A German customer has told you that from January they need e-invoices. Before you buy software or sign up for anything, check whether the rule reaches you at all. For most suppliers based outside Germany it does not, and holding a German VAT number changes nothing on its own.
That said, your customer probably is not wrong to ask. This article separates the two questions: what you are obliged to do, and what is worth doing anyway. It also covers the part that matters more than the format, namely what a cross-border invoice to a German business has to contain regardless.
The rule, and where you sit in it
Germany's obligation covers domestic business-to-business supplies: both the supplier and the customer established in Germany. The decisive test is a fixed establishment, an office, a workshop, a warehouse with staff. It is not the same as a VAT registration, and this is where most of the confusion sits.
| Your situation | Must you issue German e-invoices? |
|---|---|
| No presence in Germany at all, invoicing a German company | No |
| Registered for German VAT, but no fixed establishment | No. Registration alone does not bring you in. |
| A fixed establishment in Germany, invoicing German customers | Yes, on the same timetable as any German business |
| A German subsidiary invoicing German customers | Yes. The subsidiary is a German business. |
If you fall outside, you may say so on the invoice, and some suppliers add a short line noting that they have no fixed establishment in Germany. Which deadline applies to businesses that are inside is covered in the guide to the German deadlines.
So why is your customer asking?
Because their side of this is real, even though yours is not. Four reasons, in the order you are likely to meet them:
- They must be able to receive structured invoices, and have been able to since January 2025. Having built that, they would rather use it than run a second, manual path for a handful of foreign suppliers.
- Your PDF now costs them work. Once accounts payable is set up to read invoices automatically, anything unstructured becomes an exception that a person has to key in.
- Procurement policy often goes further than the law. Large buyers standardise across all suppliers because carve-outs are expensive to administer.
- Nobody separated the cases. Plenty of companies simply told every supplier on the list, domestic or not.
None of that obliges you. It does mean that refusing has a cost: your invoice lands in the slow lane, and slow lanes are where payment dates go to die. For most suppliers, sending a structured file is cheaper than the conversation about not sending one.
What your invoice must contain either way
This is the part worth your attention, because it applies whether you send a PDF or a structured file, and getting it wrong causes real problems for your customer.
Most cross-border business-to-business supplies to a German customer fall under the reverse charge: you do not charge VAT, and your customer accounts for it. A correct reverse charge invoice has some non-obvious requirements:
- No VAT charged. The invoice adds no VAT to the total. In the structured data that is not left blank, though: the standard requires a rate of zero and a tax amount of zero for the reverse charge category. The zero records that the tax moves to your customer, not that the supply is tax-free.
- The prescribed wording. German rules require a note that the recipient owes the tax, which German invoices carry as Steuerschuldnerschaft des Leistungsempfängers. The English phrase reverse charge is widely accepted alongside it.
- Both VAT numbers. Yours and your customer's German one. The customer's number is what lets the transaction be matched on their side.
- A reference to the reverse charge provision, under German law or the equivalent in your own.
One risk sits squarely with you: if your customer's VAT number does not check out, you can end up owing the VAT you never charged. That is worth thirty seconds before you invoice a new customer. You can check any EU VAT number against the European Commission's register and keep the result on file.
If you decide to send one
You need one thing, a correct file, and nothing else. In particular:
- No portal. Germany has no clearance system for business-to-business invoices. Email is a perfectly good delivery method.
- No provider and no network. Peppol is useful and entirely optional; use it if your customer asks for it by name.
- No German software. The obligation, where it applies, is about the file rather than the system that produced it.
Which format? For a company customer, ZUGFeRD: it is an ordinary PDF with the invoice data embedded inside, so it looks like your normal invoice and their software can still read it. XRechnung, pure XML with no visual layer, is what German public authorities require, and they will give you a routing identifier if so.
The detail that catches people out: reverse charge has to live in the data, not only in the wording. The tax category must be set to the reverse charge code, with the rate and the tax amount at zero and an exemption reason stated, either as text or as the standard code VATEX-EU-AE. A file that says reverse charge in a free text field and nothing in the tax fields will fail validation or, worse, pass into your customer's system with no tax treatment recorded.
Practically: create the ZUGFeRD invoice in the browser, or convert the one you already produce to ZUGFeRD. Invoices from other software can be checked in the ZUGFeRD validator, which names anything missing in plain language. The other routes, including credit notes and XML from your own software, are on creating e-invoices.
What this costs you
Nothing structural, which is the point of this article. No German software licence, no registration, no provider contract, no change to how you invoice everyone else. You keep your own system and add one step for the customers who asked.
And if you would rather not, you are within your rights. Just make that a decision rather than an accident, and tell the customer plainly, so their accounts payable team can plan for a manual exception instead of chasing you in February.
Related reading
If you do have a presence in Germany, the guide to the German deadlines covers which one applies to you. For how the hybrid file is put together and which profile to use, see the ZUGFeRD format guide.
Legal position as at September 2026, last reviewed on 10 September 2026. Based on sections 13b, 14 and 14a of the German VAT Act, the transitional rules in section 27(38), 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 the mandate reaches your business, and how a specific supply should be invoiced, is a question for your tax adviser.
Frequently asked questions
I have a German VAT number. Does the mandate apply to me?
Not on its own. The obligation covers supplies where both sides are established in Germany, and the test is a fixed establishment, not a VAT registration. A foreign business registered for German VAT but without a fixed establishment there falls outside it.
My customer says they cannot accept PDFs any more. Are they right?
About their own obligation, probably. About yours, usually not. They must be able to receive structured invoices and are likely standardising on them, but a cross-border supply is not covered by the German rule. Sending one is a commercial decision rather than a legal duty.
Do I need a German portal, a provider or Peppol?
No. There is no clearance portal for business-to-business invoices in Germany, and Peppol is optional. A compliant file attached to an ordinary email is enough. Portals and routing identifiers only apply to invoices to public authorities.
How do I show reverse charge on a structured invoice?
Not as a sentence alone. The tax category has to be set to the reverse charge code, with the rate and the tax amount both at zero and an exemption reason stated, alongside the wording the German rules require. A file that only mentions reverse charge in free text will be read as having no tax treatment at all.
What if my customer's VAT number turns out to be wrong?
That is your risk, not theirs. If the number does not check out, you can end up owing the VAT you never charged. Verify it before you invoice and keep the result.