Germany’s e‑invoice mandate 2025–2028: deadlines, exceptions, and practical steps

• In 2026: domestic businesses must be able to receive e‑invoices. For qualifying supplies, paper remains permitted only if the invoice is issued and transmitted by 31 December 2026; sending a plain PDF electronically generally requires recipient consent.
• Issuing in 2027: businesses whose 2026 total turnover exceeded EUR 800,000 generally need e‑invoices for in-scope supplies performed in 2027. Issuers at or below that threshold can use the turnover-based transition through 31 December 2027.
• Issuing from 2028: the e‑invoice rule generally applies to all in-scope transactions between domestic businesses, regardless of turnover. Permanent statutory exceptions remain.
• PDF invoices: a plain PDF is not an e‑invoice, but it can remain a valid “other invoice” while a transition or permanent exception applies.

Last materially reviewed: 8 August 2026. Legal basis checked against the BMF FAQ (as of March 2026) and the current statutory text.

This guide provides general information and is not legal or tax advice. Special cases should be checked against the official sources or with a qualified adviser.

• What counts as an e‑invoice
• Deadlines for 2025, 2026, 2027, and 2028
• Who is affected and which exceptions apply
• How to receive and send e‑invoices
• When a PDF invoice is still valid
• Validation and eight-year retention
• Practical readiness checklist

For German VAT purposes, an e‑invoice contains structured electronic data that allows automatic and electronic processing. XRechnung and suitable ZUGFeRD profiles that comply with EN 16931 are common examples. Other agreed formats can also qualify if they allow the required invoice data to be extracted correctly and completely into a format that complies with, or is interoperable with, EN 16931.

All invoice details required by sections 14 and 14a UStG must generally be included in the structured component. Attachments may add supporting detail, but generally cannot replace required structured data. For a final invoice, however, the deduction of received partial payments under section 14(5) UStG may be shown in an unstructured attachment if the structured component expressly refers to it; this remains permitted after 2027.

A plain PDF, image, or scan is an “other invoice”, not an e‑invoice. That classification does not automatically make the invoice invalid: transition rules and permanent exceptions can still permit it.

A business is domestic when its registered office, management, or a participating permanent establishment is in Germany—or, if it has no registered office, when the entrepreneur’s residence or habitual abode is in Germany. A German VAT registration by itself does not necessarily make a foreign business domestic for these rules.

If either party is not domestic under that test, the German domestic B2B issuing mandate does not apply to the transaction. A German VAT registration alone does not change that result, although foreign, B2G, or contractual requirements may still apply.

The EUR 800,000 test uses the issuer’s total turnover in the previous calendar year. For supplies performed in 2027, that means total turnover in 2026; the transitional invoice must be issued and transmitted by 31 December 2027. “Total turnover” is the statutory measure under section 19(2) UStG, not simply financial-statement revenue.

Read the detailed guide to the 2027 EUR 800,000 transition.

Receiving and issuing are separate questions. A business can be required to receive e‑invoices even when its own supplies are exempt from mandatory e‑invoice issuance.

For domestic entrepreneurs, there is no general receiving exception based solely on turnover, legal form, or sector. This can include freelancers, solo self-employed people, landlords, doctors, agricultural and forestry businesses, and operators of photovoltaic systems—even when they only make VAT-exempt supplies.

In the table, “receive” shows whether the recipient generally must be able to receive e‑invoices—not whether every individual invoice in that row must be electronic.

“Kleinunternehmer” is a VAT status under section 19 UStG—not a synonym for every small company or Kleingewerbe, and not the EUR 800,000 transition test. Businesses using this regime may still issue compliant e‑invoices voluntarily.

Read the complete Kleinunternehmer guide to receiving, issuing, PDFs, and retention.

Tax law does not prescribe one B2B transmission channel. An email inbox is sufficient for receiving; the parties can instead agree an interface, portal, shared storage location, or physical data medium. B2G portals can impose separate channel and reference requirements.

