Germany E-Invoice Mandate 2027/2028: Complete Timeline & Requirements

Germany's B2B E-Invoicing Mandate: What You Need to Know

Germany is implementing a phased approach to mandatory B2B e-invoicing. After years of B2G requirements, the mandate now extends to all business-to-business transactions. This guide breaks down the timeline and what your business needs to do to comply.

The Growth Law (Wachstumschancengesetz)

Germany's e-invoicing mandate stems from the Growth Opportunities Act (Wachstumschancengesetz), which modernizes tax administration and aims to reduce VAT fraud through structured electronic invoicing.

The law mandates that all B2B invoices between German businesses must be in a structured electronic format that complies with European standard EN 16931. Paper invoices and simple PDF emails will no longer be valid for B2B transactions after the transition periods.

Detailed Timeline Breakdown

Phase 1: Reception Capability (January 1, 2025) ✓ ACTIVE

Since January 1, 2025, all German businesses must be technically capable of receiving e-invoices in EN 16931-compliant formats. This means:

• You must have a system to receive XRechnung or ZUGFeRD invoices
• You cannot refuse an e-invoice from a supplier
• You may still send paper/PDF during the transition period

Transition Period (2025-2026)

During this period, businesses can still send paper invoices or PDF invoices if:

• The recipient agrees to receive paper/PDF
• The invoice amount does not exceed €250 (simplified invoices)

This is a grace period to help businesses prepare for the full mandate.

Phase 2: Large Business Issuance (January 1, 2027)

From January 1, 2027, businesses with previous year revenue exceeding €800,000 must issue e-invoices for all B2B transactions. Key points:

• Revenue threshold based on prior year figures
• Applies to all domestic B2B invoices
• Cross-border invoices follow different rules

Phase 3: Universal Mandate (January 1, 2028)

From January 1, 2028, ALL businesses in Germany must issue e-invoices for B2B transactions, regardless of size. This includes:

• Small businesses (Kleinunternehmer)
• Freelancers and sole proprietors
• All GmbH, AG, and other company forms

Accepted E-Invoice Formats in Germany

Germany accepts the following EN 16931-compliant formats:

Format	Type	Best For
XRechnung	Pure XML	B2G, full automation
ZUGFeRD 2.x	Hybrid PDF/XML	B2B, visual + machine readable
Factur-X	Hybrid PDF/XML	International (identical to ZUGFeRD)

Important: Simple PDF invoices sent via email are NOT compliant with the e-invoice mandate. The invoice must contain structured, machine-readable data in XML format.

What is NOT an E-Invoice?

The following are explicitly excluded from the definition of a compliant e-invoice:

• ❌ PDF files sent via email (without embedded XML)
• ❌ Scanned paper invoices
• ❌ Word documents or spreadsheets
• ❌ Image files (JPG, PNG)
• ❌ EDI messages that don't comply with EN 16931

Exemptions and Special Cases

The mandate includes some exemptions:

• Simplified invoices: Invoices under €250 can remain in any format
• B2C transactions: Consumer invoices are not affected
• Cross-border: Different rules apply for international transactions
• Tax-exempt supplies: Some exemptions may apply

How to Prepare Your Business

1. Audit current processes: Review how you currently send and receive invoices
2. Ensure reception capability: Verify you can receive XRechnung/ZUGFeRD NOW
3. Choose your format: Decide between XRechnung (pure XML) or ZUGFeRD (hybrid)
4. Update your software: Ensure your ERP/accounting system supports e-invoicing
5. Train your team: Educate staff on new processes
6. Test with partners: Run pilot tests with key customers and suppliers

Penalties for Non-Compliance

While specific penalties are still being defined, non-compliance could result in:

• VAT deduction rejection for invoices not in proper format
• Delays in payment processing
• Potential fines for repeated non-compliance
• Audit flags from tax authorities

The German e-invoice mandate represents one of the largest e-invoicing rollouts in Europe. By starting your preparation now, you can ensure a smooth transition and even gain efficiency benefits from automated invoice processing.