Germany e-Invoicing Mandate 2027
Decentralised exchange · EN 16931 formats (XRechnung, ZUGFeRD)
E-invoicing is being phased in for domestic B2B transactions in Germany. Every business has had to be able to receive structured e-invoices (XRechnung or ZUGFeRD) since 1 January 2025. Issuing becomes mandatory on 1 January 2027 for businesses whose previous year's turnover exceeded EUR 800,000, and on 1 January 2028 for all businesses. B2G e-invoicing has been mandatory at federal level since 27 November 2020.
| Status | Phased |
|---|---|
| Legal basis | Wachstumschancengesetz (Growth Opportunities Act, March 2024) amending §14 UStG; BMF circulars of 15 October 2024 and 15 October 2025 |
| Phase-in | 4 phases, 2020 to 2028 |
| Scope | B2G: Mandatory · B2B: Mandatory · B2C: Not required |
| Format | XRechnung, ZUGFeRD from version 2.0.1 (PDF/A-3 with embedded XML; MINIMUM and BASIC-WL profiles excluded) · EN 16931 |
| Platform | Direct exchange between the parties (email is sufficient) · Decentralised exchange with no central clearance platform; a transaction reporting system is planned for a later stage |
| Penalties | Fines of up to EUR 5,000 per violation where an invoice is not issued or not issued on time (§26a UStG) |
Phase-in timeline
2020 to 2028- 2020B2G e-invoicing mandatory for suppliers to federal authorities
- 2025All businesses must be able to receive structured e-invoicesToday
- 2027Issuing mandatory for businesses with previous-year turnover above EUR 800,000previous-year turnover > EUR 800,000
- 2028Issuing mandatory for all businesses
Mandate at a glance
Verified Jul 2026- B2G mandatory
- B2B mandatory
- B2C not required
- Non-residents: out of scope
- XRechnung
- ZUGFeRD from version 2.0.1 (PDF/A-3 with embedded XML; MINIMUM and BASIC-WL profiles excluded)
- EN 16931
- Direct exchange between the parties (email is sufficient)
- Periodic reporting (not real-time)
- 8 years
- Digital signature: optional
- Storage: EU
- Fines of up to EUR 5,000 per violation where an invoice is not issued or not issued on time (§26a UStG)
- Risk to input VAT deduction where no compliant invoice exists
Full technical breakdown: Germany guide on e-Invoice.app
Is e-invoicing mandatory in Germany?
Partly. The mandate is being phased in. E-invoicing in Germany is mandatory for B2G, B2B transactions. Germany operates a decentralised model via Direct exchange between the parties (email is sufficient). Non-resident businesses are outside the scope of the mandate.
What are the Germany e-invoicing deadlines?
The next Germany e-invoicing deadline is 1 January 2027: Issuing mandatory for businesses with previous-year turnover above EUR 800,000 (previous-year turnover > EUR 800,000).
| Date | Scope | Obligation | Threshold |
|---|---|---|---|
B2G | B2G e-invoicing mandatory for suppliers to federal authorities | None | |
B2B | All businesses must be able to receive structured e-invoices | None | |
Upcoming | B2B | Issuing mandatory for businesses with previous-year turnover above EUR 800,000 | previous-year turnover > EUR 800,000 |
Upcoming | B2B | Issuing mandatory for all businesses | None |
What format and platform does Germany require?
Germany requires e-invoices in XRechnung or ZUGFeRD from version 2.0.1 (PDF/A-3 with embedded XML; MINIMUM and BASIC-WL profiles excluded) (EN 16931), exchanged via Direct exchange between the parties (email is sufficient) on a non-real-time basis. Invoices must be retained for 8 years. For format specifications and implementation detail, see the full Germany technical guide on e-Invoice.app.
What are the penalties in Germany?
- Fines of up to EUR 5,000 per violation where an invoice is not issued or not issued on time (§26a UStG)
- Risk to input VAT deduction where no compliant invoice exists
What changed recently?
- The BMF published a second circular on the mandatory e-invoice, updating the VAT application decree and clarifying open questions from the 2024 circular.
- Receipt obligation began; all German businesses must be able to accept structured e-invoices.
- The retention period for invoices under §14b UStG was reduced from ten to eight years by the Fourth Bureaucracy Relief Act.
- The BMF published its implementing circular confirming formats, thresholds and the phase-in calendar.
Need the full Germany compliance detail?
This page is a high-level snapshot. For registration procedures, technical specifications, exemption rules and implementation guidance, see the detailed Germany country guide on our partner site e-Invoice.app.
Germany e-invoicing guide on e-Invoice.appGermany e-invoicing: frequently asked questions
Does the EUR 800,000 threshold exempt small businesses entirely?
No. It only delays the issuing obligation by one year, to 1 January 2028, and the obligation to receive e-invoices has applied to businesses of every size since 1 January 2025. Small businesses using the §19 UStG small-business scheme are, however, exempt from the issuing obligation altogether; they must still be able to receive e-invoices.
Is a PDF invoice an e-invoice in Germany?
No. Since January 2025 a plain PDF no longer counts as an electronic invoice. An e-invoice must contain structured data compliant with EN 16931, such as XRechnung or the XML part of ZUGFeRD.
Are any transactions exempt from the German mandate?
Some transactions are exempt, including small-value invoices (up to EUR 250), tickets, supplies to consumers and many supplies exempt under §4 numbers 8 to 29 UStG. The full exemption list and cross-border edge cases are covered in the detailed Germany guide on e-Invoice.app.
More detailed questions? See the full Germany guide on e-Invoice.app.
Sources
This page was verified against the following sources on 23 July 2026.
- Fragen und Antworten zur Einführung der obligatorischen E-Rechnung (Bundesministerium der Finanzen)
- BMF-Schreiben: Einführung der obligatorischen elektronischen Rechnung (15 October 2025) (Bundesministerium der Finanzen)
- § 26a UStG Bußgeldvorschriften (Gesetze im Internet (Bundesamt für Justiz))
- eInvoicing in Germany (European Commission)
- Shortening of retention periods for invoices from 2025 (KMLZ)
- Germany B2B e-invoicing mandate: requirements and timeline (EDICOM)
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