E-Invoicing in Germany

The obligation comes from the Growth Opportunities Act, which the Bundesrat approved on March 22, 2024. According to the Federal Ministry of Finance (in German), invoices between domestic businesses have had to be e-invoices since January 1, 2025, with transition rules. Every business must be able to receive them, and an email inbox is enough for that. Businesses with a prior-year turnover above 800,000 euros must issue e-invoices from January 1, 2027, and all others from January 1, 2028, as the ClearTax guide and the VAT IT guide set out.

Invoices to consumers and cross-border invoices are outside the mandate, and so are invoices up to 250 euros and passenger tickets. Small businesses under section 19 of the VAT Act do not have to issue e-invoices but must be able to receive them.

An e-invoice must follow the European standard EN 16931. The ministry names XRechnung and ZUGFeRD from version 2.0.1, except for the profiles MINIMUM and BASIC-WL. Peppol BIS Billing 3.0 also meets the standard. Germany has no central platform for invoices between businesses and no clearance before an invoice is sent: the parties choose the channel, which can be email, the Peppol network, EDI or a portal. Invoices to public authorities also need a Leitweg-ID; invoices between businesses do not.

The EN 16931 data model has a group of fields for payment instructions, and the German rules make it mandatory. It holds the means of payment, the payee's account, usually an IBAN, and an optional remittance reference that the seller issues to link the payment to the invoice. Accounts payable can build the SEPA payment file from these fields, and the seller can match the incoming transfer by the reference.

A machine-readable IBAN is still a target for fraud. An invoice with changed bank details is a common attack on finance departments, and verification of payee checks the name behind the IBAN before a euro transfer leaves. For invoices that should be paid on a due date, SEPA Request-to-Pay sends a payment request with the reference attached.

The EU's VAT in the Digital Age package, adopted by the Council on March 11, 2025, makes e-invoicing and near real-time reporting mandatory for transactions between businesses in different member states from July 1, 2030, according to the European Commission. German businesses will then need e-invoices for their EU customers too, and the invoice data will go to the tax authorities.

Finance Loop is the meeting place for the payments side of e-invoicing: banks, payment institutions and treasury teams who turn invoice data into payments. It connects the finance, IT and AI communities in Germany, Austria and Switzerland, with events in Frankfurt, Munich, Berlin and Hamburg.

Finance Loop supports When Banks Say 'No', a half-day payments seminar in Frankfurt for compliance, treasury, finance, export and legal teams on blocked payments, de-risking and sanctions. Finance Loop is also media partner of Capital & Code, a Frankfurt conference whose audience includes corporate treasurers who manage liquidity and risk.

Receiving e-invoices from German businesses has been mandatory since January 1, 2025. Issuing them is mandatory from January 1, 2027 for businesses with a prior-year turnover above 800,000 euros and from January 1, 2028 for all other businesses.

No. A PDF is an image of an invoice. An e-invoice is issued, sent and received in a structured format that software can read, such as XRechnung or the XML part of a ZUGFeRD file.

Formats that follow EN 16931, in practice XRechnung, ZUGFeRD from version 2.0.1 without the profiles MINIMUM and BASIC-WL, and Peppol BIS Billing 3.0. Other EDI formats are allowed if the data can be extracted in line with the standard.

Peppol is one allowed channel for invoices between businesses, but not a mandatory one. It is used for invoices to some public authorities.