German E-Invoicing (E-Rechnung)
Last updated: 2026-02-26
German E-Invoicing (E-Rechnung)
Last updated: 2026-02-26 | Sources: BMF — E-Rechnungspflicht, §14 UStG
Current Status
Germany has introduced a phased e-invoicing mandate (E-Rechnungspflicht) for domestic B2B transactions, implemented through amendments to §14 UStG as part of the Wachstumschancengesetz (Growth Opportunities Act).
Timeline
| Date | Requirement |
|---|---|
| January 1, 2025 | All businesses must be able to receive e-invoices in structured format |
| January 1, 2027 | Businesses with prior-year turnover > €800,000 must send e-invoices |
| January 1, 2028 | All businesses must send e-invoices for domestic B2B transactions |
What Qualifies as an E-Rechnung
An E-Rechnung (electronic invoice) in the German context must be a structured electronic format compliant with EN 16931. Accepted formats:
- XRechnung — the German CIUS (Core Invoice Usage Specification) of EN 16931, using UBL 2.1 or UN/CEFACT CII syntax
- ZUGFeRD 2.x (Zentraler User Guide des Forums elektronische Rechnung Deutschland) — a hybrid format embedding a structured XML (Cross-Industry Invoice) within a PDF/A-3. Only ZUGFeRD profiles "EN 16931" (formerly "Comfort") and above qualify
- Any other format conforming to EN 16931
Important: A plain PDF is not an E-Rechnung. A PDF is considered "sonstige Rechnung" (other invoice) and will no longer be accepted for domestic B2B after the transition periods.
Transition Period (2025-2027)
During the transition period:
- Receiving: All businesses must accept structured e-invoices from January 1, 2025. This means having a system (even just an email inbox) capable of receiving XML/ZUGFeRD files
- Sending: Businesses may continue sending PDF invoices until their size-based deadline
- Businesses with turnover ≤ €800,000 may send PDF invoices through December 31, 2027
- EDI procedures: Existing EDI (Electronic Data Interchange) systems may continue through December 31, 2027, even if not EN 16931-compliant
Exemptions
The following are exempt from the E-Rechnung requirement:
- Kleinbetragsrechnungen (small invoices up to €250 gross)
- Fahrausweise (travel tickets/transportation documents)
- B2C transactions
- Cross-border transactions (though EU-level ViDA requirements may apply later)
- Tax-exempt supplies under §4 Nr. 8-29 UStG (e.g., medical services, insurance, financial services)
Kleinunternehmer and E-Rechnung
Kleinunternehmer (small businesses under §19 UStG) must be able to receive e-invoices from January 1, 2025, like all other businesses. For sending, they are subject to the same timeline:
- From January 1, 2028, Kleinunternehmer must also send e-invoices for B2B transactions
- Their e-invoices will show €0.00 VAT with the §19 UStG exemption note
Technical Requirements
- E-invoices must be transmitted electronically (email with XML attachment is acceptable)
- No specific transmission channel is mandated (Peppol is not required, but may be used)
- The structured data must be machine-readable and processable without manual intervention
- Businesses must ensure the authenticity of origin, integrity of content, and legibility of the invoice
Practical Impact for Muckle Users
- German users creating invoices for domestic B2B customers need to be aware of the send deadline for their size bracket
- PDF download remains valid for sending during the transition period
- Future: Muckle will offer XRechnung/ZUGFeRD export for German users who need to send structured e-invoices
Recent Updates
- 2025-11-08: EU Council adopted the ViDA (VAT in the Digital Age) package, which will layer EU-wide digital reporting requirements on top of national e-invoicing mandates.
- 2025-01-01: E-Rechnung receiving obligation went live for all German businesses.