E‑Rechnungs-StudioGermany’s e‑invoice mandate 2025–2028: timeline, transition rules & practical steps
According to the BMF FAQ (status October 2025), key obligations are already active. Since 01 Jan 2025, businesses must be able to receive e‑invoices. Transition periods for issuing run through 31 Dec 2026 and can extend through 31 Dec 2027 if prior‑year turnover (2026) is up to EUR 800,000. For these extension cases, full issuing obligation applies from 01 Jan 2028.
Note: This page summarizes BMF FAQ guidance (status October 2025) and provides general information, not legal or tax advice. Check official guidance for special cases.
What counts as an “e‑invoice” since 01 Jan 2025?
For VAT purposes, an e‑invoice is a structured electronic format that enables automated processing. A standard PDF is considered “other invoice” (not an e‑invoice).
Timeline (domestic B2B) — at a glance
1) Receiving obligation: from 01 Jan 2025
- All domestic businesses must be able to receive e‑invoices.
- An email inbox is sufficient to ensure receipt (practically: one shared address + process).
- Even small businesses may have to receive e‑invoices, even if exempt from issuing in some cases.
2) Issuing transition period: through 31 Dec 2026
Until 31 Dec 2026, issuers may still send “other invoices” instead of e‑invoices.
- Paper invoices remain possible.
- Electronic “other invoices” (e.g., PDF by email) generally require the recipient’s consent—like before.
3) Extension through 31 Dec 2027 (turnover condition)
The transition can extend through 31 Dec 2027 if the issuer’s prior‑year turnover (2026) is up to EUR 800,000.
4) EDI until end of 2027 (under conditions)
EDI procedures that do not yet meet the new e‑invoice requirements may also continue through 31 Dec 2027 under the statutory conditions.
5) Full issuing obligation from 01 Jan 2028 in extension cases
If the transition was extended due to the EUR 800,000 threshold, full e‑invoice issuing obligation applies from 01 Jan 2028. Otherwise, full obligation applies after the general transition deadline.
What does this mean for PDF invoices?
PDF invoices can still be used in transition periods in many cases, but a PDF by itself is not an e‑invoice in the VAT sense. If recipients require structured data, you need a valid XRechnung or ZUGFeRD output.
To avoid deadline pressure, convert and validate real invoices early. Start with the format your recipient expects:
Practical checklist: what to do now
- Enable receiving: shared mailbox + storage + responsibilities.
- Clarify formats: what do your customers/suppliers accept (XRechnung, ZUGFeRD)?
- Test early: convert real PDFs into e‑invoices and validate them.
- Build validation into your workflow: fix errors/warnings before sending.
- Ensure human readability: hybrid PDFs are readable; XML‑only invoices need a viewer.
- Document consent for PDFs (if you plan to keep sending PDF invoices during the transition period).
FAQ
From when do I have to be able to receive e-invoices?
Since January 1, 2025, businesses in Germany must be able to receive e-invoices.
From when does sending e-invoices become mandatory?
The requirement is phased in. Transition rules apply until the end of 2026 and in specific cases until the end of 2027. Issuing only becomes fully mandatory after those transition periods end.
Can I still send PDF invoices in 2026 and 2027?
During the transition period, PDFs as other electronic invoices are still possible, but generally require recipient consent.
Does the mandate also apply to small businesses?
Small businesses may be exempt from issuing in some cases, but they still need to be able to receive e-invoices.
What is the difference between XRechnung and ZUGFeRD for mandate compliance?
Both can meet the mandate when they are EN 16931 compliant. XRechnung is pure XML, while ZUGFeRD is a hybrid of PDF/A-3 and XML.
Is it free and without registration?
Yes. You can start conversion and validation for free without registration.
What data is stored and for how long?
Files and results are stored only as long as needed for processing. Details are documented in the privacy policy.
Next step
Use the transition window wisely: run a full test cycle (PDF → XML → validation → fixes → export) so your process is stable long before deadlines hit.