E-Invoicing in Germany 2026 – Mandatory B2B Requirements, Timeline and Formats

E-invoicing has been a mandatory component of Business-to-Government (B2G) transactions in Germany since November 2020. The next major phase — mandatory B2B e-invoicing — is now actively rolling out, with the receiving obligation already in force since January 2025 and issuing obligations beginning in 2027. Here is what businesses need to know.

The Legal Framework

The B2B e-invoicing mandate was introduced through the Growth Opportunities Act (Wachstumschancengesetz), passed by the German Federal Council in March 2024. The Federal Ministry of Finance (BMF) published detailed implementation guidance in October 2024, supplemented by an updated letter in October 2025. The mandate applies to domestic B2B transactions between businesses established in Germany — it does not cover B2C transactions or cross-border sales.

The Three-Phase Rollout

Phase 1 — 1 January 2025: Receiving Obligation (Already in Force)

Since 1 January 2025, all businesses operating in Germany must be technically capable of receiving and processing structured electronic invoices compliant with the EN 16931 standard. This obligation applies to every domestic B2B company regardless of size or turnover. Crucially, the sender no longer requires the buyer’s explicit consent to send a structured e-invoice — businesses cannot refuse to accept compliant e-invoices.

During the transition period from 1 January 2025 to 31 December 2026, businesses may still issue paper invoices or other electronic formats such as PDFs, provided the recipient agrees. This gives businesses time to update their ERP systems, invoice templates, validation processes, and archiving procedures.

Phase 2 — 1 January 2027: Issuing Obligation for Larger Companies

From 1 January 2027, businesses with annual turnover exceeding €800,000 in the previous year must issue structured electronic invoices for all in-scope domestic B2B transactions. Paper and PDF invoices will no longer be accepted for these companies — full transition to digital invoicing solutions is required.

Businesses at or below the €800,000 threshold can continue using the extended transition relief through the end of 2027 — but they must still be able to receive e-invoices, as that obligation has applied since 2025.

Phase 3 — 1 January 2028: Full Mandatory B2B E-Invoicing

From 1 January 2028, the obligation to issue structured e-invoices extends to all remaining businesses in Germany, regardless of size or turnover. This date marks the completion of Germany’s B2B e-invoicing rollout — paper invoices and unstructured PDFs will no longer be valid for domestic B2B transactions for any company.

What Is an E-Invoice?

A true e-invoice is not simply a PDF or image of an invoice sent by email. It is a structured electronic document created in a specific machine-readable data format compliant with the EN 16931 European standard. Key characteristics:

• Created in a structured data format (XML or equivalent)
• Capable of being automatically processed by financial and accounting systems without manual data entry
• Contains all required invoice data in a standardised structure

The BMF has confirmed that simple PDF files — even if sent electronically — are classified as “other invoices”, not e-invoices, unless they contain embedded structured XML data (as in the ZUGFeRD hybrid format).

Accepted E-Invoice Formats

Germany accepts multiple formats, all compliant with EN 16931:

XRechnung — Germany’s national XML standard, the primary format used for B2G invoicing since 2020 and the most widely deployed format for B2B.

ZUGFeRD (version 2.1 and above) — a hybrid format combining a human-readable PDF with an embedded XML data layer. The visual PDF appearance remains convenient for users while the XML enables automated processing. Note: only profiles from COMFORT level upward are EN 16931-compliant.

Peppol BIS 3.0 — UBL-based format transmitted via the Peppol network, increasingly used for B2B invoicing.

EN 16931-compliant EDI — EDI may still be used during the transition period with the recipient’s consent. From 2028, EDI formats must fully comply with EN 16931 requirements.

There is no central government portal for B2B e-invoice exchange — transmission can occur via email, Peppol network, API integration, shared corporate storage, or portal download. The choice of transmission method is a commercial matter agreed between the parties.

Key Exemptions

• B2C transactions — entirely outside the scope of the B2B mandate
• Small-value invoices up to €250 — exempt from the structured e-invoicing requirement
• Cross-border transactions — the mandate covers domestic B2B transactions only; cross-border invoicing is not affected at this stage

Archiving Requirements

E-invoices must be archived in their original electronic format for at least 8 years in accordance with German bookkeeping rules (GoBD). Printing an e-invoice to PDF or paper and discarding the original structured file does not meet the archiving requirement.

What This Means for Your Business

If you have a German VAT number and conduct domestic B2B transactions, you are already subject to the receiving obligation — your systems must be capable of accepting XRechnung, ZUGFeRD, or other EN 16931-compliant formats today.

If your turnover exceeds €800,000, prepare now for the January 2027 issuing mandate — the transition window is closing, and updating ERP systems, invoice templates, and supplier workflows takes time.

If your turnover is below €800,000, you have until January 2028 to fully transition your issuing processes — but the receiving obligation already applies.

If you use EDI, ensure your EDI connections will be EN 16931-compliant by January 2028 or plan to migrate to an accepted format.

For any questions about e-invoicing compliance in Germany or other EU countries, our team of experts is ready to help: Contact us — amavat®