E-invoicing in Germany: what English-speaking businesses actually have to do

Germany's e-invoicing rules are not complicated, but almost everything written about them is in German, aimed at German accountants, and published by companies selling accounting software. This is the same information in plain English, without the sales pitch: which deadline binds you, whether the rules reach you at all, and the short list of things you genuinely need.

The single most useful fact up front: the law regulates the invoice file, not how you send it. There is no German equivalent of Italy's clearance system or France's public portal for ordinary business-to-business invoices. A compliant file attached to a normal email fully satisfies the law. You do not need an ERP system, an accounting subscription, a service provider or a network membership.

The three deadlines

Note which one is already in force. The receiving obligation started in January 2025 and had no grace period at all. If an XRechnung arrives today and you cannot open it, check it and archive it properly, you are already behind, whatever your size.

The threshold that decides between 2027 and 2028 is the total turnover of the whole business, not the part you invoice to companies, and it is a net figure. Turnover with private customers counts towards it too.

Does any of this apply to you?

Four questions settle it:

1. Are you established in Germany? The obligation covers domestic transactions where both sides are established in Germany. A company with no German establishment is not bound by it, even when invoicing German customers.
2. Do you invoice businesses? Invoices to private consumers are not covered.
3. Are your invoices above 250 euro? Small-value invoices up to 250 euro and transport tickets may permanently stay ordinary invoices.
4. Do you use the Kleinunternehmer scheme? If so, you never have to issue an e-invoice, though you must still be able to receive one.

The Kleinunternehmer scheme is the small business arrangement for businesses under a turnover threshold, who therefore charge no VAT. If that is you, the issuing obligation never arrives. Many freelancers in that position switch anyway, because larger clients start asking.

If you are a foreign supplier who has been told by a German customer that they now need a structured invoice, they are usually right about their own needs even though the law does not bind you. Sending one costs you little and saves them manual work; what to do when a German customer asks covers that case in full, including what a cross-border invoice must contain either way.

What actually counts as an e-invoice

Not a PDF. That is the whole surprise, and it catches everyone.

An e-invoice carries the invoice as structured data in a defined format that follows the European standard EN 16931. A PDF is a picture of an invoice: a person can read every figure on it, and a machine can read none of them reliably. Scans, Word documents and invoices in the body of an email are equally out.

Two formats matter in Germany:

• ZUGFeRD is a hybrid: a normal PDF that looks exactly like your current invoice, with the structured data embedded invisibly inside it. Your customer can open it like any PDF, and their software can read the data. For business customers this is almost always the right choice; the ZUGFeRD format guide shows how the file is built.
• XRechnung is pure XML with no visual layer. It is what German public authorities require, along with a routing identifier they give you. A person cannot read it without a suitable viewer.

Both satisfy the same standard, so for a private-sector customer either is legally fine. ZUGFeRD is the friendlier option because it does not depend on what software your customer has.

What you do not need

• No portal. For domestic business-to-business invoices there is no government system to submit through.
• No provider or network. Peppol exists and is useful, but it is optional here.
• No new accounting software. The obligation is about the file. Keep your current invoicing method and add one step.
• No permission from your customer. A proper e-invoice needs no agreement, and since 2025 the recipient may not refuse it. Ironically it is the plain PDF that needs their consent while the transition lasts.

What you do need

1. A correct file. It must pass the rules of the standard, not merely carry the right label. Software that claims compliance can still produce files that fail.
2. A way to read what arrives. An ordinary email inbox is legally enough to receive, but you also need to open and check incoming invoices before paying them.
3. Proper archiving. Keep the structured original unchanged for eight years. A printout is not the original, and neither is a PDF you regenerated. An email inbox is not an archive.

What to do this week

1. Work out which deadline is yours from your 2026 turnover. Everything else follows from that date.
2. Test the receiving side today, because that obligation is already running. Take an e-invoice you have received and open it in the XRechnung viewer to confirm you can read and check it. The viewer also accepts ZUGFeRD PDFs.
3. Produce one compliant invoice and see what your customers will get. You can create a ZUGFeRD invoice in the browser, or convert an invoice you already have to ZUGFeRD if your current software cannot. Every route, from the form to XML from your own software, is laid out on creating e-invoices.
4. Check what your current software produces. If you already generate e-invoices elsewhere, run one through the ZUGFeRD validator; it names exactly what is missing, in plain language.
5. Sort out archiving before the volume grows, not after.

None of this requires German. The tools on this site work in English, and so does the assistant if you would rather describe what you need than fill in a form.

Legal position as at September 2026, last reviewed on 8 September 2026. Based on sections 14, 14b and 27(38) of the German VAT Act, section 34a of the VAT Implementing Regulation, the European standard EN 16931 and the German Finance Ministry letters of 15 October 2024 and 15 October 2025. This article is general information, not tax advice. Whether a specific obligation applies to your business is a question for your Steuerberater, the German tax adviser.

Frequently asked questions

I am a freelancer in Germany. When do I have to start?

You already had to start receiving on 1 January 2025, with no transition period. For issuing, the date is 1 January 2027 if your total 2026 turnover was above 800,000 euro, and 1 January 2028 otherwise. If you use the Kleinunternehmer small business scheme, you never have to issue one.

My company is outside Germany. Does the German mandate apply to me?

Generally no. The obligation covers domestic transactions where both supplier and customer are established in Germany. A company with no German establishment is not bound by it. Your German customers may still ask for a structured invoice, because it is far easier for them to process, and you are free to send one.

Is a PDF invoice still allowed?

Until your own deadline, yes, though a plain PDF needs the recipient's agreement, which can be tacit. After your deadline a PDF is no longer a proper invoice for domestic business-to-business sales. Invoices up to 250 euro and invoices to private consumers are permanently exempt.

Do I need to join a network or use a government portal?

Not for business-to-business invoices in Germany. There is no clearance portal of the kind Italy and France operate. A compliant file attached to an ordinary email satisfies the law. Portals and routing identifiers only come into play when you invoice public authorities.

Which format should I use, ZUGFeRD or XRechnung?

For business customers, ZUGFeRD: it is a normal PDF with the data embedded inside, so your customer can read it even if their software cannot. For public authorities, XRechnung, which also needs a routing identifier from the authority. Both satisfy the same European standard.