🇩🇪 Germany E-Invoicing Mandate (E-Rechnung)

Overview of E-Invoicing in Germany

Germany's e-invoicing mandate, known as the E-Rechnung (electronic invoice) reform, is one of the most significant changes to German tax administration in decades. The Growth Opportunities Act (Wachstumschancengesetz), passed in March 2024, established a phased approach to mandatory B2B e-invoicing that begins with a universal obligation to receive structured electronic invoices from January 1, 2025, followed by a phased sending obligation starting January 1, 2027.

Germany's approach is notable for its format flexibility — rather than mandating a single national format, the law requires compliance with the European standard EN 16931, which means businesses can use XRechnung, ZUGFeRD 2.x, or any other EN 16931-compliant format. This flexibility reflects Germany's large and diverse business landscape, from global enterprises to the Mittelstand (small and medium enterprises) that form the backbone of the German economy.

For businesses operating across borders, Germany's alignment with EN 16931 ensures interoperability with Belgium, France, and other EU countries moving toward e-invoicing mandates.

Timeline of Germany's E-Invoicing Mandate

Who Is Affected?

B2G (Business-to-Government)

The B2G mandate has been in place since November 2020. Federal suppliers must use XRechnung submitted via the ZRE portal. Most German states (Bundesländer) have also implemented their own e-invoicing portals. If you do business with the German public sector, you should already be fully compliant.

B2B (Business-to-Business)

The B2B mandate is phased by obligation type and company size:

• From January 2025: All businesses must be able to receive e-invoices — this means having software or processes that can ingest and interpret structured XML data.
• From January 2027: Businesses with prior-year revenue above €800,000 must send e-invoices.
• From January 2028: All businesses must send e-invoices, completing the mandate.

This phased approach gives smaller companies additional time but requires immediate action on the receiving side. Even if you are a small business, you must be ready to accept e-invoices from your suppliers starting January 2025.

B2C (Business-to-Consumer)

Business-to-consumer invoicing is exempt from the E-Rechnung mandate. There is no obligation to send structured e-invoices to end consumers, and no timeline has been announced for extending the mandate to B2C.

Accepted Formats and Technical Standards

Germany accepts any format compliant with the European standard EN 16931. In practice, the most commonly used formats are:

XRechnung

XRechnung is Germany's national e-invoicing standard and the required format for B2G transactions. It is a pure XML format based on UBL 2.1 or CII (Cross Industry Invoice) syntax. XRechnung is maintained by KoSIT (Koordinierungsstelle für IT-Standards) and includes Germany-specific business rules on top of EN 16931. See our XRechnung format guide for detailed technical information.

ZUGFeRD 2.x

ZUGFeRD (Zentraler User Guide des Forums elektronische Rechnung Deutschland) is a hybrid format that embeds a structured XML file inside a PDF/A-3 document. ZUGFeRD 2.1 and later versions are EN 16931-compliant and therefore accepted for the B2B mandate. The "Extended" and "XRechnung" profiles of ZUGFeRD fully satisfy the requirements. For more details, consult our ZUGFeRD format guide.

Other EN 16931 Formats

Any other format that implements the EN 16931 semantic data model is technically acceptable. This includes Peppol BIS 3.0 and Factur-X (the French counterpart of ZUGFeRD). Businesses trading across borders may find it practical to use Peppol BIS 3.0 for transactions with partners in countries like Belgium that mandate Peppol.

Important: Simple PDF invoices, scanned documents, and image files are explicitly not e-invoices under the German mandate. A valid e-invoice must contain structured, machine-readable data in an EN 16931-compliant format.

How to Prepare for the E-Rechnung Mandate

1. Ensure receiving capability now. Since January 2025, you must be able to accept EN 16931-compliant invoices. At minimum, set up an email inbox or portal that can receive XML files, and acquire software to read and process them.
2. Choose your sending format. Decide whether XRechnung or ZUGFeRD best fits your workflow. XRechnung is pure XML and works well for automated processing. ZUGFeRD provides a human-readable PDF alongside the structured data, which can ease the transition.
3. Update your ERP or accounting software. Most major German accounting platforms (DATEV, SAP, Lexware, etc.) either already support or are adding support for E-Rechnung. Verify your vendor's roadmap.
4. Validate your invoices. Use the KoSIT validation tool or other EN 16931 validators to ensure your invoices pass all business rules before sending them to customers.
5. Coordinate with trading partners. Confirm that your suppliers and customers are also preparing for the mandate, and test exchange of structured invoices ahead of the sending deadlines.

Germany vs. Other EU E-Invoicing Mandates

Germany's phased approach contrasts with Belgium, which mandates a single go-live date (January 2026) with a single format (Peppol BIS 3.0). France takes a platform-based approach with Chorus Pro and certified PDPs, starting September 2026 for large enterprises. Italy has had universal e-invoicing since 2019 using its country-specific FatturaPA format through the SDI system.

Germany's format flexibility is a distinguishing feature — businesses can choose the EN 16931 implementation that best suits their needs, rather than being locked into a single national format. This is advantageous for companies with international operations that may already use Peppol BIS or ZUGFeRD.

Frequently Asked Questions