Businesses Operating in Germany
How should businesses prepare for Germany's B2B e-invoicing mandate?
Germany's Wachstumschancengesetz requires all VAT-registered German businesses to be able to receive structured e-invoices from January 2025, and to issue structured e-invoices from January 2027 (large companies) or January 2028 (smaller companies). The required format is a structured XML-based invoice conforming to EN 16931, such as XRechnung or Factur-X (ZUGFeRD). PDF invoices no longer satisfy the legal requirement after transition.
Which e-invoice formats are accepted in Germany?
Germany accepts any structured format conforming to EU norm EN 16931 for domestic B2B e-invoicing:
- XRechnung: Germany's native implementation of EN 16931 as pure XML (UBL or CII syntax); mandatory for public sector
- ZUGFeRD 2.x: German hybrid PDF/A-3 and XML format equivalent to Factur-X; accepted for private sector B2B
- Peppol BIS Billing 3.0: Accepted when transmitted via Peppol network; used where buyer has Peppol address
- Other EN 16931 formats: Any other format meeting EN 16931 data requirements in a structured machine-readable syntax
- Not accepted: PDF-only invoices (even if data was once structured), Word documents, images
Frequently Asked Questions
- From when must German businesses accept structured e-invoices?
- All German VAT-registered businesses must be technically capable of receiving structured e-invoices from January 1, 2025. This means businesses must have a process to receive and read structured XML or hybrid PDF/A-3 invoices. Rejecting compliant e-invoices from suppliers could create dispute and payment delay issues. Businesses that are not yet capable of processing the structured content can store the files and manually enter data.
- Do German small businesses need to issue e-invoices?
- Small businesses using the Kleinunternehmerregelung VAT exemption are exempt from German e-invoicing obligations. VAT-registered businesses with revenue below EUR 800,000 have until January 2028 to begin issuing structured e-invoices. However, all businesses, regardless of size, must be able to receive structured e-invoices from January 2025.