Germany’s B2B e-invoicing: receiving since 2025, issuing by 2028

What has already changed

Since 1 January 2025, businesses in Germany have been required to be able to receive electronic invoices for domestic transactions between businesses. In German VAT law an electronic invoice now means a structured invoice in a format that follows the European standard for electronic invoicing, EN 16931, and can be processed automatically. A PDF sent by email is no longer an electronic invoice in that sense; it is classed as an other invoice.

In practice, receiving can be as simple as providing an email inbox that accepts the files, but that meets the letter of the rule without delivering any of the value. A structured invoice that arrives in an inbox and is then printed, checked and typed into accounting software by hand has become more work, not less. The businesses that benefit are the ones that route incoming structured invoices directly into their accounting or purchasing systems.

Common formats include XRechnung, which is widely used for invoices to public bodies, and ZUGFeRD from version 2.0.1 onwards in profiles that meet the European standard, which combines a readable PDF with embedded structured data. Other formats can be used where they allow the necessary data to be extracted in line with the standard, and electronic data interchange arrangements between trading partners are addressed by transitional rules.

The transition for issuing invoices

The obligation to issue electronic invoices is phased. Until the end of 2026, businesses may still issue paper invoices and other electronic formats such as PDF, subject to the recipient accepting them where required. During 2027, businesses whose turnover in the previous year did not exceed a set threshold may continue to issue other formats, while larger businesses must issue structured electronic invoices. From 1 January 2028, the obligation to issue structured electronic invoices applies generally to domestic B2B transactions.

There are exceptions. Invoices to private consumers are not covered, small-amount invoices below a set value are exempt, and certain tickets are excluded. Businesses should check the current administrative guidance and their own situation with a tax adviser rather than assume a transaction is in or out of scope.

Since 2025

All businesses must be able to receive structured electronic invoices for domestic B2B transactions.

Until end of 2026

Paper and other formats such as PDF may still be issued under transitional rules.

2027

Smaller businesses below the turnover threshold may still issue other formats; larger businesses issue structured invoices.

From 2028

Structured electronic invoices become the general rule for issuing domestic B2B invoices.

Why the format is the easy part

Software vendors have largely solved the format question. Most accounting and invoicing tools used in Germany can already create and read the common formats, or will do so soon. If e-invoicing were only about producing a correct file, it would be a configuration exercise.

The harder problems sit around the invoice. A structured invoice exposes the quality of the data that produces it: customer master data with incomplete addresses or missing VAT numbers, product descriptions that differ between the shop and the ERP, purchase order numbers that customers require but sales teams never record, and tax treatments decided manually case by case. None of these problems are new. The mandate simply makes them visible and machine-checked.

On the receiving side, the problem is matching. An incoming invoice is only useful if it can be matched to an order and a delivery automatically. Businesses without purchase orders, or whose suppliers never quote them, find that structured data arrives but still needs a person to decide what it is for.

What the systems work actually involves

For most businesses the work falls into four parts. The first is an inventory of every place invoices are created or received: the ERP, the online shop, a subscription tool, a field service app, the spreadsheet a branch office still uses. Mandates tend to be discovered one exception at a time unless someone lists these first.

The second is master data cleanup. Customer and supplier records need the data fields the standard requires, and the process that creates new records needs to enforce them so the problem does not return.

The third is integration. Incoming invoices should flow into approval and booking without re-keying, and outgoing invoices should be generated from the system that knows what was ordered and delivered, not typed into a separate invoicing tool.

The fourth is exception handling. Rejected or unreadable invoices, disputes and credit notes need an owner and a queue. This is the part most often forgotten, and it is where problems accumulate quietly.

Archiving and proper records

Electronic invoices must be stored in their original structured form and retained for the statutory period, in line with German principles for proper electronic records. A printed or converted copy does not replace the original file. This matters for businesses that currently print invoices for approval or store only PDFs in a document management system.

Archiving should therefore be designed together with receiving and issuing, not added afterwards. The question to ask any provider is simple: where is the original structured file kept, for how long, and how would we retrieve it for a tax audit?

A realistic order of work

Businesses that have only met the receiving obligation formally should start by routing incoming structured invoices into their accounting workflow, because this delivers immediate value and exposes supplier data problems early.

The next step is to prepare issuing well before the deadline that applies. Test invoices with major customers, especially public sector customers and large companies that already require structured formats, reveal data gaps while there is still time to fix them calmly.

Finally, use the mandate to remove re-keying elsewhere. If the invoice is generated from order and delivery data, the same integration usually removes manual steps in quoting, order entry and payment reconciliation. That is where the real saving lies, and it is why e-invoicing is better treated as a process project than a compliance checkbox.

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