Briefing document & Podcast: Germany E-Invoicing B2B Mandate, Timeline and Compliance

Last update: November 12, 2025

• Public Sector (B2G) – Already in place: Since November 2019, all German public authorities must accept structured e-invoices (EN 16931 standard) for public procurement contracts. At the federal level, e-invoices (in format XRechnung) became mandatory for suppliers by late 2020 (with state authorities following by April 2020). [ec.europa.eu]
• Business-to-Business (B2B)
  • Phased introduction: Starting 1 January 2025, electronic invoicing becomes the default for domestic B2B transactions. From that date, all businesses must be able to receive e-invoices in a compliant format, and they may issue e-invoices without needing customer consent (ending the primacy of paper invoices). However, 2025–2026 is a transition period: businesses can still use paper or non-EN16931 PDF invoices if they choose (these “legacy” invoices remain valid for VAT purposes during the transition).
  • From 1 January 2027, large companies (annual turnover over €800,000) are required to issue only e-invoices for in-country B2B sales.
  • By 1 January 2028, the e-invoicing mandate extends to all businesses for domestic B2B transactions. (In other words, paper or unstructured invoices will no longer be permitted for B2B in-country sales after 2027 for large firms, and after 2028 for everyone.) [ec.europa.eu], [ec.europa.eu] [finanzamt.bayern.de] [bundesfina…sterium.de], [bundesfina…sterium.de] [ec.europa.eu]
• E-Reporting (Digital VAT Reporting)
  • Upcoming EU-level mandate: Germany has not yet implemented a domestic real-time invoice reporting system, but it is preparing to follow the EU’s “VAT in the Digital Age (ViDA)” roadmap. On 11 March 2025, EU finance ministers approved EU-wide measures requiring that by 2030 all cross-border B2B sales within the EU be reported electronically in near real-time, using e-invoices as the data source.
  • The current plan is that by 1 July 2030, businesses must issue intra-EU B2B invoices in a structured electronic format, and transmit the invoice data to tax authorities at the time of issuance (replacing the periodic EU sales list). Germany is expected to implement these EU reporting requirements on that timeline. (Notably, as of 2025, Germany has not introduced any national B2B invoice clearing portal or real-time reporting ahead of the EU schedule.) [consilium.europa.eu] [consilium.europa.eu], [ebnerstolz.de] [ebnerstolz.de], [ebnerstolz.de] [ec.europa.eu]

• Domestic B2B Transactions: The new e-invoicing rules apply to business-to-business supplies within Germany. Whenever a VAT invoice must be issued for a domestic B2B sale of goods or services, it generally needs to be an electronic invoice (after the transition period). This covers all in-country taxable B2B transactions except specific exemptions (see below). [bundesfina…sterium.de], [finanzamt.bayern.de]
• Business-to-Government (B2G): E-invoicing for sales to the public sector is governed by separate public procurement laws. In practice, B2G invoices in Germany are already required to be electronic (in formats like XRechnung) due to the EU Directive 2014/55/EU. All federal and state authorities in Germany must accept EN 16931-compliant invoices, and suppliers are effectively obliged to use them for public contracts. (The new 2025 mandate for B2B e-invoices does not alter B2G rules – it primarily targets B2B commerce in the private sector.) [ec.europa.eu], [ec.europa.eu] [bundesfina…sterium.de], [bundesfina…sterium.de]
• Business-to-Consumer (B2C): Consumer invoices are excluded. The obligation to issue e-invoices does not apply to B2C transactions. Invoices to private end customers remain optional, and if issued, they can be paper or electronic at the business’s discretion. (German VAT law generally doesn’t require an invoice for B2C sales in most cases, hence the e-invoicing mandate focuses on B2B only.) [bundesfina…sterium.de], [bundesfina…sterium.de] [bundesfina…sterium.de], [finanzamt.bayern.de]
• Cross-Border Transactions: International and intra-EU transactions are currently out of scope of Germany’s national e-invoicing mandate. The 2025–2028 phased requirement applies to in-country (innerdeutsche) B2B supplies. For intra-EU B2B sales, the upcoming EU-wide mandate in 2030 will apply (requiring e-invoices and digital reporting for cross-border sales). Until then, sending a regular invoice (paper or PDF) for cross-border B2B remains acceptable under German rules. Exports to non-EU countries and imports are likewise not covered by the domestic e-invoice requirement (they fall outside “inland” transactions). [finanzamt.bayern.de] [ebnerstolz.de], [ebnerstolz.de]
• Exemptions: Certain transactions that are generally exempt from VAT or from invoice requirements are not subject to the e-invoice mandate. Notably, if no invoice is legally required, the mandate doesn’t create one. For example, VAT-exempt transactions (under §4 Nos. 8–29 UStG, e.g. many financial services or medical services) and sales by small businesses under the small entrepreneur scheme (§19 UStG) remain exempt from having to issue invoices, thus e-invoicing is not mandatory for those. Low-value invoices (up to €250 gross) and certain tickets (e.g. transit fare tickets) can still be issued as simplified receipts and are excluded from the e-invoicing obligation. In summary, the law carves out small invoices, invoices by VAT-exempt or flat-rate farmers/entrepreneurs, and B2C receipts from the e-invoice requirement. All other taxable B2B supplies in Germany are in scope. [bundesfina…sterium.de], [finanzamt.bayern.de]

