E-invoicing in Germany: what suppliers need to know

E-invoicing in Germany is mandatory in two steps. Since 1 January 2025, every business established in Germany must be able to receive e-invoices from other businesses. From 1 January 2027, businesses whose total turnover in 2026 was above €800,000 must also issue them; from 1 January 2028, all businesses must.

The rules apply to supplies between businesses established in Germany. Foreign suppliers without a fixed establishment in Germany are generally outside the mandate. This article explains who is affected, which formats count and what the German Federal Ministry of Finance clarified in October 2026.

Who the German e-invoicing mandate applies to

The mandate covers business-to-business supplies where both sides are domestic businesses. According to the Ministry of Finance, a business counts as domestic if it has its seat, its management or a fixed establishment involved in the supply in Germany.

Situation	E-invoice required?
German business invoicing a German business customer	Yes, in line with the timeline below
Foreign business with a German fixed establishment involved in the supply	Yes
Foreign business registered for VAT in Germany, without a fixed establishment there	No, and it may state this on the invoice
Invoices to consumers	No
Supplies to or from businesses abroad	Not under the German rules (see “After 2030” below)

The note on the invoice matters in practice. A German customer may rely on a foreign supplier’s statement that it has no fixed establishment in Germany, provided the customer acts with the care of a prudent business person. Whether a fixed establishment exists depends on the facts, so check it with a tax adviser if you have staff, premises or equipment in Germany.

Timeline and exceptions

From	Receiving	Issuing
1 January 2025	Required for all domestic businesses	Paper still allowed; PDF or other formats only with the recipient’s consent
1 January 2027	Required	Required if total turnover in 2026 was above €800,000
1 January 2028	Required	Required for all domestic businesses

The €800,000 threshold refers to total turnover as defined in section 19(2) of the German VAT Act. It is calculated on payments received and includes sales to consumers. A metal fabricator that received €650,000 from business customers and €300,000 from private customers in 2026 is above the threshold and must issue e-invoices from 2027. Existing EDI arrangements that do not meet the e-invoice requirements may be used until the end of 2027.

Some invoices never need to be e-invoices, even for businesses in scope:

• invoices of up to €250 gross (small-amount invoices),
• tickets that count as invoices,
• supplies by small businesses under the German small business scheme (they must still be able to receive e-invoices),
• invoices to consumers and to legal entities that are not businesses, such as many associations.

What counts as an e-invoice

An e-invoice is a structured electronic invoice based on the European standard EN 16931 that can be processed automatically. The two common German formats are:

• XRechnung: a pure XML file, readable for people only with a viewer.
• ZUGFeRD from version 2.0.1, except the profiles MINIMUM and BASIC-WL: a PDF with embedded XML data, readable for both people and software.

A plain PDF sent by email is not an e-invoice. For receiving, an email inbox is enough. To read XRechnung or ZUGFeRD files without special software, the German tax administration offers a free viewer at e-rechnung.elster.de.

What the October 2026 guidance clarifies

On 15 October 2026, the Ministry of Finance published supplementary rules. Several points matter for manufacturers and the trades:

• Progress invoices issued before your obligation starts do not have to be e-invoices, even if the work or payment follows later.
• Final invoices: until 30 June 2030, progress payments already received may be deducted as a single total in the structured part, with the details in a free-text field or an embedded attachment.
• Construction work: the structured part may list only the individual trades with their totals, as long as the detailed bill of quantities is attached in human-readable form.
• Supporting detail such as timesheets may go into an embedded attachment, as long as the structured part describes the type, scope and tax rate of the service.
• Corrections to an e-invoice must also be issued as e-invoices.
• Sanctions: issuing an “other invoice” where an e-invoice is required is not an administrative offence under section 26a of the German VAT Act. Discuss the wider consequences, for example for your customer’s input VAT deduction, with your tax adviser.

Storing e-invoices

For VAT purposes, businesses in Germany must keep a copy of every incoming and outgoing invoice for eight years. For an e-invoice, at least the structured part has to be stored so that it remains unaltered in its original form.

After 2030: cross-border invoices in the EU

The German mandate covers domestic supplies only. At EU level, the VAT in the Digital Age package was adopted in March 2025. From 1 July 2030, it introduces digital reporting requirements based on mandatory e-invoicing for cross-border business-to-business supplies within the EU. Suppliers who trade across EU borders will need e-invoicing for those transactions too.

E-invoicing with ERPNext

If you run ERPNext, the German formats are covered by a free open-source extension. It creates XRechnung and ZUGFeRD or Factur-X invoices (profiles BASIC, EN 16931, EXTENDED and XRECHNUNG) directly from a sales invoice and imports incoming e-invoices as purchase invoices. It does not send or receive invoices via Peppol and does not handle the UBL format, so check which channel and format your customers expect.

At openBlueprint, we set up ERPNext for small and mid-sized manufacturers and businesses in the trades, including e-invoicing and the export of bookkeeping data for German tax advisers. The overview of further areas shows how invoicing, stock and accounting build on the same database.

What to do now

1. Check whether you are domestic. Seat, management or a fixed establishment involved in the supply in Germany means the mandate applies.
2. Check your 2026 turnover with your tax adviser to know whether your deadline is 1 January 2027 or 2028.
3. Test your invoicing software. Create a test invoice as XRechnung or ZUGFeRD and have it validated.
4. Ask your key customers which format and address they expect.
5. Organise incoming invoices so their data reaches your bookkeeping without re-typing.

This article reflects the Ministry of Finance guidance as of 15 October 2026. It is not tax advice.