E-invoicing in Germany: what applies from 2027
An e-invoice is an invoice whose details come in a defined, machine-readable form. A program can take over seller, amounts and taxes without anyone typing them in. Between businesses in Germany it is becoming mandatory in stages.
What counts as an e-invoice?
Since 1 January 2025, an invoice in Germany only counts as an e-invoice if it is issued, transmitted and received in a structured electronic format that allows electronic processing. The basis is the European standard EN 16931.
A plain PDF sent by email is therefore not an e-invoice, even if it looks like one. Like a paper invoice, it counts as an “other invoice”.
When does the mandate apply?
It applies to invoices between businesses established in Germany, in stages:
- Since 1 January 2025
- Every business in Germany must be able to receive e-invoices, including small businesses under the small business scheme.
- Until 31 December 2026
- All businesses may still issue other invoices: paper at any time, a PDF by email only if the recipient agrees.
- From 1 January 2027
- Businesses with more than €800,000 turnover in the previous year must issue e-invoices. Up to €800,000, the transition period runs until the end of 2027.
- From 1 January 2028
- The transition periods have ended: invoices between businesses in Germany must be issued as e-invoices. EDI procedures that do not meet the e-invoice requirements may also only continue until the end of 2027.
Who is exempt?
Under VAT law, you do not need an e-invoice for, among others:
- invoices to private individuals
- many VAT-exempt supplies, such as exempt letting of property or financial services
- small-amount invoices up to €250 gross
- tickets that count as invoices
- invoices from businesses under the small business scheme; they too must be able to receive e-invoices
- supplies to legal entities that are not businesses, for example many associations
Invoices to public authorities follow their own rules as well: at federal level, the E-Invoicing Ordinance (E-Rechnungsverordnung) has required e-invoices from €1,000 since November 2020.
Which formats are there?
XRechnung is the German standard, originally for invoices to public authorities. An XRechnung is a pure XML file, in either the CII or the UBL syntax. It contains no invoice image.
ZUGFeRD is a PDF with the invoice data embedded as XML. People read the image, programs read the data. ZUGFeRD counts as an e-invoice from version 2.0.1, except for the MINIMUM and BASIC-WL profiles. Factur-X is the French name for the same approach; both are technically largely the same.
UBL following Peppol BIS is the internationally widespread variant used in the Peppol network, also outside the EU.
Other formats, for example from EDI procedures, are allowed if sender and recipient agree on them and all mandatory details can be taken from them in full.
XRechnung or ZUGFeRD: the difference
Both rest on the same standard and carry the same details. The difference is the packaging: an XRechnung is data only, a ZUGFeRD invoice is data and invoice image in one file. Because the content is the same, one can be converted into the other.
If image and data of a ZUGFeRD invoice differ, the data has prevailed since 2025. Looking at the image alone is therefore not enough.
How do I open and check an e-invoice?
An XRechnung is an XML file. In a browser or text editor you only see code. Validation shows whether an invoice meets the standard. It is not a direct requirement for deducting input VAT, but the German Federal Ministry of Finance considers it useful and recommends validating invoices as early as when they are created and sent. It does not recommend any particular tool.
The free Visual Invoice reader shows the invoice in plain language, checks it against the rules of EN 16931 and recalculates totals and taxes. It does not check the additional XRechnung rules. The file stays in your browser.
What if the check report finds errors?
The check report shows which rule of the standard is broken and explains the finding in plain words. Pass the findings on to the sender. They can correct the invoice and send it again.
How do I issue e-invoices?
With a program that produces the invoice data in the right format. Visual Invoice writes your invoices as ZUGFeRD or XRechnung, works out totals and VAT and checks the mandatory details. The Basis account is free.
Source of the legal details: German Federal Ministry of Finance, questions and answers on e-invoicing (in German). As of October 2026. This page gives an overview and is not tax advice.
