Germany's e-invoicing timeline from 2025 to 2028
German businesses have had to accept e-invoices since 1 January 2025. Sending them is phased in: any business may still send other invoices until the end of 2026, smaller ones until the end of 2027, and from 2028 e-invoices are the rule between German businesses.
Germany chose a gradual route. The receiving side came on day one, so that by the time senders must switch, every customer can accept what they send. This guide follows the Federal Ministry of Finance (bundesfinanzministerium.de), whose questions and answers on the e-invoice are the place to check the details for your own case.
The timeline at a glance
| Period | Receiving | Sending |
|---|---|---|
| 1 January 2025 to 31 December 2026 | Every business established in Germany must be able to receive e-invoices | Any business may still choose paper or, with the customer's agreement, another electronic invoice |
| During 2027 | Unchanged | Businesses whose previous-year turnover is below a threshold set in the law may still send other invoices; others send e-invoices |
| During 2027 | Unchanged | Existing EDI exchanges that do not meet the new requirements may continue |
| From 1 January 2028 | Unchanged | E-invoices are required for sales between businesses established in Germany |
In August 2026, the general transition has a few months left. A larger German business that sends paper or PDF invoices today needs to send e-invoices from January 2027.
Receiving: easier than it sounds
The ministry is clear that an email inbox is enough to receive e-invoices. Receiving did not require joining a network in January 2025. What a business does need is a way to read, check and store the structured file it receives, not just the human-readable view. A checklist for getting ready to receive e-invoices covers that side in general terms.
What counts as an e-invoice in Germany
An e-invoice is an invoice in a structured electronic format that a computer can process, and it must follow the European standard EN 16931. Two German formats are named as examples that qualify:
- XRechnung, a pure XML format that began in public-sector invoicing.
- ZUGFeRD, a hybrid of a readable PDF and embedded XML, in its recent versions and except its two most basic profiles.
Other formats, including EDI, can be used if both parties agree and the required data can be extracted in a form that meets the standard. Every detail the law requires on an invoice must be in the structured part; pointing to an unstructured attachment does not count.
A PDF on its own is not an e-invoice under these rules, even when it is sent by email. It counts as another electronic invoice, which is allowed during the transition and needs the customer's agreement. The difference is explained in why a PDF invoice is not an e-invoice, and the standard behind it in EN 16931 explained.
Who the rules leave out
- Sales to consumers. The obligation covers sales between businesses.
- Suppliers established abroad. The rules concern sales where both the supplier and the customer are established in Germany. A foreign business with a fixed establishment in Germany that is involved in the sale counts as established there.
- Small-amount invoices and travel tickets. These may always be issued on paper.
- The small-business scheme. Invoices from businesses under it may also always be issued on paper.
Does Germany require Peppol?
No. German law sets the format, not the delivery route. Email, a customer portal, a direct connection between systems and the Peppol network can all carry a German e-invoice. Many businesses that already trade with Belgium or the Nordic countries find Peppol convenient, but in Germany it is a choice, not an obligation.
What to do before January 2027
- Check where you stand. Work out whether your previous-year turnover puts you in the longer transition, and whether any of your customers exchange invoices with you over EDI today.
- Ask your customers. Many larger German businesses already receive e-invoices and will say which format and channel suit them best.
- Test the full round trip. Send a few e-invoices to a friendly customer before the deadline, and confirm their software reads every field, including your bank details and payment terms.
- Plan your archive. The structured file is the original invoice, so keep that file, not just a printout or the PDF view, for the retention period that applies to you.
- Mind the receiving side. Make sure incoming e-invoices are read from their structured data, not filed away unopened because the email looked like any other.
How Germany compares with its neighbors
France is starting its own reform in September 2026 with approved platforms at its center; France's e-invoicing reform covers the differences. EU-wide rules for cross-border invoices follow later; ViDA explained covers them.
Frequently asked questions
When do German businesses have to send e-invoices?
Generally from 1 January 2027. Businesses below the turnover threshold in the law, and existing EDI exchanges, have until the end of 2027. From 2028, e-invoices are required between businesses established in Germany.
Is ZUGFeRD an e-invoice in Germany?
Recent ZUGFeRD versions are, except their two most basic profiles, because the structured part follows EN 16931. The readable PDF inside it is a convenience; the embedded data is what counts.
Do I need an e-invoice to bill a German customer from abroad?
Generally not under the German rules, which concern sales where both businesses are established in Germany. Your customer may still prefer one, so ask which format they can process.
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