Germany e-invoicing mandate: dates, formats, GoBD

What the German e-invoicing mandate is

The German e-invoicing mandate (E-Rechnungspflicht) requires businesses established in Germany to use structured electronic invoices for domestic B2B supplies. Every business has had to be able to receive them since 1 January 2025; issuing becomes mandatory from 1 January 2027 or 2028, depending on prior-year turnover. It matters because a PDF will no longer count as a valid invoice once the transition ends.

The legal basis is section 14 of the German VAT Act (UStG), rewritten by the Growth Opportunities Act of 2024. An e-invoice is now defined as an invoice that is issued, transmitted and received in a structured electronic format that allows electronic processing. Everything else, paper included, is an other invoice (sonstige Rechnung). The Federal Ministry of Finance (BMF) explains the rules in its guidance letters of 15 October 2024 and 15 October 2025 and in its FAQ, which are the sources for the dates below, checked as of September 2026.

The timeline: receive since 2025, issue from 2027 or 2028

The mandate applies to supplies between businesses established in Germany. The receiving obligation came first and has no threshold. The issuing obligation phases in, and during the transition an other invoice remains permitted only on the conditions listed here.

Public-sector invoicing was already ahead of this timeline. Suppliers to federal authorities have had to send e-invoices since 27 November 2020 under the federal E-Invoicing Ordinance, usually as XRechnung with a buyer reference (Leitweg-ID), and the federal states have their own rules. A business that already invoices public bodies therefore has a head start on formats, but not necessarily on receiving, which the B2B mandate adds.

• Since 1 January 2025: every domestic business must be able to receive e-invoices; the BMF confirms that an e-mail inbox is enough to meet this
• 2025 and 2026: every issuer may still send paper invoices; other electronic formats such as a plain PDF only with the recipient's consent
• From 1 January 2027: businesses whose prior-year total turnover exceeded EUR 800,000 must issue e-invoices for domestic B2B supplies
• Throughout 2027: businesses with prior-year turnover of EUR 800,000 or less may still issue paper or, with consent, other electronic invoices
• Until 31 December 2027: existing EDI procedures that do not meet the e-invoice definition may continue
• From 1 January 2028: all domestic B2B invoices must be e-invoices, whatever the issuer's size
• From 1 July 2030: EU-wide e-invoicing and digital reporting for intra-EU B2B supplies under the ViDA package

The EUR 800,000 threshold, worked through

The threshold looks at total turnover (Gesamtumsatz) as defined in section 19(2) UStG for the previous calendar year. It is tested once, for 2027 only; from 2028 there is no threshold left to test. Three German companies show how it works.

Company A, a wholesaler, had total turnover of EUR 2,400,000 in 2026. It may send PDF or paper invoices until 31 December 2026 and must issue e-invoices from 1 January 2027. Company B, a small engineering firm, had EUR 720,000 in 2026. It may keep issuing other invoices throughout 2027 and must switch on 1 January 2028. If Company B's turnover rises to EUR 950,000 in 2027, nothing changes, because the universal obligation of 2028 applies to it anyway.

Company C sells EUR 20,000 a year and uses the small business scheme (Kleinunternehmer) in section 19 UStG, which since 2025 is open to businesses whose turnover did not exceed EUR 25,000 in the previous year and does not exceed EUR 100,000 in the current year. It never has to issue e-invoices under this scheme, but it has had to be able to receive them since 2025. The practical lesson is to plan groups by the earliest date that applies to any entity, and to treat receiving as a live obligation for every entity today.

What is outside the mandate

The obligation is narrower than the word mandate suggests. It covers only invoices between businesses established in Germany, so the following remain free to use paper or other formats, subject to the ordinary invoicing rules.

• Small-amount invoices (Kleinbetragsrechnungen) up to EUR 250 gross
• Travel tickets (Fahrausweise)
• Invoices issued by small businesses under section 19 UStG
• Invoices to consumers and to other non-business recipients (B2C)
• Cross-border invoices to or from businesses not established in Germany, until the ViDA rules for intra-EU supplies apply in 2030

XRechnung vs ZUGFeRD and the EN 16931 standard

Germany does not prescribe a single format. An e-invoice must follow the European standard EN 16931, or another format the parties agree on if it allows the required data to be extracted correctly and completely and is interoperable with EN 16931. In practice two families dominate.

XRechnung is a pure XML invoice: a German core invoice usage specification (CIUS) of EN 16931, in UBL or UN/CEFACT CII syntax, already required for invoices to federal public bodies. ZUGFeRD is a hybrid: a PDF/A-3 that people can read, with a CII XML file embedded inside it. ZUGFeRD 2.0.1 and later qualify, except the MINIMUM and BASIC-WL profiles, which do not carry a full invoice. ZUGFeRD and the French Factur-X are technically the same standard.

With a hybrid invoice, the structured part now leads. If the PDF image and the XML disagree, the BMF treats the XML as the invoice. That reverses decades of habit: the accountant who checks the picture and posts from it is checking the wrong document.

