
• Date
• Description of goods or services
• VAT amount, etc.

E-invoices must be stored in a tamper-proof and audit-compliant manner. The statutory retention period remains the same: 10 years in accordance with Section 147 of the German Fiscal Code (AO).

Visualizing E-Invoices

Because e-invoices are machine-readable, formats like XRechnung require special viewer software to make them human-readable. For ZUGFeRD files, a PDF view is already included.

In both cases, it’s important to note that the structured XML data is the legally binding part of the e-invoice, not the visual display.

Outlook: Reporting System and EU Requirements

Starting in 2028, Germany plans to introduce an e-invoice reporting system under which invoice data will be transmitted directly to the tax authorities.
This measure aims to further reduce VAT fraud and forms part of the EU initiative “VAT in the Digital Age” (ViDA).

From July 2030, cross-border invoices within the EU will also have to be issued and reported in accordance with the EN 16931 standard.

Using Invoicing Software to Meet E-Invoicing Requirements

To comply with the new legal requirements, businesses will need to use suitable invoicing software.
Such solutions make it easy to create structured electronic invoices in formats such as XRechnung or ZUGFeRD and ensure automated processing, archiving, and secure transmission of invoice data.

Platforms like easybill also offer helpful additional features, such as integrations with accounting systems and template management — making them ideal for an efficient and legally compliant implementation of the e-invoicing obligation from 2025 onward.

Key Factors to Consider When Choosing E-Invoicing Software

• User-friendliness:
  Look for intuitive interfaces and simple workflows to ensure smooth adoption and operation.
• Data security:
  Make sure the software meets high security standards and keeps your data protected.
• Integrations:
  Ensure the software provides all necessary interfaces to fit seamlessly into your existing processes and to exchange data smoothly — for example, with your tax advisor.

Tips for Implementing the E-Invoicing Obligation

Phase 1: Preparation & Analysis

• Understand the legal framework:
  Familiarize yourself with the requirements of the e-invoicing mandate, especially regarding formats (e.g. XRechnung, ZUGFeRD) and applicable exceptions.
• Assess your current situation:
  Review your existing invoicing workflows, system landscape (e.g. invoicing or ERP software), and data flows.
• Define goals and responsibilities:
  Identify which departments are affected and appoint internal project leads.

Phase 2: Technical Implementation & Training

• Check or select your software:
  Ensure your invoicing software can generate and process e-invoices in the required format — consider switching providers or expanding your system if needed.
• Set up integrations:
  Establish seamless connections between your invoicing, ERP, and archiving systems.
• Train your staff:
  Conduct targeted training sessions to make sure all relevant employees are familiar with the new processes, tools, and legal requirements.

Phase 3: Evaluation & Optimization

• Identify and fix issues:
  Analyze potential technical or organizational weaknesses and resolve them in time.
• Go live:
  Transition to live operations either gradually or on a set date, and establish internal control mechanisms to ensure ongoing quality assurance.

Related Posts:

Ähnliche Beiträge:

ZUGFeRD – the new standard for European e-invoicing Craftsman invoice: show labor costs and material costs separately Writing invoices without a trade – Is that possible at all? What is an e-invoice? What you should know about ZUGFeRD and XRechnung Advantages of the e-invoice for accounting New: Receive e-invoices and enter receipts via AI