In short
Since 1 January 2025, Germany has required an e-invoice as a rule between domestic businesses, and every domestic business must be able to receive e-invoices. Issuing has transition periods: for supplies up to the end of 2026 an invoice on paper is still allowed, and for supplies in 2027 only for businesses whose total turnover in the previous year was at most 800,000 euros.
This guide says what that means, which formats count and what to do first. It is not tax advice; the sources are at the end.
The deadlines
| Who | Receive | Issue |
|---|
| All domestic businesses | since 1 January 2025 | transition until 31 December 2026, then as an e-invoice |
| Businesses with at most 800,000 euros of total turnover in the previous year | since 1 January 2025 | transition until 31 December 2027, then as an e-invoice |
| Businesses that use EDI | since 1 January 2025 | EDI with the recipient's consent until 31 December 2027 |
During the transition the invoice may be issued on paper. Another electronic format, such as an ordinary PDF, is only allowed with the recipient's consent. Invoices to private consumers are not covered by the obligation.
These details come from the German VAT Act and from the questions and answers of the Federal Ministry of Finance (BMF), checked on 20 October 2026. Which turnover counts for the 800,000-euro limit is set by § 19 paragraph 2 of the VAT Act: have your tax adviser confirm it.
What an e-invoice is
Under § 14 paragraph 1 of the VAT Act, an e-invoice is an invoice that is "issued, transmitted and received in a structured electronic format" and allows electronic processing. An "other invoice" (sonstige Rechnung), by contrast, is "transmitted in another electronic format or on paper". An ordinary PDF is therefore not an e-invoice.
As formats that meet the requirements, the BMF names in particular XRechnung and ZUGFeRD from version 2.0.1, except the MINIMUM and BASIC WL profiles.
- XRechnung is a Core Invoice Usage Specification (CIUS) of the European standard EN 16931, maintained by the KoSIT. It exists in the UBL and CII syntaxes. It is binding for public contracting authorities in Germany, and a permitted format between businesses.
- ZUGFeRD is a hybrid format: a PDF/A-3 as the visual form with an embedded XML file in the CII syntax. From version 2.0 it is identical to the French Factur-X. Since 1 January 2025, the embedded XML is the invoice in Germany, and the PDF is only a view. The MINIMUM and BASIC WL profiles do not count as a full invoice.
Where a converter fits
E-invoices arrive in different forms: XRechnung as UBL or as CII, ZUGFeRD with an embedded CII file. A converter is useful when the invoice you have is not the one your software expects, for example an XRechnung in UBL when your accounting software reads CII.
Converting does not make an invoice compliant by itself. This converter does not check the XRechnung rules, and there is no validation yet: check the result before you use it.
What to do first
- Make sure you can receive. According to the BMF, an email inbox in which you can receive e-invoices is enough. Check how you open and read the files.
- Know your deadline. Find out whether your total turnover in the previous year was at most 800,000 euros.
- Check your software. Find out which formats it produces and reads (XRechnung, ZUGFeRD) and with which profiles.
- Test with real invoices. Send and receive a few, and compare the amounts and the parties with the originals. With ZUGFeRD, the XML is what counts.
- Keep the original. Keep the file as you received or sent it. For the retention obligation, ask your tax adviser.
Sources
Last updated: 20 October 2026