E-invoicing in Germany: when your shop has to issue e-invoices

What an e-invoice is

Under German VAT law, an e-invoice is an invoice in a structured electronic format that software can read. The format has to follow the European e-invoicing standard EN 16931 or convert to it without loss.

A PDF sent by email is not an e-invoice. German law calls it an “other invoice”, just like paper.

Two formats are common in Germany. XRechnung is a pure XML file that people can hardly read without software. ZUGFeRD is a PDF with the XML file attached: your customer sees the usual invoice, their accounting reads the data. According to the German Federal Ministry of Finance, ZUGFeRD counts from version 2.0.1, except the MINIMUM and BASIC-WL profiles.

Who has to do what, and when

The obligation covers invoices to other businesses for their business, when both you and your customer are established in Germany. It is in section 14 of the German VAT Act, introduced by the Growth Opportunities Act. The transition periods are in section 27(38).

1. 1

   Since 1 January 2025: receiving

   Every business has to accept e-invoices, including small businesses under the VAT exemption. An email inbox is enough. The sender does not need your consent.

2. 2

   Until 31 December 2026: transition for all

   You may still send businesses paper, or a PDF if the customer agrees.

3. 3

   From 1 January 2027: turnover above €800,000

   If your total turnover in 2026 was above €800,000, invoices to businesses in Germany have to be e-invoices. Until the end of 2027, the only exception is an EDI procedure agreed with the customer.

4. 4

   Until 31 December 2027: transition up to €800,000

   With lower turnover in the previous year, you may still send paper in 2027, or a PDF with consent.

5. 5

   From 1 January 2028: everyone

   The obligation then applies regardless of turnover. Small businesses under the VAT exemption and invoices up to €250 remain exempt.

What does not affect you

The €800,000 is your total turnover in the previous year, not only your sales to businesses. It has nothing to do with the threshold for the small business VAT exemption.

• Invoices to consumers. If you only sell to consumers, you do not have to issue e-invoices, only be able to receive them.
• Invoices up to €250 in total. They can always go out as PDF or paper.
• Small businesses under the VAT exemption, when issuing. They still have to be able to receive e-invoices.
• Invoices to businesses outside Germany. The German obligation only applies when both sides are established in Germany.

What it means for your shop

Nothing changes for orders from consumers. The point is business customers: when a business buys from you for its business and the invoice is above €250, you need an e-invoice from your deadline.

Check where your invoices are created: in the shop system, an invoicing app or your accounting software. That is where the format has to be right and where you switch on ZUGFeRD or XRechnung.

An inbox is enough to receive, but you also have to be able to read and book the files. An XRechnung without suitable software is just a block of XML.

And in the rest of the EU?

The obligation above is German law. The EU is following: under Directive (EU) 2025/516, known as ViDA (VAT in the Digital Age), member states may require domestic e-invoices without the recipient’s consent. From 1 July 2030, e-invoices following the EU standard become the rule, and cross-border sales between businesses will also be reported digitally to the tax authorities.

If you are established in another EU country, your own national rules apply.