Germany eInvoicing mandate: requirements, formats, and what changes in 2027

Germany’s domestic B2B eInvoicing obligation has applied since January 1, 2025. Every business established in Germany has had to be able to receive structured eInvoices since that date, with no transition period and no right to refuse. Starting on January 1, 2027, businesses whose 2026 turnover exceeded €800,000 will also have to issue them for domestic B2B transactions. Smaller issuers follow on January 1, 2028. You can issue an XRechnung, a qualifying ZUGFeRD invoice, or a Peppol BIS invoice, and you agree on the delivery channel with each customer, including email or Peppol. There is no government platform to clear invoices through.

What changes in 2027?

From January 1, 2027, German businesses with more than €800,000 in turnover in 2026 have to issue eInvoices to their business customers in Germany. Paper invoices and ordinary PDFs are no longer an option for those sales.

Germany eInvoicing timeline

Germany has added its eInvoicing obligations one at a time, starting with invoices to the public sector in 2020, followed by the B2B mandate in phases from 2025. 

Scope and start dates

Whether you have to issue eInvoices, and from when, depends on who you sell to and how much you sell in Germany.

Who is in scope: The mandate applies when you sell to another business and both of you are established in Germany. You count as established if your company is registered in Germany, is run from Germany, or has a German branch or office that takes part in the sale. Cross-border sales, where either side is established outside Germany, fall outside the mandate. A foreign company with a German VAT number but no establishment in Germany is outside the mandate too, whatever its turnover.

When you start: That depends on your German VAT turnover in the previous calendar year, which can differ from the revenue in your accounts. Above €800,000, you start on January 1, 2027. At or below it, you can keep sending paper invoices, or PDFs if your customer agrees, until the end of 2027. If your German companies are in a VAT group, the group’s combined German turnover counts. Deposit and advance invoices you issue before your start date don’t have to be eInvoices, even if the work or payment comes later. Businesses using the Kleinunternehmer small-business scheme can keep issuing paper invoices, or PDFs if their customer agrees, with no deadline. They still have to be able to receive eInvoices.

Even after your start date, in 2027 or 2028, not every invoice has to be an eInvoice.

Germany eInvoicing formats

The mandate requires invoices a machine can read. Each invoice has to be structured data that meets the European standard EN 16931 and carries the details German VAT law requires. In practice, that means one of three formats.

If you use ZUGFeRD, check two things. Not every version counts. The BMF accepts version 2.0.1 onwards and excludes the MINIMUM and BASIC-WL profiles, which don’t carry the full invoice data. And if the PDF and the embedded data disagree, the data takes precedence, so the version your customer reads on screen isn’t the one that counts for VAT.

If you already issue Peppol BIS invoices in other countries, most of the work is done. Germany adds a few required fields. When both supplier and customer are located in Germany, Peppol’s German validation rules require payment instructions, a seller contact with a telephone number and email address, and a buyer reference. XRechnung’s national rules require the same fields on every XRechnung invoice. For B2B, the buyer reference is whatever your customer gives you, such as a purchase order number. The Leitweg-ID is only needed for invoices to public authorities. Most other countries don’t require all of these fields, so a system that already sends Peppol invoices elsewhere may leave them empty. If it does, your German invoices will fail validation and can be rejected.

What counts as a valid eInvoice

Beyond the format, the invoice data has to contain every detail a German VAT invoice needs, including your and your customer’s names and addresses, your VAT ID or tax number, the invoice number and date, the date of supply, what you supplied, and the net amount, VAT rate, and VAT amount.

The BMF’s latest guidance, published on October 15, 2026, adds two points that matter for your billing system.

The description of what you sold has to be in the structured data. The data has to say what you supplied, how much, and where you supplied it if that affects the VAT, in enough detail to check the VAT treatment. A description that only appears on the PDF isn’t enough. Supporting detail, such as a timesheet, can go in an attachment.

A failed validation rule doesn’t automatically make the invoice invalid. If the file can be read and the VAT details are correct, the invoice stays valid for VAT even when it breaks a technical rule on a field that isn’t a VAT detail. This matters most for invoices you receive. If your system rejects every invoice that fails a rule, it may be rejecting valid ones. Before you reject an invoice, check whether the rule it failed is about a VAT detail.

