E-invoicing in Germany: who must do what, and when

E-invoicing in Germany is mandatory in three steps: since 1 January 2025 every German business must be able to receive e-invoices; from 1 January 2027 businesses with more than 800,000 euros of turnover in 2026 must issue them; and from 1 January 2028 every business issues them for domestic B2B sales. Until then, paper and PDF invoices remain allowed for the businesses still in the transition, with the customer's consent.

The rule sits in section 14 of the German VAT Act (UStG), with the transition in section 27. The Federal Ministry of Finance explained it in two letters, of 15 October 2024 and 15 October 2025. Germany takes its own road in one way that matters for every supplier: it fixes the format, not the channel. An invoice that follows the European standard EN 16931 counts as an e-invoice whether it arrives by email, through a portal or over Peppol.

This guide covers the timetable, the formats that count and the ones that do not, the exceptions, and what a Belgian, Dutch or other foreign supplier of a German customer needs to do.

The threshold looks at the total turnover of the previous calendar year. A business that crosses 800,000 euros in 2026 loses the extra year.

What counts as an e-invoice in Germany

An e-invoice is a structured electronic file that follows EN 16931 and that software can read without a person typing it over. A PDF, a scanned image or a Word file is not, even if it travels by email.

Invoices up to 250 euros, the German small-amount invoice, stay outside the e-invoice duty. Sales to consumers are not covered at all.

The channel: email is enough

Germany does not prescribe a network. An e-invoice can arrive as an email attachment, through a customer portal, over EDI or over Peppol. That makes it the easiest country to start in and the hardest to automate: a German buyer receives XRechnung files by email from one supplier and ZUGFeRD PDFs from another. Large buyers increasingly ask for Peppol so they can process everything in one stream.

What a foreign supplier of a German customer does

The German mandate applies to sales between businesses established in Germany. A Belgian, Dutch or other foreign supplier without a German establishment is not obliged to issue e-invoices to German customers. In practice the question comes anyway, because German customers have set up their accounting to receive e-invoices and want every supplier in the same stream.

The practical answer: if you already send Peppol invoices for Belgium, you can send the same UBL invoice to German customers who are on Peppol, or as an attachment to those who are not. The VAT treatment of a cross-border sale, usually the reverse charge, is a question for your accountant.

Common mistakes

• Treating a PDF as an e-invoiceA PDF without the embedded XML is an "other invoice" and is only allowed during the transition.
• Sending ZUGFeRD MINIMUM or BASIC-WLThose profiles lack the data the standard requires.
• Forgetting the receiving sideSince 2025 your German entity must be able to receive and read e-invoices, not just store them.
• Missing the 2027 thresholdTurnover above 800,000 euros in 2026 means e-invoices from the first day of 2027.

Germany in the European picture

Germany is one of eight countries with a B2B mandate in force on 24 October 2026, next to Italy, Romania, Belgium, Croatia, Poland, Greece and France. It is the only large one that leaves the channel free. The full overview, with dates and models per country, is in e-invoicing in Europe; Belgium, next door and on Peppol since 1 January 2026, is in e-invoicing in Belgium.

Three suppliers with German customers

• A Belgian wholesaler with forty German customersIt has been on Peppol for its Belgian customers since 2026. German customers on Peppol get the same UBL invoice over the network; the rest get the UBL file by email, which counts as an e-invoice in Germany.
• A Dutch software company with German subscribersIts invoices come out of a subscription system that makes PDFs. An export to UBL or XRechnung turns them into e-invoices that German customers book automatically.
• A British company with a German GmbHFor what the GmbH itself sells, the German timetable applies: receive since 2025, issue in 2027 if 2026 turnover was above 800,000 euros, otherwise in 2028.

A plan for your German customers

1. Ask which format and channel they want. XRechnung, ZUGFeRD or UBL; by email, through a portal or over Peppol.
2. Pick one format you can use everywhere. UBL under EN 16931 works over Peppol, for Belgian customers and in Germany.
3. Switch on receiving. German suppliers will send you e-invoices too, and your accounting has to read them.
4. Test with a customer you know well. An invoice their software reads without errors is the only real test.
5. Keep a list per customer. Format, channel and address per customer stop invoices landing in the wrong place.