• The e-invoicing mandate applies to “inländische Unternehmer”, meaning any business established or with a permanent establishment in Germany that is making taxable supplies domestically. This includes German companies and also foreign businesses that have a registered branch or similar fixed establishment in Germany. (In practice, nearly all VAT-registered businesses located in Germany fall under this mandate for their B2B sales.) [bundesfina…sterium.de]
• Foreign businesses without a German establishment (but merely VAT-registered for certain transactions) are generally not required to issue e-invoices under the German rules if they are not based in Germany. The official guidance notes that foreign entrepreneurs who are only VAT-registered in Germany (with no seat or fixed establishment in-country) can indicate on their invoice that they have no German establishment to explain why they are issuing a paper/PDF invoice. In such cases, the German customer may accept a non-e-invoice if the supplier is truly foreign. [bundesfina…sterium.de]
• All sizes of businesses are included (large and small), but as noted in the timeline, small businesses under €800k turnover have a longer grace period until end of 2027 to comply with issuing e-invoices. Additionally, businesses using older EDI invoicing systems that don’t meet the new standard can continue using them until end of 2027 (to give them time to upgrade). By 2028, all active VAT-registered businesses in Germany (aside from the exempt categories mentioned) must use structured e-invoices for B2B. [bundesfina…sterium.de], [bundesfina…sterium.de]
• Ability to receive: Importantly, every in-scope business must be capable of receiving e-invoices from 1 Jan 2025 onward. This is a broad requirement: even businesses who themselves are exempt from issuing (e.g. small businesses, or those still in transition) must set up a way to accept e-invoices from their suppliers. (The rationale is that e-invoicing can only be effective if all parties can actually receive them.) In practice, having a simple email inbox for PDF/XML invoices is considered sufficient to meet the reception requirement – a dedicated IT system or portal is not mandatory for receiving. [bundesfina…sterium.de], [bundesfina…sterium.de]

