Germany E-Invoicing Deadlines: The 2025–2028 Timeline Every Company Must Know
Germany is switching domestic B2B invoicing to structured electronic invoices under Section 14 of the German VAT Act (UStG), and the transition runs on a fixed calendar. Since January 1, 2025, every business in Germany must be able to receive compliant e-invoices — there is no size threshold and no opt-out for this reception duty. Many international groups discover this the hard way: their German subsidiary is already legally required to process XRechnung and ZUGFeRD invoices today, even though nobody in the group has ever heard of either format.
On the issuing side, transitional rules soften the start. Through the end of 2026, businesses may still send paper or simple PDF invoices for domestic B2B supplies (PDF only with the recipient's consent). From January 1, 2027, businesses whose prior-year turnover exceeded €800,000 must issue structured e-invoices; from January 1, 2028, the obligation covers all businesses making domestic B2B supplies in Germany. After that, a plain PDF simply no longer qualifies as an invoice for these transactions.
The pragmatic response is to treat 2026 as the implementation window rather than a grace period. Reception must work now, customer-side rejections of non-structured invoices are already common, and converting outbound flows takes months when ERP data is incomplete. Services like Taxlayer convert PDF invoices to ZUGFeRD automatically, and a free e-invoice validator lets you verify that generated invoices actually pass EN 16931 validation before customers test them for you.
Your checklist
- 1Confirm reception capability immediately: your German entity must have been able to receive and process EN 16931 e-invoices since January 1, 2025 — a monitored email inbox that accepts XML and ZUGFeRD files is the minimum.
- 2Determine your issuance deadline: check whether the German entity's prior-year turnover exceeds €800,000 — if so, mandatory issuance starts January 1, 2027; otherwise January 1, 2028.
- 3Map every domestic B2B invoice flow against the timeline, including intercompany invoices between German group entities, which are covered like any other domestic B2B supply.
- 4Stop relying on recipient consent for PDFs: it only carries you through the transition period, and large German customers are already refusing unstructured invoices ahead of the deadlines.
- 5Plan the outbound conversion project for 2026: close EN 16931 data gaps in your ERP, choose ZUGFeRD or XRechnung per customer segment, and pilot with a few German customers early.
- 6Validate before go-live: run generated e-invoices through an EN 16931 validator so format errors are found in testing, not in your customers' accounts-payable rejections.
- 7Update archiving to GoBD standards: store the structured XML unchanged for the statutory retention period — the XML, not the rendered PDF, is the invoice.
- 8Brief accounts payable on supplier deadlines too: from 2027/2028 your German suppliers must invoice you structurally, and your booking process should verify and use the XML data — our e-invoicing checklist covers the full setup.
Frequently asked questions
What are the key dates of the German e-invoicing mandate?
January 1, 2025: all German businesses must be able to receive structured e-invoices for domestic B2B transactions. January 1, 2027: businesses with more than €800,000 prior-year turnover must issue e-invoices. January 1, 2028: the issuance obligation applies to all businesses. The legal basis is Section 14 of the German VAT Act (UStG) as amended by the Growth Opportunities Act.
Is the reception obligation really already in force?
Yes. Since January 1, 2025, every business established in Germany must be able to receive and process compliant e-invoices for domestic B2B supplies, regardless of size or sector. Unlike the issuance duty, there is no transition period for reception — a supplier may send you a structured e-invoice today, and you cannot refuse it.
Can we keep sending PDF invoices until 2028?
Only within the transitional rules. Until the end of 2026, paper and — with the recipient's consent — unstructured formats like plain PDF remain permitted for domestic B2B supplies. Businesses above €800,000 prior-year turnover lose this option from 2027; all others from 2028. Many large German customers are demanding structured formats earlier by policy.
Does the German mandate cover invoices from foreign companies?
The issuance obligation covers domestic B2B supplies between businesses established in Germany, so a foreign entity without a German establishment is generally outside the statutory duty. However, a foreign group's German subsidiary is fully in scope, and German customers increasingly require EN 16931 invoices from all suppliers operationally, whatever the statute says.