• XRechnung: XML only, needs a viewer to be read by a person, standard for public-sector invoicing
• ZUGFeRD EN 16931 or EXTENDED profile: readable PDF plus embedded XML, popular for B2B
• ZUGFeRD MINIMUM and BASIC-WL: not valid e-invoices under the mandate
• Plain PDF by e-mail: an other invoice, allowed only during the transition and with consent
• EDI: allowed until the end of 2027 even if it does not meet EN 16931

Receiving e-invoices in practice

Being able to receive sounds trivial because an e-mail address suffices, but receiving is where most finance teams are exposed. An XRechnung file opened by an e-mail client shows code, not an invoice, and since 2025 a recipient cannot refuse an e-invoice that a supplier sends lawfully or insist on paper instead. From 2027, when a supplier is obliged to issue an e-invoice, a paper or PDF invoice from that supplier is not a proper invoice, which can put the recipient's input VAT deduction at risk.

The workable design has four steps: a dedicated inbox for invoices, validation of the XML against EN 16931, visualisation for the approver, and posting from the data rather than retyping. Decide what happens to an e-invoice with no purchase order, an unknown supplier or a price difference before the first one arrives.

• Publish one invoice e-mail address to suppliers and keep it out of personal mailboxes
• Validate each XML file and reject technically invalid invoices promptly
• Show approvers a readable rendering generated from the XML, not a separate PDF
• Archive the original XML unchanged, whatever you do with the data afterwards

Worked example: posting an e-invoice and correcting it

A supplier issues an XRechnung for goods: net EUR 10,000, VAT at 19 percent EUR 1,900, total EUR 11,900. The buyer validates the file, matches it to the order and posts: Dr Purchases 10,000 / Dr Input VAT 1,900 / Cr Trade payables 11,900. The XML file is archived as the original record.

Two weeks later, goods worth EUR 1,000 net are returned. The supplier issues a corrective invoice as an e-invoice that refers to the original number: net 1,000, VAT 190, total 1,190. The buyer posts Dr Trade payables 1,190 / Cr Purchases 1,000 / Cr Input VAT 190, leaving a payable of EUR 10,710. Neither file is edited or replaced.

Watch the word Gutschrift. In German VAT law it means a self-billed invoice issued by the customer, not a commercial credit note. Label corrections as a corrective or cancellation invoice (Rechnungskorrektur or Stornorechnung) unless you really are self-billing, and remember that self-billed invoices fall under the same e-invoice rules.

GoBD archiving for e-invoices

The GoBD are the BMF's principles for keeping books and records electronically. They require records to be complete, correct, timely, orderly and unalterable, and to remain machine-readable for the whole retention period. For e-invoices this means the structured file itself must be kept, in its original form and unchanged.

Retention of invoices and other accounting vouchers is eight years, following the 2025 reduction from ten; books and annual financial statements remain at ten years. For a hybrid ZUGFeRD invoice the XML is the part that must be kept; if the PDF part carries extra information relevant to the booking, keep that part too and confirm the approach with your tax adviser (Steuerberater).

The tax authorities have rights of data access during an audit under section 147(6) of the Fiscal Code: direct access to the system, indirect access through the business's staff, and delivery of the data on a storage medium. An archive that holds only printouts or images of e-invoices fails all three.

• Keep the original XML unchanged; a converted copy may be kept in addition, never instead
• Store it so it can be found from the posting and the posting from it
• Keep a written procedural documentation (Verfahrensdokumentation) of how invoices arrive, are checked, posted and archived
• Keep the records machine-evaluable for eight years, including after a software change
• Log changes: who did what and when, with the original value retained

What an accounting system must do for the German mandate

The mandate is a data exchange problem, and each weak spot in master data becomes a rejected or invalid invoice. Before choosing a system or an e-invoicing provider, check it against this list.

Then decide between generating and receiving e-invoices inside the accounting system or through a specialist provider. The first keeps one record per invoice; the second can be faster to deploy but needs a reliable interface so that invoice data, status and the archived file stay linked to the ledger entry. Whichever you choose, test with your ten largest customers and suppliers well before the date that applies to you, because their master data will fail first.

• Issue XRechnung and qualifying ZUGFeRD invoices, validated against EN 16931 before sending
• Receive, validate and visualise incoming XML and post purchases from the data
• Hold complete master data: legal names, addresses, VAT IDs, buyer references (Leitweg-ID for public bodies)
• Carry the correct VAT category and exemption reason on every line, not just a rate
• Number invoices uniquely and link every correction to the original
• Lock issued invoices so corrections happen only by further documents
• Archive the structured file for eight years in a GoBD-compliant way
• Know, per legal entity, which transition rule applies in 2026 and 2027

E-Rechnung and Skyline Nexus ERP

Skyline Nexus ERP already provides the ledger disciplines the German mandate rests on. Invoice numbering schemes are set per business location with a prefix and sequence, tax rates and tax groups are maintained centrally, and the VAT return and the VAT GL accounts are computed on the same basis. Posted journals are corrected by reversal rather than edited, fiscal periods can be closed and locked, and the Accounting Audit Trail records who changed what, with old and new values. Skyline Nexus ERP runs in English and Arabic, with interface translations for German among many other languages.

Native XRechnung and ZUGFeRD connectors for Germany are being rolled out market by market; tell us that you invoice in Germany and we will confirm your go-live date. Until then, the workable route is to connect an e-invoicing provider that produces and receives EN 16931 files, feeding it sales, returns, contacts and taxes through the Skyline Nexus REST API, while archiving the XML files in a GoBD-compliant archive. Ask for a demonstration with your own invoice scenarios.