Hanuma Global
Services Consulting & Training Resources Insights & articles Country mandate tracker Readiness scorecard Company About us How we work Helios ↗ Contact us

E-invoicing in Germany

Rolling out Confidence: high Checked 21 Jul 2026
ModelB2B · decentralised EN 16931 exchange (no national platform or clearance)
Required formatXRechnung / ZUGFeRD 2.x (any EN 16931-compliant format)
Timeline2025–28

Who is in scope

Domestic B2B only — both supplier and customer established in Germany (seat, management, or a participating fixed establishment). B2C excluded. Carve-outs: small-value invoices up to €250 (§33 UStDV), travel tickets (§34 UStDV), and supplies exempt under §4 nos. 8–29 UStG. No clearance, no reporting platform, no government portal — transmission is left to the parties (email, portal, Peppol, EDI).

Key dates

  • 27 Nov 2020 B2G: federal contracting authorities must receive XRechnung (E-Rechnungsverordnung); Länder followed on their own timetables.
  • 1 Jan 2025 RECEIVE obligation: every business established in Germany must be able to receive EN 16931-compliant e-invoices for domestic B2B supplies. No consent required from the recipient.
  • 1 Jan 2025 → 31 Dec 2026 Transition: paper and unstructured PDF invoices may still be ISSUED for domestic B2B, with the recipient's consent.
  • 1 Jan 2027 ISSUE obligation for businesses whose prior-year (2026) total turnover exceeded €800,000.
  • 1 Jan 2027 → 31 Dec 2027 Businesses with 2026 turnover ≤ €800,000 may still issue paper/PDF with recipient consent; EDI-only arrangements must be EN 16931-extractable.
  • 1 Jan 2028 Turnover threshold falls away — all non-exempt domestic B2B invoices must be issued as EN 16931 e-invoices; EDI transition ends.
What practitioners get burned by

Three things. (1) The operative guidance is now the BMF-Schreiben of 15 Oct 2025 — the second application letter, which supersedes/extends the 15 Oct 2024 one; anyone still working from the 2024 letter is out of date (it changed treatment of corrections, §14c liability, EDI and hybrid formats). (2) The €800,000 test is on 2026 turnover, so the number that decides a company's 2027 obligation is already being earned now. (3) Germany has no e-reporting/clearance system yet — the transaction-reporting layer was deferred pending ViDA (2030), so 'Germany is done in 2028' is wrong; a second wave is coming.

Sources

3 of 5 are primary sources. Mandate dates move — treat this page as a starting point and confirm against the primary source before committing a plan.

Also in Europe

Planning for Germany?

A page is a starting point. A scoped analysis gives you the specification, the mapping and the effort — in weeks, not quarters.