German e-invoicing mandate 2026/2027: what applies to you

You have had to be able to receive e-invoices since 1 January 2025. Sending is staggered: from 1 January 2027 for companies with more than €800,000 in prior-year revenue, and from 1 January 2028 for everyone else. Until then you may send paper or PDF if the recipient agrees.

For receiving, yes — that has applied since 2025. For sending, not yet: 2026 is the final year of the general transition period. Throughout 2026 you may still send PDF invoices, provided your customer agrees. From 1 January 2027 that ends for companies above €800,000 in revenue.

All domestic companies whose total revenue in the previous year exceeded €800,000 must issue e-invoices in business-to-business trade from 1 January 2027. Anyone below that threshold has until 31 December 2027. From 2028 the obligation applies to everyone.

No. It covers only invoices between domestic companies (B2B) and invoices to public authorities. You may keep issuing paper or PDF invoices to private customers. Private individuals themselves need not receive or process e-invoices.

The German mandate applies only to transactions between companies based in Germany. Invoices to other EU countries are not covered. That said, more and more EU states are introducing their own mandates, and the EU’s ViDA initiative (VAT in the Digital Age) foresees Europe-wide alignment. If you invoice internationally, check the rules of the destination country.

The legal basis is the Wachstumschancengesetz, which rewrote § 14 of the German VAT Act (UStG). The technical requirements follow the European standard EN 16931. For invoices to authorities the federal E-Rechnungsverordnung (ERechV) and the corresponding state regulations apply as well. The Federal Ministry of Finance has clarified application in several BMF letters.

No. Small businesses under § 19 UStG are exempt from issuing e-invoices and may keep sending PDF or paper indefinitely. They must, however, be able to receive e-invoices — and have been required to since 1 January 2025.

An invoice whose content sits in clearly named data fields, so software can read and validate it without retyping. The relevant standard is EN 16931. In Germany the two common formats are XRechnung (pure XML) and ZUGFeRD (PDF with embedded XML).

No. Since 2025 an ordinary PDF counts as an "other invoice", not an e-invoice — it holds only an image, not usable data. ZUGFeRD is the exception: there, structured XML data is embedded inside the PDF, which does meet the requirements.

No, they are two different formats — though both satisfy the legal requirements. XRechnung is a pure XML file, readable by humans only with a viewer, and common in dealings with public authorities. ZUGFeRD is a readable PDF with embedded XML data and is more widespread in B2B trade.

An XRechnung is an XML file. In a browser or text editor you will see only raw data. To read it you need a viewer — the public administration provides free tools, and any e-invoicing software displays the file as a normal invoice. With our e-invoice validator you can upload a file, view it and check it for format errors at the same time.

Legally, an email inbox the sender knows about is enough. In practice you also need something that makes the file readable and archives it in an audit-proof way — because what must be retained is the structured file itself, not a printout. Since 2025 you no longer have to give consent: a sender may send you an e-invoice without asking.

You need software that produces the format — writing XML by hand is not practical. In cashwerk you write the invoice as usual and choose XRechnung or ZUGFeRD when sending; the EN 16931 mandatory fields are filled from your master data. For invoices to authorities the customer’s Leitweg-ID is added.

Yes. Exempt are small-value invoices up to €250 gross, travel tickets, sales to private customers, invoices abroad and certain VAT-exempt services under § 4 nos. 8 to 29 UStG. Small businesses under § 19 UStG need not issue e-invoices but must be able to receive them.

Eight years. The Fourth Bureaucracy Relief Act (BEG IV) shortened the period for accounting documents from ten to eight years as of 1 January 2025 (§ 147 (3) AO, § 257 (4) HGB); it applies to all documents whose period was still running at that point. What must be kept is the original structured data set — a printout or a converted PDF is not sufficient. The GoBD additionally require the file to remain unchangeable and machine-readable.

Pure validators and viewers are often free — ours included. For creating and sending, programs in the German market typically range from roughly €10 to €50 per user per month. Current cashwerk rates are on the pricing page.

The most immediate consequence: your customer may reject a formally incorrect invoice, and without a proper invoice their input VAT deduction can be denied — which means queries and delayed payments. Formal errors can also be challenged during a tax audit. For specific doubts, your tax advisor is the right port of call.