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Germany's e-invoicing regulation timeline

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Executive summary

Germany distinguishes clearly between B2G and B2B electronic invoicing. For B2G, the XRechnung format—based on EN 16931 and implemented in UBL or CII syntax—has been mandatory since November 2020 for all invoices to public authorities, typically exchanged via the Peppol network. For B2B, businesses must be able to receive structured e-invoices compliant with EN 16931, while issuing such invoices will become mandatory from Jan 2027 for companies with prior-year turnover above €800,000, and from January 2028 for all businesses in domestic B2B transactions. Small-amount invoices of €250 or less (VAT included), passenger transport tickets, and most VAT-exempt supplies stay outside the obligation and can still be issued on paper or as PDF. ZUGFeRD, a hybrid PDF + XML format aligned with EN 16931 and equivalent to France’s Factur-X, is accepted alongside XRechnung. Germany is preparing for EU-wide Digital Reporting Requirements (ViDA), expected around 2030, which will introduce VAT e-reporting requirements based on EN 16931 data. Structured invoices must be archived in their original XML format for eight years, in compliance with GoBD rules ensuring data integrity, readability, and domestic accessibility. Invopop provides coverage for German invoicing through the OASIS UBL and ZUGFeRD apps, supporting both XRechnung and ZUGFeRD formats. The platform also offers integrations with Stripe and Chargebee, enabling businesses to issue compliant invoices directly from their merchant or ERP platforms while automatically handling format compliance and Peppol network routing when required.

Invoicing in Germany

Electronic invoicing is well established and regulated, with a clear distinction between B2G and B2B/B2C transactions. For B2G, the XRechnung format is mandatory for invoices to public authorities, and these are primarily exchanged via the Peppol network or authorized access points. Since January 2025, all German businesses must be able to receive structured e-invoices compliant with EN 16931; B2C invoicing remains unregulated in format. Under the recently passed Wachstumschancengesetz (Growth Opportunities Act), Germany will implement a phased rollout for domestic B2B invoicing in structured electronic formats. For more information, check the ZUGFeRD section below.
XRechnung is Germany’s standard for e-invoices in public procurement (B2G, called E-Rechnungen), though it can also be used for B2B transactions. It’s part of the implementation of the EU directive 2014/55/EU, which requires all contracting authorities in the EU to accept electronic invoices in a structured XML file. It can be implemented using two different syntaxes, CII and UBL.
ZUGFeRD is a German standard for electronic invoicing designed to bridge the gap between traditional invoices and digital formats. ZUGFeRD combines a standard PDF/A-3 invoice with an embedded XML file containing the structured data. This hybrid approach is well suited for B2B transactions, as it allows both people and accounting software to work with the same document. It is fully aligned with the European Norm EN 16931. It is worth noting that ZUGFeRD and Factur-X are a joint project between Germany and France, and their content is identical.

E-reporting

Germany is aligning with the EU’s ViDA directive, which projects Digital Reporting Requirements (DRRs). Digital reporting obligation is likely around 2030 or later for Germany, though exact timelines and legal details are not yet fixed. The forthcoming reporting model would require EN 16931 compliant data enabling tax authorities to access invoice‑level data for VAT monitoring and fraud prevention.

Regulation

In July 2025, the Ministry of Finance made public how structured e-invoices must be archived:
  • Only the XML must be archived (even if it’s a ZUGFeRD hybrid) the embedded XML is the tax‑binding element. PDFs are optional if a readable view can be generated.
  • Invoices must be stored in the XML format received (CII or UBL), even if converted internally, to satisfy audit requirements.
  • Data generally must remain in Germany and must comply with GoBD.
  • Germany shortened the invoice archival period from 10 to 8 years.
The B2B issuing obligation is phased in. The €800,000 turnover threshold only applies during the transition:
  • Until 31 December 2026: any business can still issue paper invoices. Other electronic formats, such as plain PDF, are allowed if the customer agrees.
  • During 2027: only businesses with a prior-year turnover of €800,000 or less can keep issuing paper or non-structured electronic invoices.
  • From 1 January 2028: every domestic B2B invoice must be a structured e-invoice (XRechnung or ZUGFeRD), regardless of turnover, unless one of the exemptions below applies.
Some invoices are excluded from the obligation altogether and can still be issued as regular invoices, such as paper or PDF. The BMF letter of 15 October 2024 lists them as:
  • Small-amount invoices (Kleinbetragsrechnungen) with a total of €250 or less, VAT included (§ 33 UStDV). The limit applies to each invoice separately, so a business that otherwise has to e-invoice can still send a PDF for an invoice of €250 or less.
  • Passenger transport tickets (§ 34 UStDV).
  • Tax-exempt supplies under § 4 Nr. 8 to 29 UStG.
The receiving obligation has no exemptions: every German business has had to be able to receive e-invoices since 1 January 2025.
Germany’s e‑invoicing compliance is strict and technical, especially around invoice content, format, and archiving:
  • Legally required invoice elements: seller/buyer tax IDs, invoice number, date, line‑item details, VAT breakdowns, and references to contracts or purchase orders if applicable. Missing or incorrect data can make an invoice legally invalid.
  • Structured formats: For B2G, this is XRechnung; for future B2B mandates, invoices will need to be EN 16931-compliant (XRechnung or ZUGFeRD). PDFs without an XML attachment are insufficient for mandated channels.
  • Archiving: All invoices, whether received or issued, must be retained digitally and unaltered for 8 years in a compliant system.

