E-invoicing in Germany: what founders need to do and when

E-invoicing in Germany: what founders need to do and when

Status as of 24 October 2026. General information, not legal or tax advice.

If you invoice other businesses in Germany, the e-invoice rules affect you, probably sooner than you think. Since 1 January 2025 every domestic business has to be able to receive an e-invoice. From 1 January 2027 the duty to issue e-invoices starts for businesses with more than EUR 800,000 of total turnover in the previous year, and from 1 January 2028 it applies to almost everyone else. A PDF sent by email is not an e-invoice.

Business groups asked for the 2027 step to be pushed back to 2028. As of October 2026 no legislative process for that has started, and reports from July 2026 say the federal government is holding to the deadlines. On 15 October 2026 the Federal Ministry of Finance (Bundesfinanzministerium, BMF) published a third letter on the topic that clarifies details without changing the dates.

What counts as an e-invoice

An e-invoice is an invoice created, sent and received in a structured, machine-readable format that follows the European standard EN 16931. In Germany two formats have established themselves: XRechnung (pure XML data) and ZUGFeRD (a PDF with an XML file embedded in it), the latter from version 2.0.1 and excluding the MINIMUM and BASIC-WL profiles.

Two points catch people out. First, a plain PDF, even one sent by email, is legally an "other invoice" (sonstige Rechnung), not an e-invoice. Second, with a ZUGFeRD file only the XML part is legally decisive. All mandatory VAT details must be in the structured data, and if the PDF and the XML differ, the XML wins.

Which format to use. XRechnung is the standard for invoices to public authorities, who often also require a routing ID (Leitweg-ID) on the invoice. ZUGFeRD is the usual choice for business customers, because the recipient gets a readable PDF and software gets the XML. Peppol is not a format but a network for sending e-invoices, and you can send an XRechnung through it. Check which of these your invoicing software supports before you need it.

The timeline

The rules apply to domestic business-to-business (B2B) invoices, meaning both sides are businesses based in Germany.

  • Since 1 January 2025: every business must be able to receive and process e-invoices and store them properly. There was no transition period for this.
  • Until 31 December 2026: issuers may still send paper invoices or other electronic formats such as PDF, as long as the recipient agrees.
  • From 1 January 2027: businesses whose total turnover in 2026 was above EUR 800,000 must issue e-invoices. Businesses at or below that limit may keep using paper or PDF with the recipient's consent until 31 December 2027. Existing electronic data interchange (EDI) procedures may also continue until the end of 2027 with the recipient's consent, whatever the turnover.
  • From 1 January 2028: the transition rules end. All domestic B2B businesses must issue e-invoices, except those covered by a permanent exception.

The turnover that counts is the total turnover of the previous calendar year, so for 2027 it is your 2026 turnover. Exactly EUR 800,000 is still inside the transition rule.

Who is exempt

Some exceptions are permanent and do not end in 2028:

  • Small-amount invoices (Kleinbetragsrechnungen) up to EUR 250 gross, and tickets (Fahrausweise).
  • Small businesses under section 19 of the VAT Act (Kleinunternehmer) do not have to issue e-invoices. They still have to be able to receive them.
  • Private customers and foreign customers. The obligation covers domestic B2B transactions, so invoices to private end consumers and to customers abroad are outside it.
  • Certain VAT-exempt services, for example exempt rental of real estate.

What to sort out in practice

Receiving. You need a way to receive and open structured invoices today, and software that can read them. A mailbox alone is not enough, because the XML file is not meant to be read by people.

Archiving. At a minimum, the structured part of every e-invoice has to be stored unchanged, complete and readable. Keeping only a PDF copy of a ZUGFeRD invoice does not meet that. Storage outside a dedicated system is accepted as long as the data cannot be altered.

Errors. The BMF distinguishes types of errors. An invoice with a business-rule error, such as a missing mandatory field, generally remains an e-invoice but should be corrected. An invoice that does not meet the format requirements at all is legally only an other invoice.

Consequences. According to the BMF letter of 15 October 2026, issuing an other invoice instead of a required e-invoice is not an administrative offence. It can still cause problems, for example for your customer's input VAT deduction, so do not treat it as harmless.

The 15 October 2026 letter. It introduces no new format. It adds clarifications, including relief for advance-payment and final invoices, construction services, gross-price invoices and mass business.

If you are founding a company now

A new company has to be able to receive e-invoices from its first day, and it will have to issue them at the latest from 2028. The EUR 800,000 limit looks at the previous calendar year, and the sources I found give no official answer for a company that has no full previous year, for example one founded in 2026 or later. Commentators disagree on whether and how a short first year is annualised.

You can sidestep the question. Issuing an e-invoice is always allowed, and the recipient's consent is not needed, so a new company that creates XRechnung or ZUGFeRD files from its first invoice is covered however the question is answered and never has to switch in 2027 or 2028. That is a good reason to choose invoicing and accounting tools that produce them from the start.

If you want to open a company now, Delegro runs the formation process for you. You complete the steps online, and the notary carries out the formation and checks identities. Start your company formation with Delegro.

Sources: Federal Ministry of Finance (BMF), letters of 15 October 2025 and 15 October 2026 on the mandatory e-invoice, and BMF FAQ (March 2026); section 27(38) of the VAT Act (Umsatzsteuergesetz) and sections 33 and 34a of the VAT Implementation Regulation (Umsatzsteuer-Durchführungsverordnung), as cited in the sources below; IHK Darmstadt, "E-Rechnung (B2B) seit 2025"; IHK Munich, "Elektronische Rechnungen (E-Rechnung)"; Zentralverband des Deutschen Handwerks (ZDH), "Elektronische Rechnung"; Grant Thornton Germany, "Mandatory e-invoicing from 2027"; Ecovis KSO, notes on the BMF letter of 15 October 2025; Sage, "E-Rechnung 2026: BMF-Klarstellungen"; ubs-tax.de and pandotax.de, summaries of the BMF letter of 15 October 2026; industrie-fachwissen.de, on the postponement debate (status 22 August 2026).