Sending and receiving eInvoices

The German mandate regulates the invoice itself, but there is no central platform and no clearance step, so the tax authority does not see the document when you send it. Compare that with France, where every domestic B2B invoice runs through a plateforme agréée (an accredited platform), or Spain, where a copia fiel of each invoice will have to reach the AEAT. Germany asks for neither, and it has not legislated eReporting yet.

Instead, you agree on a delivery method with each customer. The BMF allows email, electronic interfaces, and portals, so your setup can vary by customer. You might send over Peppol to one buyer, email a ZUGFeRD file to another, and upload an XRechnung file to a third buyer’s supplier portal. 

Peppol is optional in Germany, so some of your customers won’t be registered on it. If you build around it, you may still need a second route for everyone else, such as sending the XRechnung or ZUGFeRD file by email.

If you do use Peppol, your German entity needs its own Peppol address so suppliers can find it. KoSIT, the German Peppol Authority, recommends your German VAT number. Since August 2026, you can also use a German Electronic Business Address (GEBA), Peppol code 0246, which lets you route invoices to a specific unit such as your accounting team.

What 2027 means for the invoices you receive

You’ve had to be able to receive eInvoices since January 1, 2025, and you can’t refuse them. From 2027, larger suppliers have to send them, and smaller ones follow in 2028, so more of the invoices you receive will arrive as XRechnung or ZUGFeRD files.

The BMF accepts an email inbox as enough to receive, but what arrives still needs handling. An XRechnung is a data file a person can’t read without software. If a supplier sends you a valid eInvoice and you can’t process it, their obligation is still met, and any delay in booking or paying it is yours.

Invoices will also keep arriving in different formats and through different channels, including PDFs from suppliers abroad and from small businesses that are exempt. Plan for one process that can check, approve, and pay all of them.

What are the penalties?

There’s no fine for sending a paper or PDF invoice when you should have sent an eInvoice. The BMF confirmed in its October 2026 guidance that sending a PDF instead isn’t an administrative offense. Not issuing an invoice at all, or issuing it late, can still be fined up to €5,000.

You still have to issue eInvoices, and getting it wrong costs in other ways. Your customer needs a valid invoice to reclaim the VAT they paid you, so a PDF puts that deduction at risk. Your customer may hold payment until you send an eInvoice, which means you get paid later (higher DSO). You may also have to reissue the invoice, and the error can come up in an audit.

How long do you need to keep eInvoices?

You have to keep every invoice you issue and receive for 8 years, counted from the end of the year the invoice was issued.

For an eInvoice, you have to keep the original file, exactly as you sent or received it, in its machine-readable format so the tax authority can read it. A PDF view isn’t enough, and neither is the data your software extracted and stored in its own records. Check how your eInvoicing tool stores invoices, and whether it keeps the original file when it converts them.

Get ready to issue eInvoices in Germany

The eInvoicing format is the easy part. Most of the work is in your customer data and in handling exceptions, such as credit notes, corrections, and invoices that fail validation.

Start with your customer data. Your billing system needs to tell German business customers apart from consumers and foreign businesses, with their VAT ID and address on file. If you couldn’t reasonably have known a customer was a business, the tax authority won’t challenge a PDF you sent them. And if you sell to a mix of consumers and businesses on ongoing contracts, checking once at signup, or when the contract changes, is enough. Your billing system also has to store the extra fields the German rules require, such as the buyer reference, and pass them to your eInvoicing tool.

Then look at the exceptions. Refunds and corrections often run through a separate flow in your billing system, and the credit notes they create have to be eInvoices too. When an invoice fails validation, someone needs to see why, fix it, and resend it.

With the right eInvoicing tool, you don’t have to rebuild your billing system or ERP, and your team keeps working the way it does today. When you compare tools, ask what “Germany support” covers in practice, including how each tool handles your exceptions.

Invopop supports German eInvoicing, including XRechnung, ZUGFeRD, and Peppol BIS, and adapts to how you and your customers want to send and receive eInvoices. It takes the invoice data from your billing system or ERP, turns it into the German format each customer needs, checks it against the German rules, and can issue through Peppol or fall back to email when a customer isn’t on the network. 

Talk to our team about what your setup needs for Germany.

Frequently asked questions about Germany B2B eInvoicing mandate