Change note

Germany has already started rewriting how B2B invoices work. Here's what that means for you.

If your group has a German company, or you invoice German business customers, the rules on what counts as an invoice are changing in phases, and the first phase is already in force. This is the no-jargon version: what has changed, what changes next, and how to work out whether it touches you without reading a ministry letter.

What's changing, in one breath

Since January 2025, every business established in Germany must be able to receive structured electronic invoices for domestic business-to-business sales. A paper invoice or an ordinary PDF no longer counts as an e-invoice; the invoice has to arrive as structured, machine-readable data under the European standard. Issuing is next: from 2027 larger German businesses must send their domestic B2B invoices this way, and from 2028 everyone must. (bundesfinanzministerium.de)

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.

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)
  • From 1 January 2027: businesses whose previous-year turnover exceeded 800,000 euros must issue e-invoices for domestic B2B sales. Until the end of 2026, paper (and, with the recipient's consent, PDF and other formats) remains allowed for everyone.
  • From 1 January 2028: the issuing obligation covers all domestic B2B businesses, whatever their size. Established EDI arrangements must be compliant by then too.
  • 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.
  • What stays out: B2C invoices, invoices of 250 euros or less, and certain exempt supplies. The mandate covers transactions between businesses established in Germany, which is exactly why group structures need a careful look (see below).

Accurate as of July 2026, based on the Finance Ministry's guidance letters of October 2024 and October 2025. German guidance is still being refined, so always confirm the current state and your own obligations against the official source before acting.

Does this actually hit you?

Quite possibly, and earlier than most teams assume. A few examples:

  • 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 isn't an invoicing platform. It won't format or send a single invoice. What it does is make sure this mandate (and France's, and the next one in whatever country you sell to) never ambushes you: it watches the official German sources, flags the milestones that apply to your setup, and turns each one into a plain action with an owner and a deadline, so “Germany is changing invoicing” becomes “confirm our German entity can receive XRechnung by this date, assigned to this person, source attached”.

No 60-page PDFs. No newsletter you mean to read and never do. Just the official source, the date, and what to do next.

See it on your business

Not another newsletter you mean to read and never do. Tell me where your business sells, and I'll show you the rule changes that actually touch you, scoped to your jurisdictions, entities and invoice flows.

Talk it through with the operator who built it

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