• Structured Format (EN 16931): Under the new definition effective 2025, an “E‑Rechnung” (electronic invoice) is only recognized if it is in a structured electronic format that meets the European standard EN 16931. This ensures the invoice can be automatically processed. Simply emailing a PDF no longer counts as an e-invoice (PDF is considered an unstructured format). The accepted standard format is XML-based data following EN 16931’s model for invoice fields. [bundesfina…sterium.de], [bundesfina…sterium.de] [bundesfina…sterium.de]
• National Standards – XRechnung and ZUGFeRD: Germany’s ordinance identifies XRechnung (the XML schema CIUS developed for Germany’s public sector) and ZUGFeRD (a hybrid PDF/XML format) as compliant e-invoice formats, so long as they adhere to EN 16931 requirements. In particular, XRechnung is the core format used by authorities and many businesses, and ZUGFeRD 2.0.1 or higher (except its minimal subsets) is also acceptable for B2B invoices. These formats encapsulate the full invoice data in structured form. (Other EN 16931-compliant formats, such as the French “Factur-X” which is equivalent to ZUGFeRD, or pure XML like UN/CEFACT, are likewise acceptable in principle.) What’s crucial is that all required invoice information is present in the machine-readable data. [bundesfina…sterium.de] [finanzamt.bayern.de], [bundesfina…sterium.de]
• Required Data Fields: An e-invoice must contain all the information legally required for a VAT invoice – now embedded in the structured XML. German law (§14 UStG) mandates certain fields (seller and buyer name/address, VAT ID for intra-EU sales, invoice date and number, date of supply, description of goods/services, quantity, net amount, applicable VAT rate, VAT amount, etc.). The EN 16931 standard defines these core elements and ensures each is captured in a dedicated data field. For instance, the invoice must include the seller’s and buyer’s VAT identification, itemized charges, tax rates, and references like purchase order or Leitweg-ID (for B2G) in structured form. All the obligatory content for VAT purposes must be in the electronic dataset – simply attaching an unstructured document or image is not enough. (If a PDF image of the invoice is included in a hybrid file, the XML data must match it; in case of any discrepancy, the XML data are deemed authoritative from 2025 onward.) In summary, the e-invoice needs to convey the complete invoice details in a format that can be read by software without manual re-keying. [ebnerstolz.de] [bundesfina…sterium.de] [bundesfina…sterium.de], [bundesfina…sterium.de]
• Transmission Method: The law is technology-neutral about how e-invoices are exchanged – there is no single mandated platform or clearing system in Germany (unlike Italy’s SdI). Businesses can send e-invoices via email, via existing EDI networks, through portals or even physical media if needed. The only requirement is that the format of the invoice file itself is structured. (For example, a supplier might email an XML or a ZUGFeRD PDF to the buyer, or use a service like Peppol to transmit an invoice. All these methods are acceptable.) Both parties can agree on which e-invoice format and channel to use, as long as the format meets the data standards for a valid e-invoice. [bundesfina…sterium.de], [bundesfina…sterium.de] [bundesfina…sterium.de]
• E-Reporting Format: Germany’s future e-reporting obligations (for sharing data with tax authorities) will likewise be built on the EN 16931 standard. The EU’s planned “Digital Reporting Requirements” system will require that the invoice data for each transaction is submitted in a structured electronic form. In practice, this means the information from the e-invoice will be transmitted to the tax authority in a standardized schema. The scope of data to be reported includes line-item details of the transaction: who the buyer and seller are, tax amounts, dates, etc., essentially mirroring the content of the e-invoice. Unlike the current system of summary VAT filings, the upcoming regime will collect invoice-level data (each invoice reported individually rather than aggregated totals). This granular reporting is aimed at real-time tax oversight and will use the same data points that are present on a compliant e-invoice. (In short, the e-invoice you issue to your customer will also be the data you send to the Behörden for E-Reporting – there aren’t extra fields beyond what a full VAT invoice requires, except some meta-data like invoice issuance date/time.) [ebnerstolz.de], [ebnerstolz.de] [ebnerstolz.de]

• Domestic Invoices: Germany’s new e-invoicing law does not institute a real-time government submission for domestic invoices. Businesses are not required to send each invoice to the tax authority under the 2025 national rules. The e-invoice must be issued to the buyer on time, but it is exchanged directly between supplier and customer (peer-to-peer or via service providers), not through a tax authority platform. Tax authorities will see these transactions only via the normal VAT returns or if audited. In practical terms, the due dates for reporting domestic invoices remain the usual VAT filing deadlines (e.g. monthly/quarterly VAT returns by the 10th of the following month, etc.), as no invoice-by-invoice report is required yet. Businesses should still issue invoices within the general timeframe required by law (usually by the 15th of the next month for EU VAT directive compliance), but there is no new immediate “upload” obligation in 2025. [ec.europa.eu], [ec.europa.eu]
• Cross-Border E-Reporting: With the adoption of the EU’s ViDA package, a near-real-time reporting system will be introduced for intra-EU B2B transactions in the coming years. Once in effect (expected 2030), German companies making cross-border B2B supplies will have to submit the invoice data electronically to the German tax authority at the time of issuance of the invoice. The planned rule is that the data must be transmitted by the moment the invoice is issued (or should have been issued). In specific cases like self-billing (Purchaser issuing an “E-Gutschrift”) or certain reverse-charge reports, a grace period of up to 5 days will be allowed for the submission. However, for the majority of invoices, reporting will be effectively instantaneous or same-day. This granular reporting will cover: intra-EU B2B goods supplies, intra-EU B2B services, triangulation transactions, and any B2B transaction where the VAT is shifted to the recipient (reverse charge) across EU borders. Each such invoice’s details will be transmitted to the Federal Central Tax Office, replacing the current Zusammenfassende Meldung (summary listings) which are done monthly/quarterly. The due date for these reports will coincide with invoice issuance (no longer a month-end summary; it’s effectively real-time). [ebnerstolz.de] [ebnerstolz.de], [ebnerstolz.de]
• No Domestic Real-time Mandate (Yet): It’s worth noting that Germany has not announced a domestic real-time reporting for B2B invoices beyond the EU’s cross-border scope. Some EU countries plan to extend real-time reporting to all invoices, but Germany appears to be waiting for the harmonized EU approach. As of now, domestic B2B invoices will not be systematically reported to the tax office in real time – only the usual VAT return deadlines apply. This could change in the future if Germany opts for a national reporting system, but any such change would require further legislation (and none is adopted yet aside from aligning with the EU requirements). [ec.europa.eu]

