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Germany's e-invoicing obligation: 2025, 2027 and 2028

Who must receive and send e-invoices in Germany and when, which formats are accepted (XRechnung, ZUGFeRD, Peppol) and what the transition rules mean.

6 min read · Updated 28 Oct 2026

Germany's Growth Opportunities Act (Wachstumschancengesetz) introduced mandatory B2B e-invoicing for domestic transactions in three steps. The first step is already in force; the next two follow on 1 January 2027 and 1 January 2028.

The timeline

  • 1 January 2025 — every domestic business must be able to receive e-invoices. There is no exemption for small companies on the receiving side.
  • 1 January 2027 — businesses whose previous-year turnover exceeded €800,000 must issue e-invoices to other domestic businesses.
  • 1 January 2028 — all remaining businesses must issue e-invoices; the transitional allowance for EDI also ends.

What counts as an e-invoice

An e-invoice is a structured electronic format that complies with EN 16931. A PDF — even one sent by email — is a 'sonstige Rechnung', not an e-invoice. Accepted formats include XRechnung, ZUGFeRD from version 2.0.1 (all profiles except MINIMUM and BASIC WL) and other EN 16931 compliant formats such as Peppol BIS Billing 3.0.

BASIC is allowed

A common misconception is that only ZUGFeRD EN 16931 (Comfort) and above qualify. The Federal Ministry of Finance accepts BASIC as well — only MINIMUM and BASIC WL are excluded because they lack line items.

Exclusions

  • Small-value invoices up to €250 and travel tickets may still be paper or PDF.
  • Certain VAT-exempt supplies are excluded.
  • Kleinunternehmer (small businesses under § 19 UStG) are exempt from issuing, but not from receiving.

How to prepare

  1. Make sure your inbox or AP software can read XRechnung and ZUGFeRD — this has been mandatory since 2025.
  2. Decide your sending format: ZUGFeRD if customers like a readable PDF, XRechnung for the public sector, Peppol BIS 3.0 if your customers are on Peppol.
  3. Validate your templates against EN 16931 now. Calculation errors (BR-CO-15, BR-CO-17) and missing VAT numbers are the most common reasons for rejection.

This guide summarises public specifications and official guidance. It is not legal or tax advice — check with your adviser for your situation.