German e-invoicing mandate: does it apply to you?
Enter who you invoice and your turnover: the check shows when you must issue e-invoices and what you must already be able to receive.
Issue e-invoices from
1 January 2028
2026 turnover up to €800,000: paper and PDF remain allowed in 2027, e-invoices become mandatory on 1 January 2028.
| Be able to receive e-invoices | Required since 1 January 2025 |
| Paper or PDF (with consent) until | 31 December 2027 |
| EDI without EN 16931 until | 31 December 2027 |
| Always allowed on paper or as PDF | Small amounts up to €250, tickets |
Basis: sections 14(1), 14(2) and 27(38) UStG; sections 33, 34, 34a UStDV; Finance Ministry letter of 15 October 2025.
Prepared by Radif Partners · Method · VAT Act, ministry letters and XRechnung 3.0.2 checked on 25 October 2026
The German e-invoicing mandate covers supplies between businesses established in Germany. Since 1 January 2025 every business in Germany must be able to accept an e-invoice; there is no transition period for receiving, and an email inbox is enough. For issuing, the transitional rules of section 27(38) of the VAT Act (UStG) apply. Until the end of 2026 you may still send paper or PDF invoices, a PDF only with the customer's consent. In 2027 this remains allowed only if your total turnover in the previous year was no more than 800,000 euros; from 1 January 2028 the e-invoice is mandatory for all domestic B2B invoices. Exceptions cover invoices up to 250 euros, travel tickets, most VAT-exempt supplies and small businesses, which may always issue an ordinary invoice. Invoices to consumers are not affected. Only a structured format under the European standard EN 16931 counts as an e-invoice, such as XRechnung or ZUGFeRD from version 2.0.1; a plain PDF does not.
The three stages of the mandate
The Growth Opportunities Act rewrote section 14 UStG. Whether an invoice must be electronic now depends on two questions: is the supply made to another business, and are both established in Germany? If so, the e-invoice is the rule. When you actually have to issue one is set by the transitional provision in section 27(38) UStG.
| Period | Receiving | Issuing |
|---|---|---|
| from 1 January 2025 | Required for every business | Paper or PDF still allowed, PDF with consent |
| until 31 December 2026 | Required | Paper or PDF allowed for everyone |
| during 2027 | Required | Paper or PDF only if prior-year turnover is up to €800,000; EDI with consent |
| from 1 January 2028 | Required | E-invoice for all domestic B2B supplies |
Receiving has no grace period. In its letter of 15 October 2025 the Federal Ministry of Finance confirms that a business may not refuse an e-invoice and that an email inbox is enough to accept one. The duty to issue grows in steps: larger businesses from 2027, everyone from 2028.
Who is not affected
Some exceptions are in the Act itself, others in the implementing regulation (UStDV). In these cases you may keep issuing a paper or PDF invoice after 2027 if the customer agrees:
- Small-amount invoices up to €250 gross under section 33 UStDV, such as restaurant receipts and till purchases.
- Travel tickets under section 34 UStDV, such as rail and flight tickets.
- VAT-exempt supplies under section 4 nos. 8 to 29 UStG, for example residential lettings, medical treatment or insurance.
- Small businesses: under section 34a sentence 4 UStDV they may always issue an ordinary invoice. They must still be able to receive.
Cross-border invoices fall outside the German mandate. A French supplier or a customer in Austria is not established in Germany, so the invoice form between you stays free as long as both agree. The same goes for supplies to associations or public bodies that do not act as businesses; invoices to the federal administration, however, have been governed by the E-Invoicing Regulation for years, see e-invoicing the federal government.
Check whether one invoice is allowed in a given year
The everyday question is rarely “does the mandate apply” but “may I still send this one invoice as a PDF”. That depends on the year of supply, the previous year’s turnover and the type of invoice. The small calculator answers exactly that:
This invoice form is
This invoice form is
Only with the customer’s consent
| 2025 | Only with the customer’s consent |
| 2026 | Only with the customer’s consent |
| 2027 | Only with the customer’s consent |
| 2028 on | No longer allowed |
What counts as an e-invoice
Under section 14(1) UStG an e-invoice is an invoice in a structured electronic format that allows electronic processing and complies with the European standard EN 16931. In Germany the common formats are XRechnung and ZUGFeRD. ZUGFeRD combines a readable PDF with an embedded XML file; it counts as an e-invoice from version 2.0.1 and only in the profiles from BASIC upwards, not in MINIMUM or BASIC WL. Other formats such as EDI messages are allowed if the data can be converted correctly and completely into an EN 16931 format. The details are on what is an e-invoice?, and the choice of format on XRechnung or ZUGFeRD.
What to do now
Set up receiving first, because it is already required: a fixed address for invoices, a program or viewer to read them and storage that keeps the XML file unchanged. The retention period is 8 years. Most businesses have until the end of 2026 for issuing; still, check now whether your accounting or invoicing software produces XRechnung or ZUGFeRD. Without software of your own you can write single invoices with the free invoice creator.