E-Invoice Requirement: What Applies and When

As of January 1, 2025, Germany’s e-invoice requirement applies to transactions between domestic companies (B2B): as of then, every affected company must generally be able to receive e-invoices, while the requirement to issue them takes effect in phases over transition periods. An e-invoice is not a PDF, but a structured electronic format according to the EN 16931 standard – in Germany primarily XRechnung and ZUGFeRD.

What Counts as an E-Invoice

Format is decisive. An e-invoice contains invoice data in machine-readable form in a structured dataset:

• XRechnung: a pure XML format, the standard especially for public contracting authorities
• ZUGFeRD: a hybrid format – a PDF for reading plus embedded XML for machines

As of the new regulation, an ordinary PDF or paper invoice only counts as a “miscellaneous invoice.” They may continue to be used during transition periods, but do not fulfill the e-invoice requirement.

The Rollout Schedule in Phases

This is how the introduction is structured according to current law (as of mid-2026):

1. Since January 1, 2025: All domestic companies must be able to receive e-invoices in B2B transactions. An email inbox is initially sufficient for this.
2. Transition period through end of 2026: Paper and PDF invoices may continue to be issued with the recipient’s consent.
3. Extended period through end of 2027: for invoice issuers with prior-year revenue of no more than 800,000 euros.
4. From 2028 onward: Issuing as an e-invoice becomes the standard rule in B2B, with legally defined exceptions.

For details and special cases, it’s worth consulting the current BMF notices or discussing with your tax advisor – the implementation has been clarified multiple times since 2024.

Who the Requirement Affects – and Who It Doesn’t

Transactions between companies with headquarters in Germany are affected. Those not subject to the issuance requirement include, among others, invoices to end consumers (B2C), small invoices up to 250 euros, and travel tickets. Micro-businesses also have relief provisions for issuing – but they must still be able to receive e-invoices. Read more on this in the article E-Invoice for Micro-Businesses.

What You Should Do Now

• Ensure receipt: Set up a dedicated inbox for incoming invoices and communicate it to your suppliers.
• Organize filing: E-invoices must be retained in their structured original form – a printout is not sufficient. You therefore need organized digital storage.
• Simplify the process: The fewer manual steps between receipt and archival, the less can go wrong.

webRichtung documents is a starting point for this in the shared operating system: incoming invoices can be imported via email, filed, evaluated, and retrieved through archive search. DATEV support and processing of XRechnung and Factur-X keep the further document flow integrated.

Common Misunderstandings

Three misconceptions about the e-invoice requirement come up particularly often:

• “I’m already sending PDFs.” A PDF is not an e-invoice within the meaning of the law – it lacks the structured dataset.
• “This only affects large companies.” The receipt requirement applies regardless of company size; only for issuance are there relief provisions and transition periods.
• “I print out the e-invoice and file it.” The printout is just an image – the electronic original must be retained.

Those who set up receipt, filing, and archival cleanly from the start will carry this requirement in a reliable workflow – and benefit at the same time from findable, evaluable documents.

This article provides general information and does not replace legal or tax advice.