E-invoicing obligation in Germany: when does it apply and to whom?

E-invoicing obligation: what applies from when

The e-invoicing obligation goes back to the Growth Opportunities Act (Wachstumschancengesetz) and concerns invoices between businesses based in Germany. Since January 1, 2025, the obligation to receive has applied: every domestic business must be able to accept and process e-invoices. According to the tax authorities, an email inbox through which the invoice files arrive is already sufficient for that. However, the invoices must then be processed and archived correctly.

Transition rules apply to issuing. In 2025 and 2026, businesses may still send paper invoices as well as – with the recipient's consent – other electronic formats such as PDF. In 2027, this relief applies only to businesses whose total revenue in the previous year did not exceed €800,000. From January 1, 2028, domestic B2B invoices must in principle be issued as e-invoices.

• Since January 1, 2025: obligation to receive for all domestic businesses
• 2025 and 2026: paper and PDF (with consent) still permitted
• 2027: transition rule only for prior-year revenue up to €800,000
• From January 1, 2028: obligation to issue in domestic B2B applies to everyone in principle
• EDI procedures with consent as a transition measure until the end of 2027

What is an e-invoice – and what is not?

An e-invoice is an invoice in a structured electronic format that allows automatic processing and complies with the European standard EN 16931. Common in Germany are XRechnung, a pure XML format, and ZUGFeRD, which combines an XML file with a readable PDF view. What matters is the structured data, not the image of the invoice.

A simple PDF – for example created with a word processor or scanned – is not an e-invoice within the meaning of the law but a so-called “other invoice” (sonstige Rechnung). In B2B it is permitted only within the transition rules. Important for archiving: e-invoices must be retained unchangeably in their original format, that is, with the structured data.

E-invoicing obligation for small businesses and private customers

Small businesses (Kleinunternehmer) have also had to be able to receive e-invoices since 2025. Under the current rules, however, they are exempt from the obligation to issue e-invoices themselves; they may continue to issue other invoices and can use e-invoices voluntarily. Also exempt are small-amount invoices up to €250 and transport tickets. In these cases, paper and PDF invoices remain possible even after the transition periods end.

The e-invoicing obligation does not apply to invoices to private customers. Anyone who sells exclusively to consumers can continue to issue invoices as before. However, as soon as businesses are also among your customers, the transition periods and the future obligation to issue apply to those invoices – for example for skilled-trade businesses that have both private and commercial customers. Here you should set up your invoicing program so that both routes work.

E-invoicing obligation for associations and landlords

For clubs and associations (Vereine), it depends on whether they act as a business for VAT purposes, for example through an economic business operation or paid services to other businesses. In that case the same rules apply to that area as for other businesses – including the obligation to receive. An association that operates exclusively in its non-commercial sphere (ideeller Bereich) is generally not affected.

Landlords, too, are usually businesses for VAT purposes and therefore must be able to receive e-invoices, for example from skilled-trade businesses or property managers. Whether and from when they have to issue e-invoices themselves depends, among other things, on whether the rental is VAT-exempt or the landlord has opted to charge VAT; there are exceptions for certain VAT-exempt transactions. Clarify your case with your tax advisor.

Implementing e-invoicing: the practical steps

Start with receiving: decide which address e-invoices are sent to, and check whether your accounting can read and process XRechnung and ZUGFeRD. Many accounting and invoicing programs already offer functions for this. Clarify with your tax firm how the invoices are handed over and archived in an audit-proof way. Inform your suppliers of the desired receiving address.

The second step is issuing: can your existing program, shop or inventory management system generate structured invoices? If not, there are two routes – switch to a standard solution or build an interface that generates e-invoices directly from your data. Use the remaining transition period to test the process calmly.

• Define a receiving address for e-invoices
• Check that XRechnung and ZUGFeRD can be read
• Ensure archiving in the original format
• Check issuing from shop, ERP or software
• Coordinate the process with your tax firm
• Exchange test invoices with business partners

How Nano Concepts supports you with e-invoicing

If your invoices originate in your own software, an online store or an inventory management system, we develop interfaces that generate e-invoices in the common formats and automate the processing of incoming invoices – through to handover to DATEV (the accounting platform widely used by German tax firms) or your accounting software. That way e-invoicing does not become extra work but an opportunity to simplify processes.

For orientation: manageable integrations can fall within the Starter package from €2,500, more extensive automations within the Professional package from €8,000. The exact quote follows after the free initial consultation. Note: This guide summarizes the principles as of October 2026 and does not replace tax or legal advice; the law and current administrative guidance are authoritative. For questions about classifying your case, please contact your tax firm.