E-invoicing requirement 2025/2026 – what business owners need to know now

Mandatory e-invoicing (E-Rechnung) is no longer a distant prospect: since January 1, 2025, every company in Germany must be able to receive e-invoices in B2B. For issuing them, staggered transition periods apply through 2027 and 2028. What this means for you in concrete terms, which formats count, why a PDF is not an e-invoice, and how to prepare properly is all explained here – compact and without the legalese.

What mandatory e-invoicing actually is

With the Growth Opportunities Act (Wachstumschancengesetz), lawmakers introduced mandatory e-invoicing (E-Rechnung) for domestic B2B transactions. This affects transactions between two companies based in Germany. Invoices to private individuals (B2C) are exempt, as are many cross-border cases.

An e-invoice (E-Rechnung) as defined by the law is an invoice that is issued, transmitted, and received in a structured electronic format and that enables automated, electronic processing. The relevant standard is the European norm EN 16931. This is exactly where the classic invoice formats fall short – more on that in a moment.

Important to know from the outset: receiving and issuing are two separate matters with different deadlines. The obligation to receive already applies to everyone since the start of 2025. The obligation to issue, by contrast, is being phased in step by step.

Since 2025: you must be able to receive e-invoices

The most important sentence first: since January 1, 2025, every company must be able to receive and process e-invoices (E-Rechnung). This applies with no transition period and regardless of your company's size – including small businesses under the small-business rule (Kleinunternehmerregelung) per § 19 UStG.

In practice this means: if a business partner sends you an XRechnung today, you must be able to accept and process it correctly. A simple email inbox is technically sufficient as a receiving channel – but you additionally need a way to make the structured file readable, book it correctly, and archive it in a GoBD-compliant manner.

By the way, you cannot refuse to receive an e-invoice. Anyone unable to accept one risks trouble with input VAT deduction (Vorsteuerabzug) and, in case of doubt, disputes with the supplier. That is why, for most businesses, this is precisely the most urgent item to address.

The transition periods for issuing: 2027 and 2028

When it comes to sending your own invoices, you have more time. Until the end of 2026, you may still send paper invoices or other electronic formats such as a simple PDF – but only if the recipient agrees. After that it gets serious, staggered by revenue:

Period	What applies to you
until 31.12.2026	Everyone may still issue paper or PDF (with the recipient's consent)
from 01.01.2027	E-invoicing (E-Rechnung) mandatory for companies with more than 800,000 euros in prior-year revenue
from 01.01.2028	Mandatory e-invoicing (E-Rechnung) for all domestic B2B transactions – with no exception based on revenue level

The 800,000 euro threshold refers to total revenue in the prior year. If you were below it in 2026, you may still use the old formats in 2027. From 2028, e-invoicing (E-Rechnung) is then mandatory for every domestic B2B transaction – no matter how small your business is.

Tip: Don't rely on the final deadline. As soon as an important customer requires e-invoices from you, you'll need them – regardless of what the calendar says. Large clients and the public sector often already assume it.

XRechnung, ZUGFeRD – and why a PDF is not an e-invoice

This is where most of the misunderstandings arise. A PDF file that you send by email is not an e-invoice (E-Rechnung) as defined by the law. For the tax office (Finanzamt), it counts as an "other invoice" – even if it is perfectly designed. The reason: a PDF is an image for humans, but it cannot be read by machines.

The formats that qualify as genuine e-invoices are those that meet the EN 16931 standard. The two common ones in Germany are:

• XRechnung – a pure XML format, fully structured and machine-readable. The standard for dealings with public authorities, and equally permitted for B2B.
• ZUGFeRD (from version 2.0.1) – a hybrid format: a visible PDF with an embedded XML file. So you see a familiar-looking invoice, while the structured data sits in the background.

ZUGFeRD is the more convenient entry point for many, because the PDF remains readable for humans. Legally, however, it is the structured XML part that governs hybrid formats. If the PDF and the XML differ, the data content of the XML file applies.

Archiving in a GoBD-compliant way: only the XML counts

You must retain an e-invoice in such a way that it remains unalterable, readable at all times, and machine-analyzable. The Federal Ministry of Finance (Bundesfinanzministerium) clarified the GoBD in 2025 in this regard – and that makes things easier in practice at one crucial point.

For an e-invoice, it is sufficient to archive the structured part (the XML file) in its original form. Converting the XML into an image or a printout and discarding the original is not permitted – the original must be preserved. With hybrid formats such as ZUGFeRD, you only need to additionally retain the visible PDF part if it contains tax-relevant additional information that is missing from the XML (such as booking notes).

The retention period for invoices has also been shortened to eight years (§ 14b UStG). Anyone who already files their receipts digitally and in a GoBD-compliant manner has the least to adjust here. You can read more about this in the article Storing receipts digitally – GoBD in practice.

How to prepare step by step

You don't have to overhaul everything at once. This sequence has proven effective:

1. Ensure receiving works (immediately): Set up a central invoice inbox and create a way to make XRechnung and ZUGFeRD readable and to book them.
2. Check master data: Enter your routing information (Leitweg), tax number, and payment details cleanly so that outgoing e-invoices are error-free.
3. Check your software: Can your bookkeeping or invoicing tool generate and read e-invoices? If not, switch now – not just before the deadline.
4. Clarify archiving: Make sure the original XML files are stored unalterably and for eight years.
5. Practice issuing: Generate your first e-invoices as a test before your revenue threshold or a customer requires it.

Tip: Talk to your most important customers and suppliers early. Often a brief conversation clarifies which format is expected faster than any amount of research.

How Buchführungsheld handles e-invoicing for you

The effort surrounding formats, booking, and archiving is exactly what you'd rather not do yourself. With Buchführungsheld, you simply upload your receipts – including incoming e-invoices as XRechnung or ZUGFeRD. Real bookkeepers book them correctly, handle the advance VAT return (Umsatzsteuervoranmeldung), and ensure that the structured originals are filed in a GoBD-compliant and audit-proof manner. At a fixed price, without you having to study any standards.

If you want to know what this looks like for your business, take a look at our features and pricing – or book a free preliminary consultation directly. We'll tell you honestly where you stand on e-invoicing (E-Rechnung) and what's still missing.

Frequently asked questions

Is a PDF sent by email an e-invoice?

No. A normal PDF counts as an "other invoice," not as an e-invoice (E-Rechnung), because it cannot be read by machines. Only a structured format per EN 16931 – that is, XRechnung or ZUGFeRD from version 2.0.1 – meets the requirements.

Do I have to issue e-invoices as a small business?

Small businesses under the small-business rule (Kleinunternehmerregelung) per § 19 UStG are exempt from the obligation to issue. However, you must still receive and process e-invoices – that has applied to everyone since January 1, 2025.

Until when may I still write regular invoices?

Until the end of 2026, paper and PDF are permitted in B2B with the recipient's consent. From 2027, e-invoicing (E-Rechnung) becomes mandatory for companies with more than 800,000 euros in prior-year revenue, and from 2028 for all domestic B2B transactions.

How long do I have to keep e-invoices?

The retention period for invoices is eight years (§ 14b UStG). For e-invoices, you keep the structured part – the XML file – in its original, unalterable form.