• A compliant e‑invoice for an in-scope transaction does not require the recipient’s consent.
• When permitted, a plain PDF, JPG, or similar electronic “other invoice” generally requires recipient consent. Paper invoices used during a transition do not.
• Agree the format, address or portal, and any buyer reference before sending. Recipient process requirements can be stricter than the minimum tax rules.

Learn how to receive, open, and check e-invoices, handle errors, request corrections, and retain the original files.

Yes, in permitted cases. A plain PDF is not an e‑invoice, but it can remain a valid “other invoice” under an applicable transition rule or permanent exception when all other invoice requirements are met.

• An “other invoice” can be used for a supply performed after 31 December 2024 and before 1 January 2027 only if it is issued and transmitted by 31 December 2026.
• In 2027, a plain PDF may still be permitted under the EUR 800,000 turnover transition or a permanent exception.
• When such an invoice is sent electronically, the recipient’s consent is generally required. Consent can be established by the parties’ practice; the law does not prescribe a special form.
• An otherwise correct invoice does not lose eligibility for input VAT deduction merely because a permitted “other invoice” format was used.

Convert PDF to XRechnung or convert PDF to ZUGFeRD.

What validation can—and cannot—confirm

Technical validation is recommended because it can identify format, calculation, and business-rule errors. It is not a legal prerequisite for tax recognition and cannot guarantee factual correctness, authenticity, acceptance by the recipient or portal, or payment. However, a file that does not meet the applicable structured-format requirements is an “other invoice”, so technical conformity still matters when an e‑invoice is required.

Keep the validation report as evidence of your review process. It does not replace the original invoice or the required content check.

Always review the supplier’s identity, bank details, amounts, VAT treatment, and recipient-specific requirements. If an incoming supplier invoice is wrong, request a proper correction instead of silently editing the received document.

If the issuing obligation applies, a correction must generally also be issued as an e‑invoice. If a transition rule still permits an “other invoice”, that permitted format can also be used for the correction.

Validate an e‑invoice

Retain invoices for eight years

The VAT retention period for invoices is generally eight years. At least the structured component of an e‑invoice must be retained unchanged, machine-readable, and in its original form throughout that period. The period begins at the end of the calendar year in which the invoice was issued.

For a hybrid e‑invoice, such as ZUGFeRD in a qualifying profile, the structured data is decisive if it conflicts with the visible PDF. A rendered copy is useful for people, but it does not replace retention of the original structured component. Tax-relevant supplementary documents may have their own original-form retention requirements. For VAT purposes alone, storing an e‑invoice outside a GoBD-compliant system is not automatically a breach of section 14b UStG; separate bookkeeping and tax-retention duties may still apply.

View an XML e‑invoice

1. Classify transactions as B2B, B2C, or B2G; then check whether the Kleinunternehmer exemption or another statutory exception applies.
2. Set up a monitored email address or agreed channel for receipt, with clear internal responsibilities.
3. Ensure staff can display XML-only invoices in a human-readable form.
4. Ask customers which format, transmission route, and references they require before sending.
5. Test conversion, validation, manual review, and export with real invoices before your issuing deadline.
6. Define a correction process: use the required invoice format for outgoing corrections, and request proper corrections from suppliers for incoming invoices.
7. Archive at least the original structured component unchanged for the eight-year VAT retention period.

• Federal Ministry of Finance: e‑invoice FAQ (as of March 2026)
• Section 14 UStG: invoices and definition of an e‑invoice
• Section 19(2) UStG: total turnover used for the 2027 threshold
• Section 27(38) UStG: transition rules
• Section 34a UStDV: exemption for supplies under the Kleinunternehmer regime
• Section 34 UStDV: passenger transport tickets used as invoices
• Section 14b UStG: invoice retention

Run a complete test cycle—PDF upload, data review, structured output, validation, correction, and export—before the deadline that applies to your business.