E-invoicing in Germany 2025–2028 for small businesses

Does this apply to your business?

Germany’s e-invoicing mandate covers domestic B2B transactions: invoices between businesses for supplies within Germany. It does not cover invoices to private consumers. The rules sit in Section 14 of the German VAT Act (UStG), as amended by the Growth Opportunities Act (Wachstumschancengesetz).

If you run a German entity, such as a GmbH set up by a foreign parent, it is treated like any other German company. The same applies if you are a foreign founder running a sole proprietorship or freelance business registered in Germany.

If you sell into Germany from abroad without a German establishment, the answer depends on your set-up and on how your supplies are taxed. This guide does not settle that question. Ask a German tax adviser (Steuerberater) to confirm whether the domestic mandate reaches your invoices.

• A US-owned GmbH in Munich invoicing German retailers: covered.
• A freelance developer from Spain registered in Berlin and invoicing German agencies: covered, unless the Kleinunternehmer scheme applies (see below).
• A German online shop selling only to consumers: not covered for those sales, but must still be able to receive e-invoices from its own suppliers.
• A company abroad invoicing German customers without a German establishment: check with a German tax adviser.

Key German terms, briefly explained

German invoicing rules come with their own vocabulary. You will hear these words from your accountant, your customers and your software vendor, so it helps to know them.

• E-Rechnung (e-invoice): an invoice in a structured electronic format that software can read automatically. A plain PDF is not an e-invoice.
• Sonstige Rechnung (other invoice): any invoice that is not an e-invoice, such as paper or a plain PDF. It is allowed only in transition periods and specific exceptions.
• Kleinunternehmer: a small business using the small-business VAT scheme under Section 19 UStG, which means it does not charge German VAT on its invoices.
• XRechnung: a German e-invoice format that is pure XML, with no visual layer. It was historically required for invoices to public authorities in many federal states.
• ZUGFeRD: a hybrid format. It looks like a normal PDF but carries the structured invoice data as an embedded XML file.
• EN 16931: the European standard for e-invoice content. German e-invoices must follow it, and both XRechnung and ZUGFeRD are built on it.
• Steuerberater: a licensed German tax adviser. Many small businesses in Germany work with one for VAT and bookkeeping.

The timeline from 2025 to 2028

The Federal Ministry of Finance (BMF) explained the rules in an official letter dated 15 October 2024. The timeline separates receiving from issuing. Receiving is already mandatory. Issuing is phased in by turnover, with the previous year’s turnover deciding which phase applies to you.

Receiving: already mandatory for everyone

Since 1 January 2025, every business in Germany must be able to receive e-invoices. There is no size exemption, and Kleinunternehmer are included. The BMF letter and German chambers of commerce (IHK) are consistent on this point.

The BMF letter confirms e-mail, electronic interfaces and download portals as valid ways to transmit e-invoices. An ordinary e-mail inbox is therefore enough as a channel. You do not need to join a specific network.

The harder part is reading and filing what arrives. An XRechnung file is raw XML. Opened without the right software, it looks like code. Your accounting tool needs to display it, and the original file needs to be stored properly for your bookkeeping. For a foreign-owned company, this is often where group systems fall short: the head-office ERP may handle PDFs well but not German XML formats.

Issuing: which year applies to you

The issuing deadline depends on turnover in the previous calendar year. Three examples show how this works in practice.

A German GmbH owned by a Dutch group turns over EUR 1.2 million in 2026. It must issue e-invoices to its German business customers from 1 January 2027. Until then, it may send PDF invoices to customers who agree.

A Berlin design studio with two partners turns over EUR 400,000 in 2026. It may keep sending PDF invoices with customer consent during 2027, and must issue e-invoices from 1 January 2028.

A freelance translator using the Kleinunternehmer scheme may, under Section 34a UStDV, always issue invoices as other invoices. The ordinance gives no end date for this. The translator may still choose to send e-invoices if a large client asks for them, and must be able to receive e-invoices in any case.

If you expect to leave the Kleinunternehmer scheme because your business is growing, the general rules apply to you from that point on. Plan the switch with your Steuerberater.

What is outside the mandate, and what is at stake

The BMF letter of 15 October 2024 names several categories that do not need to be issued as e-invoices. The obligation to receive e-invoices still applies to every business.

• Small-amount invoices up to EUR 250 gross (Section 33 UStDV).
• Travel tickets (Section 34 UStDV).
• Invoices for certain VAT-exempt supplies under Section 4 No. 8 to 29 UStG, such as financial services, healthcare and insurance.
• Invoices to private consumers (B2C), which are outside the mandate altogether.

If your invoicing systems sit outside Germany

Many foreign-owned companies issue German invoices from a group ERP or a billing tool chosen at head office. Before your deadline, check that this system can produce an e-invoice that follows EN 16931, typically as XRechnung or ZUGFeRD. A nicely designed PDF from a global template will not be enough.

Also check the receiving side. German suppliers will send XML or ZUGFeRD files to whatever address you give them. Make sure those files reach a system that can read and archive them, rather than a shared inbox abroad where nobody opens XML attachments.

Which of the two formats suits you is a separate question. We compare XRechnung and ZUGFeRD in detail, including which ZUGFeRD profiles count as e-invoices, in our dedicated guide on the two formats. Synelo builds integrations of this kind as projects, for example connecting a group ERP to a German e-invoice export and an inbox to accounting.

What to do now

Step 1: Set up receiving. Create a dedicated address for incoming invoices, give it to your German suppliers, and confirm that your accounting software can display XRechnung and ZUGFeRD files.

Step 2: Work out your phase. Confirm whether your German business uses the Kleinunternehmer scheme, and estimate whether 2026 turnover will exceed EUR 800,000. Note the resulting date: 2027, 2028, or no issuing obligation for now.

Step 3: Map your invoices. List which invoices go to German businesses, which go to consumers, and which fall under the exceptions above. Only the first group needs to move to e-invoices.

Step 4: Check your software. Ask your ERP or billing vendor whether it can issue EN 16931 e-invoices for Germany, and when. If it cannot, plan a replacement or an add-on well before your deadline.

Step 5: Agree on archiving and consent. Keep received e-invoices in their original format, not as printouts. Ask your Steuerberater which retention rules apply to your records, and document which customers have agreed to PDF invoices during the transition period.

Step 6: Brief your team and head office. Explain the dates and the difference between a PDF and an e-invoice to whoever issues or approves invoices.

This guide is general information as of October 2026, not legal or tax advice — check your situation with your Steuerberater or the German tax authority.