eInvoicing in Germany

eInvoicing Mandates in Germany: Germany mandates electronic invoicing for public sector contracts (B2G) since November 2019, requiring structured eInvoices compliant with the European standard EN 16931. However, there are no current mandates for business-to-business (B2B) or business-to-consumer (B2C) invoicing, although B2B eInvoicing will become mandatory progressively from 2025, with full compliance expected by 2028.
Standards and Formats: The European eInvoicing standard EN 16931 has been adopted, with XRechnung and ZUGFeRD 2.1 being the primary formats for eInvoices in Germany. Public contracting authorities are required to accept these formats, ensuring compliance and interoperability across systems.
Operating Model and Future Steps: Germany operates a decentralized model for eInvoicing, with various platforms for public authorities and the requirement for Peppol transmission for automated exchanges. While there is currently no VAT real-time reporting system or monitoring mechanism for eInvoicing developments, the framework is set for future enhancements as B2B requirements evolve.

Scope

Transaction Type	Entity Type	E-Invoicing Mandatory?	E-Reporting Mandatory?	Notes
B2G	Established	✅ Yes (Receiving only)	❌ No	Public authorities must accept EN 16931 eInvoices; suppliers encouraged.
	Non-Established	✅ Yes (Receiving only)	❌ No	Same rules apply for foreign suppliers to public bodies.
B2B	Established	Yes (from 2025 onward)	❌ No	Receiving mandatory from 2025; issuing phased in by 2028.
	Non-Established	❌ No	❌ No	No mandate yet for foreign suppliers/customers.
B2C	Established	❌ No	❌ No	No legal requirement for eInvoicing or eReporting.
	Non-Established	❌ No	❌ No	Same as above.

️ Key Dates for B2B E-Invoicing Rollout

Date	Requirement
Jan 1, 2025	All businesses must be able to receive EN-compliant eInvoices.
Jan 1, 2027	Businesses with turnover > €800,000 must issue structured eInvoices.
Jan 1, 2028	All businesses must issue structured eInvoices.

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