Skip to content
Saldek
Try free

Glossary

E-invoicing mandate in Germany

In short

In Germany, businesses must gradually use structured e-invoices for supplies to other domestic businesses: they have had to be able to receive them since 1 January 2025 and must issue them from 2027 if prior-year turnover exceeded EUR 800,000, and from 2028 as a rule for everyone. The legal basis is § 14 and § 27(38) of the German VAT Act (UStG).

· General information, not tax advice.

Under § 14(1) UStG, an e-invoice is an invoice in a structured electronic format that allows electronic processing and complies with the European standard EN 16931. A format agreed between the parties is also allowed if the mandatory details can be extracted correctly and completely into an EN 16931 format. A PDF is not an e-invoice but an “other invoice”.

Since 1 January 2025, all domestic businesses must be able to receive e-invoices; the recipient's consent is not required. Transition periods apply to issuing: for supplies made up to the end of 2026, invoices may still be sent on paper by 31 December 2026 or, with the recipient's consent, in another electronic format such as PDF.

In 2027 this relief applies only to businesses whose total turnover in the previous year did not exceed EUR 800,000; EDI procedures have their own transition rule until the end of 2027. From 1 January 2028, all domestic businesses must issue their B2B invoices as e-invoices.

Exceptions include small-amount invoices up to EUR 250, travel tickets, invoices from small businesses (Kleinunternehmer) and supplies exempt under § 4 Nos. 8 to 29 UStG. Accepted formats are XRechnung and ZUGFeRD from version 2.0.1 excluding the MINIMUM and BASIC-WL profiles, as well as other EN 16931 formats; the parties agree which one they use (Federal Ministry of Finance letter of 15 October 2025).

For Austrian businesses the obligation generally does not apply: it only covers cases where both supplier and customer are established in Germany, i.e. have their seat, management, a permanent establishment involved in the supply or their residence there. Otherwise the invoice may be issued on paper or, with the customer's consent, electronically. German customers may still require e-invoices by contract, and from 1 July 2030 ViDA makes structured e-invoices mandatory for intra-EU B2B supplies anyway.

For an e-invoice you only need to keep the structured part; the PDF part of a hybrid invoice only if it contains additional tax-relevant information (GoBD, amendment of 14 July 2025). Small businesses may always send their own invoices on paper or as a PDF (§ 34a UStDV).

In Saldek

Saldek can also create outgoing invoices as XRechnung.

Questions about this term

Do I have to send e-invoices to German customers as an Austrian business?

Not under German VAT law, as long as you have neither a seat, management nor a permanent establishment involved in the supply in Germany. Your customer may still want to agree on e-invoices by contract; XRechnung or ZUGFeRD are then the obvious choice.

Which turnover threshold applies in 2027?

It depends on the previous year's total turnover: businesses with more than EUR 800,000 in 2026 must issue e-invoices for supplies from 1 January 2027. All others may still use paper or, with consent, formats such as PDF until the end of 2027.

Is a PDF by e-mail still enough?

Until the end of 2026 with the recipient's consent, yes; with prior-year turnover of up to EUR 800,000 until the end of 2027. A plain PDF is not an e-invoice; a ZUGFeRD PDF with embedded data from version 2.0.1 is, except in the MINIMUM and BASIC-WL profiles.

What applies to small businesses (Kleinunternehmer) in Germany?

They must be able to receive e-invoices but may keep issuing their own invoices as other invoices — on paper or, with the recipient's consent, as a PDF, for example.

Sources