Mandatory B2B E-Invoicing in Germany: Timeline, Scope and Requirements

Timeline and Obligations

The implementation of Germany's e-invoicing regime follows a structured timeline. From 1 January 2025, all VAT-registered businesses in Germany must be capable of receiving structured e-invoices compliant with the European standard EN 16931. This marks the first immediate obligation under the mandate.

Sending obligations are introduced in phases:

• From 1 January 2027, businesses with an annual turnover exceeding €800,000 must issue structured e-invoices.
• From 1 January 2028, the obligation extends to all remaining B2B taxpayers in Germany, regardless of turnover.

The mandate applies exclusively to domestic B2B transactions between entities established in Germany. B2C transactions and cross-border supplies are excluded from the initial scope.

Formats, Transitional Rules, and Future Developments

The accepted e-invoice formats must comply with EN 16931, the European standard for electronic invoicing. In Germany, the primary compliant formats are XRechnung (the German CIUS of EN 16931) and ZUGFeRD version 2.x, a hybrid PDF/XML format. Simple PDF invoices will no longer qualify as electronic invoices under the new definition after the transition period.

A transitional rule allows businesses to continue issuing paper or non-structured electronic invoices (e.g., PDF) until the end of 2026 for all businesses, and until the end of 2027 for businesses with turnover below €800,000, provided the recipient consents. EDI-based invoicing is also permitted if the data can be extracted in an EN 16931-compliant manner.

Germany has obtained a derogation from the EU VAT Directive (Articles 218 and 232) to allow mandatory e-invoicing without recipient consent. Additionally, the government has signaled its intent to introduce a transaction-based digital reporting system after 2028, aligned with the EU ViDA initiative.