• Failure to Issue E-Invoices: Once the mandate is fully effective, not issuing an invoice in the required format (i.e. issuing a paper or non-structured invoice when an e-invoice is legally required) can be considered a breach of Germany’s invoicing rules. Under §26a UStG (German VAT Act’s penalty provisions), failing to issue a proper invoice is an administrative offence. The law provides for fines of up to €5,000 for not issuing an invoice on time or in the prescribed manner. In other words, a company that refuses to use e-invoices when obliged could face penalties. Tax authorities have indicated that an outright failure to comply with e-invoicing requirements would fall under these existing fine provisions (assuming the violation is willful or negligent). [haufe.de] [haufe.de], [haufe.de]
• Transition Period Leniency: During the transition phase (2025–2026, and up to 2027 for small businesses/EDI users), using paper or legacy invoices is explicitly allowed by law, so it is not penalized. Through the end of 2026, any business may still issue a “sonstige Rechnung” (paper or simple PDF) without breaking the law. Likewise, small businesses under the turnover threshold may do so until end of 2027. Because these grace periods are in place, the Ministry of Finance has indicated that no fines will be levied for using non-e-invoices during the allowed transition. Enforcement is expected to be educational in the early phase. [bundesfina…sterium.de], [bundesfina…sterium.de] [bundesfina…sterium.de] [haufe.de]
• Post-Deadline Enforcement: After e-invoicing becomes fully mandatory (2027/2028 onward), non-compliance will carry the usual consequences. A business that continues to issue invoices improperly (e.g. sends only paper invoices in 2028 without a valid exemption) could incur administrative fines up to €5,000 per offense. In addition, such a violation may raise issues in VAT audits – for example, a buyer needs a “proper invoice” to claim input VAT, and if the supplier fails to provide an e-invoice where required, the tax office might deny the VAT deduction until a compliant invoice is produced. Thus, non-compliance risks both financial penalties and tax assessment problems. That said, German officials have so far not introduced any new, higher penalties specifically for e-invoicing; the enforcement will rely on existing invoice rules. (There is no separate criminal penalty, it remains an administrative (Ordnungswidrigkeit) issue unless fraud is involved.) [haufe.de]
• E-Reporting Non-compliance: Although details will come as the EU rules are implemented, failure to submit the required data in the upcoming digital reporting system would likely be treated similarly to failures to file VAT returns or summary reports. We can expect that late or missing transactional reports will incur fines or penalties, per whichever limits German law sets (likely in line with the €5,000 fine range, or potentially higher for systematic neglect – to be defined in implementing legislation). Additionally, for cross-border transactions, not reporting an invoice might jeopardize the VAT zero-rating (for an intra-EU supply) just as a missing EU sales list could today. In short, businesses should plan to comply timely to avoid both fines and VAT treatment issues once e-reporting kicks in.

