Change note

Germany’s B2B e-invoicing: receipt now, issuing in phases.

Structured invoices are already part of German B2B operations. Issuing transitions depend on turnover and the type of transaction, while specific exceptions remain.

What's changing, in one breath

Germany now distinguishes structured e-invoices from paper invoices and ordinary PDFs. Domestic businesses must be able to receive e-invoices. Issuing requirements phase in after transitional periods, with exceptions including qualifying small-business supplies. Read the BMF guidance.

Why? The same reason as everywhere else: closing the VAT gap, and preparing the ground for the EU's wider digital-reporting plans. One thing Germany has not done, so far, is copy France's model of approved platforms that report your invoice data to the tax authority. For now, a compliant e-invoice can travel by something as ordinary as email. A reporting layer is planned to follow later, in step with the EU's ViDA package.

Key dates

In force

Domestic businesses need to be able to receive structured e-invoices. An email inbox can satisfy the receipt requirement.

Next phase

The general issuing transition ends. Issuers with previous-year turnover up to €800,000 and certain EDI arrangements have an additional year.

Following phase

The remaining general issuing transitions end. Statutory exceptions continue to apply.

These are selected milestones. Confirm the detailed scope, exceptions and transitional rules with the linked authority before making a business decision.

Official guidance: German Federal Ministry of Finance

The facts, briefly

  • Since 1 January 2025: every business established in Germany must be able to receive e-invoices for domestic B2B transactions. There is no turnover threshold on the receipt obligation and no opt-out. (bundesfinanzministerium.de)
  • Through 2026: all issuers can use the general transition. Issuers with previous-year turnover up to €800,000 have until the end of 2027. Other non-paper electronic formats require recipient consent.
  • From 1 January 2028: the remaining general issuing transitions end, including the EDI transition. Statutory exceptions continue.
  • Formats: the invoice must follow the European standard EN 16931. In practice Germany accepts XRechnung (pure structured XML) and ZUGFeRD from version 2.0.1 (a hybrid: a readable PDF with the structured data embedded), among other conforming formats.
  • Exceptions include: B2C transactions, certain VAT-exempt supplies, small invoices up to €250, qualifying travel tickets and supplies under the Kleinunternehmer regime. Check the BMF FAQ for the complete scope. (bundesfinanzministerium.de)

Does this actually hit you?

Check domestic establishment, transaction type and the applicable exception. The Kleinunternehmer exception concerns issuing, not the ability to receive.

  • Your group has a German entity. Then the mandate is not a 2027 problem, it is a 2025 one: your German company is already required to be able to receive structured e-invoices from its German suppliers, even if it never issues one. Whether the issuing duty hits it in 2027 or 2028 depends on its own turnover, not the group's.
  • You sell into Germany from abroad, with no establishment there. The issuing obligation generally does not reach you today. But your German customers are re-plumbing how they take invoices in, some will start asking every supplier for structured formats, and whether you have a German fixed establishment is suddenly a question with invoicing consequences. Worth confirming your position rather than assuming it.
  • You feel safe because 2028 sounds far away. Except the receipt duty is already live, the 2027 threshold catches more companies than expect it (800,000 euros of turnover is not a large business), and the comfortable habit of emailing PDFs only survives while every recipient keeps consenting to it.

Where Kehai comes in

Kehai monitors configured official German sources and drafts an entity-specific assessment. Your team confirms the position and records an action, owner and target date. Kehai does not format or send invoices.

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