FAQ

Compliance questions Germany
Receiving capability has been mandatory since 1 January 2025. Issuing becomes mandatory on 1 January 2027 for companies with prior-year turnover above €800k, and 1 January 2028 for everyone else. B2G has been mandatory since 2020.The €800k threshold only applies during the transition. Until the end of 2026 any business can still send paper invoices, and PDF invoices if the customer agrees. In 2027 only businesses at or below €800k can keep doing so. From 2028 every domestic B2B invoice above €250 must be an e-invoice, regardless of turnover.
Yes. Small-amount invoices (Kleinbetragsrechnungen) with a total of €250 or less, VAT included, can still be issued as regular invoices, such as paper or PDF (§ 33 UStDV). The limit applies to each invoice separately, so a business that otherwise has to e-invoice can still send a PDF for an invoice of €250 or less. Above €250, a structured e-invoice (XRechnung or ZUGFeRD) is required.Passenger transport tickets (§ 34 UStDV) and supplies that are tax-exempt under § 4 Nr. 8 to 29 UStG are also excluded, as listed in the BMF letter of 15 October 2024. These exemptions only cover issuing: every German business must still be able to receive e-invoices.
Timing is linked to contractual and procedural deadlines, not a specific law that defines a universal submission window. However, in the context of B2G many authorities specify invoice submission within 10 days of service completion in their contracts or portals, so it’s best to issue the invoice as early as possible.In the case of B2B the general VAT rule states that the invoice must be issued within 15 days after the end of the month in which the supply was made, if the transaction is subject to VAT and involves another taxable business. This 15-day window is critical because late issuance can make VAT reporting inconsistent between supplier and customer and it may also affect the buyer’s right to input VAT deduction.
Any entity with a Steuernummer (tax number) or USt-IdNr (VAT ID). Foreign suppliers selling into German B2G need a valid VAT ID and a Leitweg-ID provided by the recipient.
For B2G, the supplier must include the recipient’s Leitweg-ID (the German B2G routing identifier) in the BuyerReference field. For B2B, no extra obligations beyond the standard Peppol participant registration.
Monthly or quarterly Umsatzsteuer-Voranmeldung (USt-VA) and the annual Umsatzsteuerjahreserklärung. Cross-border B2B sales also require Zusammenfassende Meldung (EC sales list). E-reporting tied to e-invoicing is expected from 2028 but not yet legislated.
Peppol
Mandatory dates vary by country. Belgium requires structured B2B e-invoicing — Peppol BIS by default — from January 2026. Germany is phasing in B2B e-invoicing between 2025 and 2028. France’s Factur-X via Peppol applies once the PA reform takes effect. Outside mandates, Peppol delivery is voluntary but increasingly expected for B2G and cross-border trade.
Yes. Every document exchanged on Peppol BIS uses a UBL or CII syntax that conforms to the EN16931 European e-invoicing standard, plus the relevant Peppol BIS specification. Invopop generates compliant XML automatically when you use the Peppol app.
Peppol is a federated network — anyone could otherwise register a Participant ID for a company they don’t represent. Proof of ownership ties the Participant ID to a verifiable contact at the company, which is what allows the registration to be published on the SML.
Requirements vary by Authority. In Belgium, for example, the supplier must provide a recent extract from the Banque-Carrefour des Entreprises (KBO/BCE) plus a signed mandate. Invopop walks the registering party through the local requirements during the registration wizard.
Yes — a Peppol BIS document delivered through a certified Access Point is treated as the legal e-invoice in any country that recognises Peppol. The signed UBL or CII XML is the authoritative record; archive it alongside any human-readable rendering you generate.
Retention is set by each country’s tax authority — typically 7 to 10 years in the EU. Invopop preserves the original XML and any generated PDF in the silo entry so you can satisfy local archival requirements wherever you operate.
More available in our Germany FAQ section

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