• XRechnung: This is the primary format for German e-invoices. It’s an XML schema defined by KoSIT (the German IT Standards Coordination Office) and fully compliant with EN 16931. XRechnung has been used in B2G invoicing for years and is now the reference for B2B as well. All mandated e-invoices can be issued as XRechnung files. They contain structured XML data for every required field (with no PDF component). German authorities provide free tools (e.g. an ELSTER portal viewer) to display XRechnung invoices for human reading. [finanzamt.bayern.de] [bundesfina…sterium.de]
• ZUGFeRD: This is a hybrid PDF format (developed by the Forum Elektronische Rechnung Deutschland) which embeds an XML file inside a PDF. ZUGFeRD 2.1 (which conforms to EN 16931) is accepted as an e-invoice format for the mandate. It has the advantage of providing a human-readable PDF version along with the machine-readable XML. (Germany allows all ZUGFeRD profiles except the very minimal ones – profiles Minimum or Basic-WL are not sufficient, as they lack some data fields.) Using ZUGFeRD, a supplier can send a single PDF file that serves both as a visual invoice and as structured data. Many ERP systems in Germany support ZUGFeRD for B2B use. [bundesfina…sterium.de]
• Other Formats: The law is open to any format that meets the EN 16931 standard. For instance, the French “Factur-X” format is essentially the same as ZUGFeRD (they are jointly developed) and is acceptable in Germany. Standard EDI formats (like EDIFACT) can also qualify as e-invoices if they contain all the required data in structured form. Companies with industry-specific XML invoice formats can continue using them by bilateral agreement, as long as those contain all mandatory data and allow accurate import of that data. In summary, EN 16931 compliance is key – Germany does not dictate a single technical format to use, but XRechnung is provided as the default reference implementation. [finanzamt.bayern.de] [bundesfina…sterium.de]
• Transmission for Reporting: For the future EU e-reporting, we anticipate the format for submitting data will be standardized (likely an XML schema or JSON as defined by EU/Member State tax authorities). It will presumably use the same data fields from the e-invoice. The exact format in Germany will be determined when transposing the EU directive. It may involve using the existing ELSTER system or a new portal to upload/send invoice data. Since Peppol is widely used for sending e-invoices in Europe, it might also play a role in how data is reported to authorities. In any case, the content of the “report” will mirror the invoice content (e.g. a submission file containing buyer, seller, date, value, tax, etc. for each invoice). German authorities have not published the technical schema yet for the coming e-reporting, but the structure will align with the information in an EN 16931 invoice. [ebnerstolz.de], [ebnerstolz.de]

• No Pre-filled Returns as of 2025: Germany currently does not provide pre-populated VAT returns based on invoice data. The shift to e-invoicing does not (at this stage) come with any system where the tax administration prepares draft VAT declarations for taxpayers. Since there is no real-time central collection of B2B invoice data by the tax authorities in Germany yet, the tax office cannot pre-fill your VAT return – businesses must continue to calculate and file their own VAT advance returns (Umsatzsteuer-Voranmeldungen) and annual returns. The e-invoices you send or receive stay between you and your trading partner (similar to the old paper process) and are not automatically mirrored into your VAT return by the tax office. [ec.europa.eu]
• Future Possibilities: The idea of pre-filled VAT returns could become more feasible once the digital reporting of each invoice to authorities is in place (as planned for intra-EU transactions by 2030). In some countries with invoice clearance (e.g. Italy), tax authorities use the reported data to offer partially pre-filled VAT statements. Germany has not announced such measures, and the initial focus is on using e-invoicing/reporting to improve compliance and auditing, rather than to prepare taxpayers’ returns for them. As of now, no pre-populated VAT return system is implemented in Germany – taxpayers will still manually compile VAT figures from their records. The monthly/quarterly VAT filings and the annual VAT return remain an exercise for the taxpayer, using the data from their own bookkeeping (though, of course, e-invoicing should make that bookkeeping more accurate).
• Conclusion: There are no pre-filled VAT returns provided by the German tax authorities under the e-invoicing mandate. All VAT declarations must be completed and submitted by businesses as before. The e-invoicing and upcoming e-reporting reforms are aimed at closing the VAT gap and easing audits (and may eventually reduce the effort of compiling data), but at this stage taxpayers will not receive an automated VAT return draft from the authorities. Any change to that would be a future development following successful implementation of real-time reporting across the EU. [ec.europa.eu]

• See also
  • E-Invoicing/Real Time Reporting – What can you find on VATupdate.com
  • Worldwide Upcoming E-Invoicing mandates, implementations and changes – Chronological
  • Collection of E-Invoicing Guides – Worldwide – VATupdate
  • Briefing / Comprehensive Guides (incl. podcasts)

• Join the Linkedin Group on Global E-Invoicing/E-Reporting/SAF-T Developments, click HERE